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Home My WebLink AboutDRC-2017-002050 - 0901a068806d40ea........ State of Utah GARY R HERBERT Governor Spencer J Cox Lieutenant Governor Department of Environmental Quality Alan Malheson Executive Director DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Scott T. Anderson Director DRC-ZOlY- 001050 MEMORANDUM TO: THROUGH: FROM: DATE: File C-2017-16 Heather Mickelson, P.E., Peer Reviewer Phil Goble, Section Manager Russell J. Topham, P.E. March 9,2017 SUBJECT: Engineering Module 73. Inspection of Disposal of Bulk Byproduct Material February 27, 2017. Radioactive Material License UT1900479 (License) - Energy Fuels Resources (USA) Inc. (EFR) White Mesa Mill, Blanding, Utah On February 26, 2017, 1 traveled to the White Mesa Uranium Mill to perform multiple inspections, including an inspection of in-situ leach (ISL) waste disposal operations on behalf of the Utah Division of Waste Management and Radiation Control (DWMRC). Heather Mickelson, also representing the DWMRC, accompanied me. This report pertains to the waste disposal operation inspection and responds to 1 le.(2) Byproduct Receipt Notification letters from Energy Fuel Resources (EFR) dated January 24 and February 10, 2017. EFR is allowed by License Condition 10.5 of its Radioactive Material License to dispose this byproduct material in Tailings Cell 3 only. On January 25, 2017 and February 14, 2017, the DWMRC received notices that EFR would receive a total of three loads of 1 le.(2) byproduct material, and intended to dispose that waste in Cell 3 on February 10, 2017 and February 27, 2017. Inclement weather prevented work crews from performing the disposal operation intended for February 10; that operation was delayed until February 27. Three loads were received. We checked in at the White Mesa Mill at 8:00 AM on February 27, 2017, and asked to see David Turk, Site Manager for Environmental Health and Safety. Mr. Turk was not available, and we were escorted by Garrin Palmer to oversee the disposal operation. At approximately 9:20 AM, the crew assembled at a previously excavated disposal area with the requisite equipment (a loader). Two loads of waste were disposed in one excavation, and one load in another excavation. The field crew used the appropriate paperwork, i.e. Revision 3.3 of Procedure PBL-10, to guide the operation. Approximate burial sites are located on the attached partial map of Tailings Cell 2. Material disposed in the first excavation consisted of piping and other debris, much of it bagged miscellaneous waste from the ISL plant near Nichols Ranch, Wyoming. These loads bore Shipper Numbers NR-008-cpp and NR-009-wf, and were shipped by Greenfield Logistics. As can be seen in the 195 North 1950 West • Salt Lake City, UT Mailing Address PO Box 144880 • Salt Lake Cit>', UT 84114-4880 Telephone (801) 536-0200 • Fax (801) 536-0222 • T D D (801)903-3978 mww.deq.utah.gov Printed on 100% recycled paper C-2015-54 Memorandum: Inspection of November 11, 2016 Page 2 attached photo log (Photo 6), the bagged debris floated, so the burial could not be concluded at the time of inspection. Crews pumped fluid out of the excavation, and then finished the burial. The licensee supplied photographs (attached to this Memorandum following the photo log) to document completion of the operation. Material disposed in the second excavation consisted of soil from the ISL plant near Mestena, Texas. This load bore Shipper Number 165, and was shipped by Energy Fuels Resources Alta Mesa. This burial operation was carried to completion, as shown in the attached photo log. Densification by wheel-walking resulted in a non-yielding surface. Mr. Palmer surveyed the level at the bottom of the excavation prior to waste placement. Using a front-end loader, the crew placed the waste in the excavations and tamped it down. Mr. Palmer then surveyed the elevation of the top of the waste, and the crew filled the excavation to the top with soil. The survey documentation and map in the attachments verify that the waste placement envelope falls at or above the surface of tailings, within the platform fill layer, and well away from the cell bottom liner. The bill of lading for each load appears in the attachments to this report. I discussed the inspection with Logan Shumway, Mill Manager, prior to departing. EFR appears compliant with Part 10.5.E.