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HomeMy WebLinkAboutDRC-2017-005324 - 0901a06880730addState of Utah GARY R HERBERT Governor SPENCERJ COX Lieutenant Governor Department of Environmental Quality Alan Matheson Executive Director DIVISION OF WASTE MANAGEMEN !' AND RADIA TION CONTROL Scott T Anderson Director im~2on-ooEd24' MEMORANDUM TO:Project File C-2017-17 THROUGH:Heather Mickelson, PE V\ Phil Goble, Uranium Mill Section Manager £ 7/Cr7?«/7 FROM:Russell J. Topham, PE Kp DATE:rJuly 18,2017 SUBJECT:2017 Engineering Module 73, Inspection of disposal of 1 from in situ leach facilities le.(2) decommissioning debris Authority Radioactive Materials License #UT1900479, Condition 10.5: “In accordance with the Licensee's submittal to the NRC 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 cited below as Requirements.) R3J3-12-3 (quoting JO 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 11 e.(2) of the Atomic Energy Act as amended in 1954 to include in situ leach 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 I, No. 10. DRC-20 195 North 1950 West • Salt Lake Citv, UT Mailing Address P O Box 144880 • Salt Lake City. UT 84114-4880 Telephone (801) 536-0200 • Fax (801) 536-0222 -TDD (801) 536-1284 ummi.deq iitnti.gov Printed on 100% recycled paper Second Quarter, 2017 ISL Decommissioning Debris Disposal Inspection Report July 18,2017 Page 2 is demonstrated to be impracticable or the advantages of onsite burial clearly outweigh the benefits of reducing the perpetual surveillance obligations.” Requirements 1. Radioactive Materials License #UT1900479, Condition 10.5A: “Disposal of ISL waste is limited to 5,000 cubic yards from a single source.” The Division considers a source to be a discrete facility defined by its geographic boundaries.2 2. 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.” 3. Radioactive Materials License MJT1900479, Condition 10.5C: “All ISL waste shall be buried in Cell No. 3 unless prior written approval is obtained from the Executive Secretary [now the Director] for alternate burial locations.” 4. 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.” 5. Radioactive Materials License #UT1900479, Condition 10.5E: “The Licensee shall also submit for Executive Secretary 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) 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: 2 A “source” in this context is a geographically discrete facility. See Letter from Rusty Lundberg to Jo Ann Tischler dated November 7, 2013 (DRC-2013-005682) 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. 6. Radioactive Materials License #UT1900479, Condition 10.5F: The Licensee shall notify the Executive Secretary 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 on or before November 1 of each calendar year. Observations Russell J. Topham, PE of the Utah Division of Waste Management and Radiation Control (the Division), in the company of Phil Goble, Uranium Mill Section Manager observed disposal of three loads of 1 le.(2) byproduct material on June 28, 2017 at the White Mesa Uranium Mill (the mill) owned and operated by Energy Fuels Resources (the Licensee) in response to notification sent by the Licensee dated June 4 and June 12, 2017. One load came from the Mestena/Alta Mesa Project near Encino, Texas; two loads came from Cameco/Smith Ranch near Douglas, Wyoming. The Cameco loads were the first received since the Nuclear Regulatory Commission (NRC) lifted a moratorium on shipments from that facility following investigation of two leaking shipments from that facility to the White Mesa Mill August 21, 2015 and March 29, 2016. This inspection focused on the Licensee’s implementation of Standard Operating Procedure SOP PBL- 10, which governs disposal of 1 le.(2) byproduct material from in situ leach facilities. Incoming shipments for all materials are subject to another procedure, SOP PBL-19. While not a part of this inspection, the inspection team took the opportunity of this inspection to ask about changes made to the protocols for receiving incoming shipments in response to the Cameco/Smith Ranch leaking containers. The Licensee added to SOP PBL-19 new information gathering requirements to employ when receiving a leaking load. The loads observed during this inspection were dry, so the additional work specified in SOP PBL-19 was not required. For future reference, a blank copy of the SOP PBL-19 information capture form appears as an attachment to this report. 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. A copy of this paperwork is attached to this report. Revision R-3.3 is the most recent version of the procedure. The Licensee maintains a map of Tailings Cell 3 in the mill office that shows the dedicated disposal location for each 1 le.