(2) of the RML with respect to the elevation of burial. It appeared that all provisions of the approved disposal SOP Number PBL-10 Revision 3.3 were followed during placement and burial of the bulk waste. Finding: EFR appears to have followed applicable provisions of the RML and of the SOP for the burial operation. Recommendation: I recommend closing out the inspection of February 27, 2017. Attachments: Receipt Notifications dated January 24 and February 10, 2017 Bill of Lading and Disposal Documentation for each load disposed Photos of the disposal operation - both those taken by DWMRC and taken by EFR Map of disposal locations ENERGY FUELS Energy Fuels Resources (USA) Inc. 6425 South Highway 191, PO Box 809 Blanding, UT. US, 84511 435 678 2221, fax 435 678 2224 www.energyfuels.com Div of Waste Management and Radiation Control January 24,2017 JAN 2 5 2017 VIA Electronic Mail (PDF) and UPS DRC-zm- 000663 Mr. Scott Anderson Director of Waste Management and Radiation Control State of Utah Department of Environmental Quality 195 North 1950 West PO Box 144880 Salt Lake City, UT 84114-4880 Dear Mr. Anderson, Re: 1 le.(2) Byproduct Receipt Notification Pursuant to Radioactive Materials License (RML) 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 two load of 1 le.(2) byproduct material by February 10, 2017. If there are any questions regarding these shipments or the scheduling of the disposal activities feel free to contact me at the White Mesa Mill at 435.678.4113. Regards, David Turk Environmental Health & Safety Manager Energy Fuels Resources (USA) Inc. cc: Denver Central Files Mm:m' ENERGY FUELS Energy Fuels Resources (USA) Inc. 6425 South Highway 191, PO Box 809 Blanding, UT. US, 84511 435 678 2221, fax 435 678 2224 www.energyfuels.com Div of Waste Management and Radiation Control February 10, 2017 FEB M 2017 VIA Electronic Mail (PDF) and UPS WOZDM-WttZB Mr. Scott Anderson Director of Waste Management and Radiation Control State of Utah Department of Environmental Quality 195 North 1950 West PO Box 144880 Salt Lake City, UT 84114-4880 Dear Mr. Anderson, Re: 1 le.(2) Byproduct Receipt Notification Pursuant to Radioactive Materials License (RML) 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 of 1 le.(2) byproduct material by February 27, 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 No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC. Rev. No.: R-3.3 STANDARD OPERATING PROCEDURES Page 11 of 13 Date: November 13, 2014 Title: 11e.(2) Byproduct Disposal ATTACHMENT 2 lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM Date: •Z./lJl?____ Name of employee receiving the load: T~S. t Generator of the Byproduct Material: f - yC./^b^al S Shipper’s Manifest or Bill of Lading number: AlfL-r>r>g-^.PP Was the State of Utah given notice to the receiptedisposal activities associated with this load?fYe| or No Who gave and when was the notification given? tL^r-ic. n Description of byproduct material disposal area/activities: _—o^jL—l>v^—Sc*- pL&.'H'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?__ a/a //a Which tailings cell was the material placed in? t i ~1 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? /M, <1+ e-r^gj__ji LfriOd-gC ia- ^_________4-r-fcoA-c^U-___4-L-^i r riowu*. 4t> LU_ 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? 5kl_________________________________________________________________________________ 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 #: yu[Z.-opg -Ctf 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 1SL waste disposal? _____________________ Documentation of approval ft mf tWfrq 4- Was the ISL material segregated from disposed Mill material and other ISL material? Vk Refer to plat(s) used to confirm. Cell l )U- Z A-nu 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 />// 7 /»,.</. 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, fr/i J €- Will the elevation of the material exceed the plane or grade of the elevation of the uppermost flexible membrane liner of the cell? confirmedHow was this (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-*.__C-s,a. l/ytLtKzj- ^ l________UaJl!__H Were void spaces filled with tailings? ——_________________________________________________ Was the shipment properly covered? Yc-S, Sjl'u_________v c. ■ No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC. Rev. No.: R-3.3 STANDARD OPERATING PROCEDURES Page 13 of 13 Date: November 13, 2014 Title: 1 le.(2) B>product Disposal Manifest or BOL #: yo»i2.-Qc»?-cff Are additional settlement monitors required to be placed for this generator? _____MA________________________________________________________ If required, where were settlement markers were placed? /t/A____________________________________ Radiological receipt survey measurements:Prb-O , I. 1 iv'g-/ Ur- 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'/ Yes ok No or? Uranerz ENEfiCr CORPORATION Shipment No.: NR-OOB-CPP STRAIGHT BILL OF LADING ORIGINAL-NOT NEGOTIABLE GREENFIELD LOGISTICS________ Date: February 14. 2017 (Name of Carrier) 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: Blending City: Linch State: UT ZIP: 84511 State: WY ZIP: 82640 Route: Nichols Ranch to White Mesa Mill, Blending, UT. Vehicle: o Number f 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-FtSSILE, CLASS 7 J* RADIONUCLIDE: RESIDUAL NATURAL URANIUM & ASSOCIATED DAUGHTER PRODUCTS j" --- PHYSICAL FORM: SOLID CHEMICAL FORM: NATURAL URANIUM OXIDE UO^H]!) TOTAL ACTIVITY: 3.74x10,0Bq 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 LABEUNG REQUIREMENTS DO NOT LOAD OTHER FREIGHT IN THIS VEHICLE, TRANSFER EN ROUTE This is to ccrtifythaUhr nhovc-nmned materials are properly classified, described, packaged, marked and labeled, and are in proper condition for transportation according to the applicablerpgatSfions or the Deparbnelthqf Transportation. Name^^^ ----^ Date ^ ' / Y" / ~P- SHIPPER: Uranerz Energy Corp., an Energy Fuels Company CARRIER: PER WfiLVUA j PER ^___PATE V J^JrthatT date Enet'cy F>.<e J ; Ps so urce = •. L’-'- '• C _ i c. t-Jh i t l- M e = a >! i 1 1 T f- a n ^ ac v i n n G4c:-i S. l-l i y:-, ..?y • 9 1 D I and i n c Lr! S/: 5 I j V elT l c ] e IL,': Tra i 1 ei" 11} : Pccount ID; Or’Ller’ ! D : Hwnr?!' ID: Materia! ID: Descm. ID: Date T j n a 1 n : Pi ' i :•;• Mur 17 i5:l! 0u t ; !?r- 15/3 5 : A i I '. £? ) i W /G N i Ci-!D1..S Rh('-JC!H G i' o a s : T a i' a : Net : afMGG lb ‘toI-Avi )b p id 1 i i e ; c: Mai j 1 < g ,' £ M a t e c i a I R t; c e i □ t BLmNDING C o in m e n t s Opei at or : 3 i g n a t u r e TRL# 0i!l£G A Cl'iav ge by Hc-ignt Pi' / ] b / o'M 1 ? 1 5 ; £ 1 a B ib r Pi/1G/G0! 7 1.5: ac ‘j'fjlAw. I l;i I j (a } u' u1 VO .ibcM ’ b ! j ( e ) £ Ma r,Mat Chg: 0 ' <• C !'■ y : Me. lea 1 e j i (!'i) Uranez yUlZ -OOft - cPP Controled Elevation used (Cell 3) Area Elevation 5612.27 Transit Shot Initial shot for trench 6.12 Top of trench 5608.57 9.82 Bottom of trench 5603.87 14.52 tial shot used for material 6.16 Too of material in trench 5605.23 13.2 Top of cell 3 Liner 5608.5 Feet below liner 3.27 No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC. Rev. No.: R-3.3 STANDARD OPERATING PROCEDURES Page 11 of 13 Date: November 13, 2014 Title: lle.