(2) debris generator. Examination of that map reveals that if disposal operations are limited to the lateral extents of the dedicated disposal plots and if the vertical location of placement of material is limited to within two feet above and below the upper surface of the tailings, neither the excavation nor the debris will endanger the integrity of the cell liner. Second Quarter, 2017 ISL Decommissioning Debris Disposal Inspection Report July 18,2017 Page 3 Lateral disposal pit locations are determined and located in the field by survey prior to excavation. The bottom of the excavations is extended into the tailings sand, and the depth is surveyed prior to placement of material into the excavation. Once the debris is placed in the excavation and compressed, the top of waste is surveyed, after which cover soil is placed and compacted. Lateral locations were checked by the inspector onsite. Disposal data packets attached to this report show that the vertical placement is below the peripheral top of liner and well above the liner beneath the excavation. The Licensee provided in SOP PBL-10 that material must be accepted for disposal prior to departure of the transport vehicle from the generator. This allows the Licensee to ascertain that the material characteristics meet the requirements for classification as 1 le.(2), material, and to verify that the quantity to be shipped will not exceed the 5,000 cubic yard per source limit. Checks of running receipt totals confirmed that the volume limits had not been exceeded. The material is checked upon receipt to verify that what was shipped is what was expected. Second Quarter, 2017 ISL Decommissioning Debris Disposal Inspection Report July 18,2017 Page 4 Once the material is accepted for shipment, the receipt and burial are scheduled and the Licensee sends a seven-day advance notice to the Division of the date scheduled for the burial event and number of loads anticipated for disposal. The Division received the written notice on June 6 and 13, 2017. Disposal Activities Observed Photos 1 and 2 show the materials disposed during the inspection. The Cameco/Smith Ranch material was miscellaneous debris, including wire, pipe, fittings, pumps, filters, etc. No sign of moisture was noted either during pre-inspection walk- around or during disposal. The debris from Cameco/Smith Ranch contained no material requiring dismantling, sectioning or crushing. None of the loads included barrels, so License Condition 10.5B does not apply to the operations observed. Soil should be able to fill voids in the debris mass. Once placed, the material is densified to minimize the potential for excess differential settlement of the tailings, cover system and buried debris. The Mestena/Alta Mesa material was loose soil. No sign of significant moisture was noted either during pre-inspection walk- around or during disposal. Second Quarter, 2017 ISL Decommissioning Debris Disposal Inspection Report July 18,2017 Page 5 Once placed, the material is densified to minimize the potential for excess differential settlement of the tailings, cover system and buried debris. Photo 3 shows the excavation prepared to receive the Mestena/Alta Mesa material. The excavation extends through the lighter-colored platform fill and to the surface of the tailings. This photo also depicts a crew member assisting in the survey operation used to determine the elevation of the bottom of the pit. Results of the survey operation are included in the attachments to this report. Lateral location of the pit was checked in the Mill office.Photo 3: Surveying depth of excavation prepared for receipt of Cameco/Smith Ranch Debris. Photo taken June 29, 2017. Surveying of the depth of the Cameco/Smith Ranch pit was observed, but not photographed. Results of the survey operation are included in the attachments to this report. The lateral location of the pit was checked to verify the distance between the edge of the pit and the Cell 3 liner. Photo 4 shows placement of material from the Cameco/Smith Ranch facility in the excavation dedicated to receive material from that source. No excess moisture was observed in the debris during placement. Lateral location of the Mestena/Alta Mesa pit was checked to verify the distance between the edge of the pit and the Cell 3 liner. Photo 5 shows placement of material from the Mestena/Alta Mesa facility in the excavation dedicated to receive material from that source. No excess moisture was observed in the debris during placement. Photo 4: Placing Cameco/Smith Ranch debris in excavation prepared for that purpose. Photo taken June 29, 