(2) Byproduct Disposal ATTACHMENT 2 lle.m BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM Date:JZ^7 Ii7 Name of employee receiving the load:JLL Generator of the Byproduct Material: L>re^e.n. ~ AStaUeh Shipper’s Manifest or Bill of Lading number: _______ Was the State of Utah given notice to the receipt/disposal activities associated with this loadyves^ir No ------^ Who gave and when was the notification given? Ti.-t,__7-lialn Description of byproduct material disposal area/activities: __CmW Qifejr. S Has each drum 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? //A Which tailings cell was the material placed in? ^.cl I 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? /Asyfrcrct >»- A---Vrf^r L- fU^f Was the material segregated from any Mill material or equipment disposed of in the cell? __________________________________________________*____________________________ Was the material segregated from bjproduct material from other ISL sources disposed of in the cell? _ Yal_____________________________________________________________________ _ 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 #: yt/R-Opg - iQ 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 IS L waste disposal? 4 Documentation of approval ft uT/ISOi?* Was the ISL material segregated from disposed Mill material and other ISL material? Refer to plat(s) used to confirm. C* // 3 /A- 2 jJ, /^rto ‘ 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? jw Refer to drawings used to confirm ^// 3 Is the bottom of each disposal area at least 12 feet from tKe sides or dikes of the tailings cell? Yes Refer to drawings used to confirm, fell 3 fe-vJ Will the elevation of the material exceed the plane or grade of the elevation of the uppermost flexible membrane liner of the cell? AM How was this confirmed (e.g., survey or review) ______________________________ ... ............ . jg How was the area compacted? Was each lift compacted by heavy equipment (such as a Cat D-6) at least 4 times prior to placement of subsequent lifts? At'c^ r f-U.<2*, /b-.h i *•*«■■* !• H— —L* ^^ Were void spaces filled with tailings? . ixs_______________________ Was the shipment properly covered? ____—S~c..c_______k-'bo. '' c-._______ No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC. Rev. No.: R-3.3 STANDARD OPERATING PROCEDURES Page 13 of 13 Date: November 13, 2014 Title: l le.(2) B>product Disposal Manifest or BOL #: ki Cl - oo^ - £ Are additional settlement monitors required to be placed for this generator? aZA If required, where were settlement markers were placed? AlA Radiological receipt survey measurements: ______« s / Lit./- ■■___ Breathing Zone: 1. Was a Breathing Zone Sample collected? Yes 2. If yes, what were the results of the sampling? Was a photograph taken during the unloading activities? (‘Yes^r No 2 Uranerz ENERCV CORPORATION STRAIGHT BILL OF LADING ORIGINAL-NOT NEGOTIABLE GREENFIELD LOGISTICS (Name of Carrier) Shipment No.: NR-009-WF Date: February 16.2017 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 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) 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 UO^HtO TOTAL ACTIVITY: 3.74x1010Bq 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 LABEUNG REQUIREMENTS DO NOT LOAD OTHER FREIGHT IN THIS VEHICLE, TRANSFER EN ROUTE This is to certifyahsfiKe^above-nam^malernMre properly classified, described, packaged, marked and labeled, and are in proper condition for transportation according to the applicable tegmatipns of the Department of Tianspollqtion.N,nH.-^<^C-a=g‘—'-----Dale: <5 V*'/?- SHIPPER: Uraneiz Energy Corp., an Energy Fuels Company CARRIER: per yiur? ______- DATE \J ___________________________________ P-ctticWL- (Hv— zjrtyy c tnc-i'Qy ? 