2017. Photo 5: Placing Mestena/Alta Mesa material in excavation prepared for that purpose. Photo taken June 29, 2017. Second Quarter, 2017 ISL Decommissioning Debris Disposal Inspection Report July 18, 2017 Page 6 Photo 6 shows the survey operation to determine the top of the Cameco/Smith Ranch debris. As with the survey of the bottom of the pits, the survey of the top of both pits was observed. Only one photo is included in this report. The survey data is included as an attachment to this report. The survey data shows, and a check against the drawing at the mill office confirmed, that the top of waste in both pits was below the plane of the top of the flexible membrane liner, as required. •* •. * ... ' ' •. V’, ' ' • ■ Photo 6: Cameco/Smith Ranch pit being surveyed at top of waste. A partial soil cap was placed prior to survey to facilitate walking on the waste. Photo taken June 29, 2017. Photo 7 shows use of a piece of heavy equipment to densify the debris. The soil that was placed to facilitate walking on the debris is forced into the void spaces between elements of the debris. The operator uses the weight of the loader, through the bucket and the wheels, to compress the debris mass. This operation was observed for both the Cameco/Smith Ranch and the Mestena/Alta Mesa materials, but only the Cameco/Smith Ranch photo is included here. Photo 8 shows placement of cover soil over the densified debris. This cover soil serves both to retain the debris in the pit away from environmental forces, and as part of the platform fill/secondary Radon barrier. The capping soil was placed in lifts of about 12” thickness and wheel-walked to densify. Wheel-walking occurred until the surface was firm and unyielding. This operation was observed for both excavations, but only the Cameco/Smith Ranch photo is included here. Annual File Review’ Second Quarter, 2017 ISL Decommissioning Debris Disposal Inspection Report July 18,2017 Page 7 In addition to the inspection of burial of the three loads of debris already described, the paper files for all 1 le.(2) material received since January 1, 2016 were reviewed. Table 1 provides a summary of the file review data. In all cases, the data packets included all required data. The paperwork included, among other things, the shipper’s manifest, generator’s description of the material, weigh ticket and radiological survey on shipping from the generator and on receipt at the mill, the mill receiving agent’s description of the material, and the mill’s 7-day notice to the Division of the scheduled burial date. Generator Number of Loads 2016 2017 to Date3 Total Mestena/Alta Mesa 8 4 12 Uranez/Nichols Ranch 4 2 6 Uranium One Irigaray/Christensen 0 1 1 URI/Rosita 0 1 1 URI/Kingsville Dome 2 0 2 UEC/South Texas 1 0 1 UEC/La Palangana 1 0 1 Cameco/Smith Ranch 12 0 12 Cameco/Crow Butte 5 0 5 Cameco/North Butte 1 0 1 Cameco/Highland Ranch 2 0 2 Total 36 8 44 Table 1: Summary of 1 le.(2) Byproduct Disposed in 2016 and First Half of 2017. Cameco/Smith Ranch has sent its June loads in containers with an absorbent material on their floors to prevent any fluid in the debris from escaping the container. The inspection team did not get an opportunity to observe the receipt of any loads of decommissioning debris during the inspection on June 29, 2017. Photo 9 was taken by the Licensee after the inspection team left the site, when another load arrived. The Licensee asserts that the load captured in Photo 9 is representative of the two loads buried during the inspection. The Licensee is required by License Condition 10.5F to submit an annual summary of 1 le.(2) byproduct disposal by November 1 of each year. The 2016 summary is due November 1, 2017, and was received on January 26, 2017. Table 2 provides the data from that report through the end of 2016. Since review of this data was not part of the quarterly inspection detailed in this report, actual year-to- date data has not been incorporated. Running totals observed in records at the mill office indicate that the Licensee is compliant with the License Condition 10.5F limit of 5,000 cubic yards from any one Photo 9: Container of ISL byproduct material received June 29, 2017. Photo taken by Energy Fuels Resources on June 29, 2017. 