5 g i" c. a c (.’Jbi- Wri 1 :■ e Ke !'! j I i f,'+ i ~i S. !-! i g • ■> w x V 1 "■# *. P ( nci i r> p L- i fc ■/| L t j . sac L or' i'll.. . •f: r; a' l r.y ■ i c v Jr r'i L C- j 17 I 0:V , " a i 3 I I D :C i ’ g = f :‘'-£B00 lb f-i c r o c n t 1 D :: i ovc /.iTOtiOLS -?.r.i :] b Or-do,' i D ;{\» r- '1 b uw;', 0r- It/: O a r p r-1 a l I 0 :.1 i ■ rO 0 i’ia c i t f c 1 £• i’lat sc j a i f'locrr ■ pt Da i; i n .I 0 :Bl I 'li'ii; I .'(0 f.' o in m i? r,s : CON T w 3 Nt.>? G'-1.LJ l 0pe*’at or■: C!"iarat uy !/)a i C|lni i l rj ri a c i.i i ’ “ : ■ r tj live- J- WVO i i •: a) .;■ ;>ia i. 0C/ i v / p.0 1 ! if},-: > i 7 / c? i 7 1 f'i a l; ;7.'n g : 7 4 £300 ib (I- 4 4 4 0 3 0 i b :: 7,30 i S; 0 T ij t ch D ; UZ-'OO0!- Uranez JJg- 00^1 - U->^r Controled Elevation used (Cell 3)5612.27 Area Elevation Transit Shot Initial shot for trench 6.12 Top of trench 5608.57 9.82 Bottom of trench 5603.87 14.52 Initial shot used for material 6.16 Too of material in trench 5605.23 13.2 Top of cell 3 Liner 5608.5 Feet below liner 3.27 No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC. Rev. No.: R-3.3 Date: November 13, 2014 STANDARD OPERATING PROCEDURES Title: 11 e.(2) Byproduct Disposal Page 11 of 13 ATTACHMENT 2 lle.Cl) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM Date: zlslil____ Name of employee receiving the load: Generator of the Byproduct Material: /A. e, S te^sy Shipper’s Manifest or Bill of Lading number:1 _________________ Was the State of Utah given notice to the receipt'disposal activities associated with this load? or No Who gave and when was the notification given? ___Tu^l. ,____________ll3J±l±2 Description of byproduct material disposal area/activities: ___fo»r-4- •_Ixj_ftnaio________________________ Has each drum been inspected to identify the presence of any void spaces? AsA_______ Have all drums with void spaces been filled with tailings sands or soil?______/1/A_______ Which tailings cell was the material placed in?______/ d. 11 3 Was the material placed on a tailings beach area of the cell or on an area of the cell that was underlain by tailings sands? __■ tfvl---------------UZ£e-i__p _|\. . a._-ki 4-L«_ Was the material segregated from any Mill material or equipment disposed of in the cell? _________leA Was the material segregated from byproduct material from other ISL sources disposed of in the cell? Vd 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? fr5 Documentation of approval uf 7 Was the ISL material segregated from disposed Mill material and other ISL material? ^4 Refer to plat(s) used to confirm. ^? /Uz 0,% 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?2? Has 4 foot of tailings sands been maintained under each disposal area? Y'f Refer to drawings used to confirm 3 & Is the bottom of each disposal area at least 12 feet from the sides or dikes of the tailings cell? <r Refer to drawings used to confirm. r'V// 3 fira^.iyc & 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) & 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. c.anfMrt'-ik LoilrU a,. \c>uA^r f—H------j—p..^r:_lt£,L— Were void spaces filled with tailings? 7e-j>______________________ Was the shipment properly covered? _ * i t-__________________________ No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC. Rev. No.: R-3.3 STANDARD OPERATING PROCEDURES Page 13 of 13 Date: November 13, 2014 Title: 1 le.(2) Bjproduct Disposal Manifest or BOL #: I Are additional settlement monitors required to be placed for this generator? ________________MA____________________________________________ If required, where were settlement markers were placed? ___________AM__________________ Radiological receipt survey measurements: feUQ- 0 ________> T- *~v (lI Breathing Zone: 1. 2. Was a Breathing Zone Sample collected? Yes If yes, what w'ere the results of the sampling? Was a photograph taken during the unloading activities? pea or No BILL OF LADING SHIPMENT ID# 165 SHIPMENT DATE: February 2.2017 SHIPPER (From): EFR ALTA MESA LLC CONSIGNEE (To): Energy Fuels Resources (USA) Inc. 6425 South Highway 191 Blanding,UT 84511 ADDRESS: 755 Co. Rd. 315 Encino, TX 78353 ADDRESS: P. 0. Box 809, Blanding UT 84511 SHIPPER LICENSE NO.: RO5360 SHIPPER USDOT NO.:CONSIGNEE LICENSE NO.: UT-1900479 CONSIGNEE TELEPHONE NO.: (435)678-2221 SHIPPER LICENSE NO.:SHIPPER TELEPHONE NO.:361-568-3549 CARRIER NAME AND ADDRESS: Greenfield Logistics, LLC CARRIER USDOT CARRIER HAZMAT REG. NO.: Trailer# Container# GFLU002068 Seal# Seal# DESCRIPTION OF MATERIAL AND PACKAGING VOLUME Cubic feet or QUANTITY CLASSIFICATION 1 pkg. RQ Objects (SCO-1) and soil, non-Ossile,, Class 7 Dry 11 (E)2 By-Product material. 35,000 lbs. (gross) Surface contaminated objects (SCO-1) and soil Exclusive use shipment Placards applied EMERGENCY CONTACT: P. Luthiger: 1-361-816-0150 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. B>oL. 'I '1 T\ _ V ' o ‘1 i:: '. «? : l T ; i ; 0 Co . • ^ 1 ,■■ Ore: o ■ i T . Tie ricit ^ , j i II .' i ( vX / 0 "’is t i J a.. 1 no f i' ■. ;-i ; ' i ‘i :, & O Z J 00 0 o :n in f? rO: s : 0 p & r a i or: S i g n a i‘ 'j i' c CONlTilNOO OF00 000006 ii COrirge by Ocigl-i!: >itr.b T L i'OO 1 1 i x ' 0 M £ c i^O/Oc Or /'.Hr '■J ■£|'J ? ~ : O >J 08 . On ■/0:"80 it: • l<l) i- - ;. '* lb FFot-,0 It:, i; L r'ng:Oi Generator of Byproduct material: Mestena Controled Elevation used (Cell 3) 5613.04 4 US Area Elevation Transit Shot Initial shot for trench 4 Top of trench 5610.68 6.36 Bottom of trench 5604.2 12.84 Initial shot used for material 4 Too of material in trench 5608.02 9.02 Top of cell 3 Liner 5608.5 Feet below liner 0.48 Photo 1: Two loads of miscellaneous decommissioning debris from Uranez- Nichols Ranch, Wyoming. Photo taken February 27, 2017. Photo 3: Excavation prepared to receive debris from Uranez - Nichols Ranch, Wyoming. Photo taken February 27, 2017. Photo 2: Two loads of miscellaneous decommissioning debris from Uranez - Nichols Ranch, Wyoming. Photo taken February 27,2017. Photo 4: Surveying elevation of bottom of excavation prepared to receive debris from Uranez Nichols Ranch, Wyoming. Photo taken February 27, 2017. Photo 5: Placing decommissioning debris from Uranez - Nichols Ranch. Wyoming into the excavation. Photo taken February 27, 2017. Photo 7: Attempting placement of cover soil on decommissioning debris from Uranez - Nichols Ranch, Wyoming into the excavation. Floating debris shed the soil, so placement was abandoned. Photo taken February 27,2017. Photo 6: Placing decommissioning debris from Uranez Nichols Ranch, Wyoming into the excavation. Note how the bags of debris float on the solution in the pit. Photo taken February 27,2017.__________________ Photo 8: One load of soil from Mestena Encino, Texas. Photo taken February 27,2017. Photo 9: Excavation prepared to receive soil from Mestena Encino, Texas. Pipe is debris from previous burial operation exposed during excavation. Photo 7: Placing cover soil over waste soil from Mestena - Encino, Texas. Photo taken February 27,2017. Photo 6: Placing waste soil from Mestena Encino, Texas. Photo taken February 27, 2017. Photo 8: Densifying cover soil over waste soil from Mestena Encino, Texas. Photo taken February 27, 2017. wo ; mm i, tv-£ •* -.C : ■ :r«i-3 5 • 4 *^-^ ^ -t>c- ... - •* * •/. ♦* • ,« ^ . . ^: • . - ‘ " 'V o-v - - / ^ • -3&' *■ -x- ^ ' ; ^ -^oi- •••' .' :• . ' ■- 3? tr.’Tzgl a ' •. :v ■■ -....^ F t j. .W'-Jtm:. ••>••'• .. '/• ' .•--'•I': - ,V; ” m-.'i ,*>. - . .^r'.-..:.# r;2*-^ -- ••-•' '■• • y2r-y ■,, • •-* •. SfElSHiyr* *•' - • A' aBc^afeiiSkS^;^, r.fC., IS? •S-rW-.C ■ *, ., '^SS ». ,,,, * »;-«.• • « .- .-• ,--- i ' - - - - ------- ?»a*e