3 Excludes loads buried on the date of the inspection, for which paperwork was not yet completed. The paperwork for those three loads is attached to this report. Second Quarter, 2017ISL Decommissioning Debris Disposal Inspection Report July 18, 2017 Page 8 source. Table 2 uses information provided by the Licensee following the inspection to arrive at the volumes received in 2017 and the resulting volume received from each source since inception. As Table 2 shows, four sources have sent over 80% of the quantity allowed by License Condition 10.5 A per source. Of these four, two facilities are closed and are no longer shipping material. Generator Number of Cubic Yards Jan 1,2016 Through Dec 31,2016 Inception Through Dec 31,2016 Jan 1,2017 Through Jun 30,2017 (Estimated) Inception Through Jun 30,2017 (Estimated) IEC (Closed)0.00 4920.00 0.00 4920.00 USX (Closed)0.00 4636.35 0.00 4636.35 Mestena/Alta Mesa 190.00 3317.65 125.00 3442.65 Uranez/Nichols Ranch 60.00 120.00 40.00 160.00 Uranium One Irigaray/Christensen 0.00 0.00 28.30 28.30 URI/Rosita 0.00 693.79 25.00 718.79 URI/Kingsville Dome 30.00 4869.26 0.00 4869.26 URI/Vasquez 0.00 105.70 0.00 105.70 UEC/South Texas 6.40 4027.90 0.00 4027.90 UEC/La Palangana 10.60 351.60 0.00 351.60 UEC/Goliad 0.00 0.00 0.00 0.00 Cameco/Smith Ranch 245.70 3419.18 24.70 3443.88 Cameco/Crow Butte 125.00 1555.00 0.00 1555.00 Cameco/North Butte 24.70 24.70 0.00 24.70 Cameco/Highland Ranch 49.40 3044.86 0.00 3044.86 Cameco/CPP 61.10 61.10 49.40 110.50 The mill produces its own 1 le.(2) byproduct material. License Condition 10.5E(3) requires that mill material and ISL byproduct material be segregated. The map reviewed at the mill office clearly shows plots assigned for burial of ISL byproduct material on roughly the east half of Cell 3 and roughly the west half of Cell 3 reserved for waste generated by the mill. The inspection team observed that mill waste is staged for burial around the west edge of the remaining solution pool in Cell 3, well away from the areas reserved for ISL byproduct material. The inspectors also observed that the Licensee has placed interim fill/secondary Radon barrier on approximately the western one-third of Cell 3. Analysis This section follows the same sequence and numbering convention used in the Requirements section above. 1 1. License Condition 10.5 A limits the Licensee to 5,000 cubic yards of byproduct material per source. The Licensee has an approval mechanism in place that provides it an opportunity to accept or reject a proposed shipment based upon whether it meets qualifications as 1 le.(2) material and whether accepting the material would cause the Licensee to exceed the allowable quantity. As a further check, License Condition 10.5F, discussed below, requires the Licensee to report annually to the Division the quantity of byproduct material received from each facility. Second Quarter, 2017 ISL Decommissioning Debris Disposal Inspection Report July 18,2017 Page 9 The information observed and gathered during this inspection supports a conclusion that the Licensee is adhering to this license condition, and that the mechanisms in place are sufficiently robust to assist the Licensee to comply. 2. License condition 10.5B governs disposal of drummed material or material of sufficient size to be broken down into smaller segments to minimize introduction of void spaces in the cell cover. The Licensee has in place Standard Operating Procedure SOP PBL-10 which is sufficiently robust to insure compliance with License Condition 10.5B. The operations required by License Condition 10.5B were not applicable to the materials being disposed during the inspection. 3. License Condition 10.5C specifies Tailings Cell 3 as the required location for disposal of byproduct material. The mapping, documentation and physical activities observed support a conclusion that the Licensee is in compliance with this condition. 4. License Condition 10.5D requires the Licensee to document the nature of each load of byproduct material received, where it is buried, and how it was handled, including all measures taken to comply with all of License Condition 10.5, and to maintain those records onsite. The file review completed at the time of the inspection demonstrated compliance with License Condition 10.5D. Specifically, the maps and record packets contain sufficient information, and demonstrate conclusively that the Licensee is tracking the nature of the material received, applying appropriate standards in the handling and disposal of the material, making sufficiently detailed records and maps, and maintaining those records and maps onsite. 5. License Condition 10.5E required the Licensee to submit a Standard Operating Procedure by December 1, 2010 to govern the disposal operations for 1 le.(2) material received from in situ leach uranium recovery facilities. 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. Revision R-3.3 also details necessary processes not specifically identified in the License Conditions. The original version and every subsequent revision of this procedure was submitted to the Division for review and approval prior to implementation. 6. License Condition 10.5F contains two requirements. The Licensee must notify the Division at least seven days in advance of burying any byproduct material not generated onsite, and must send an annual summary of all such material buried during the year to the Division by November 1 of the following year. The Division received notice at least seven days in advance of burial of all 44 loads identified during the file review portion of the inspection, and for the three loads disposed during the inspection. The three loads observed during the inspection were included in 1 le.(2) Byproduct Receipt Notifications the Licensee sent the Division, dated June 4 and June 12, 2017, and received June 6 and June 13, 2017. The annual report for 2016 disposal activities arrived in the Division offices prior to the due date. The evidence gathered during this inspection supports a conclusion that the Licensee is compliant with License Condition 10.5F. 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 In situ Leach uranium recovery facilities. No new recommendations were identified during this inspection. Attachments: 1 le.(2) Byproduct Receipt Notifications dated June 4 and June 12, 2017 Document packet for Mestena byproduct material bearing Shipper Number 169 Document packet for Cameco byproduct material bearing Shipper Numbers 2016-CPP-0002 Document packet for Cameco byproduct material bearing Shipper Numbers 20I7-CPP-0003 Licensee’s Feed Material Receipt Inspection Form from SOP PBL-19 (used for leaking loads) Second Quarter, 2017 ISL Decommissioning Debris Disposal Inspection Report July 18,2017 Page 10 I 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 June 4, 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, Div of Waste Management and Radiation Control JUN - 6 20t7 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 loads by June 30, 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, l David Turk Environmental Health & Safety Manager Energy Fuels Resources (USA) Inc. cc: Denver Central Files / N ENERGYFUELS 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 June 12, 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, Div ct Wasle Manggsment and Radiation Control JUN 1 3 20!7 PftC-^017-00^-250 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 by June 30, 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. i Rev. No.: R-3.3 STANDARD OPERATING PROCEDURES Page 11 of 13 Date: November 13,I 2014 Title: lle.(2) Byproduct Disposal ATTACHMENT 2 lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM Date:__g-ZZ-ll__ Name of employee receiving the load: T^-r fc- Generator of the Byproduct Material: _____ Shipper’s Manifest or Bill of Lading number: _______________ Was the State of Utah given notice to the receipt/disposal activities associated with this load? Yes or No Who gave and when was the notification given? ___feawiek LcI±L7________________________________________ Description of byproduct material disposal area/activities: ___St. i- plwiro_____________p f /■-, ____ Has each drum been inspected to identify the presence of any void spaces? aJA Have all drums with void spaces been filled vyith tailings sands or soil? /b//4- Which tailings cell was the material placed in?__i l JT 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___________________________fo.... A __________________cXoi^y ^ -Vn___________ .S .________________________________________________________________________________ Was the material segregated from any Mill material or equipment disposed of in the cell? Ya:' 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: 1 le.(2) Byproduct Disposal Manifest or BOL #:___°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? Vr-i Documentation of approval L>>irui aT/‘ISOVV1-? A 7 g? Was the ISL material segregated from disposed Mill material and other ISL material? fej Refer to plat(s) used to confirm. £'„// i j/e. z M-rta & Was the maximum lift thickness above tailings less than 4 feet thick?S? 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 r<// i Ca^i. 0r*~r'„as-& Is the bottom of each disposal area at least 12 feet from the sides or dikes of the tailings cell? & i Refer to drawings used to confirm. /+/ f3 & 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)& ~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 i—;c-J •- rH~. e~.1 i f~ H______________________ ______________________________________________________________ Were void spaces filled with tailings? Vts________________________ _________ Was the shipment properly covered? Vm ''C-t A-jg-Qi/K.._____ *!'Ko.: PBL-10 j ; Rev.No.:R-3.3 | Date: November 13. i i ENERGY FUELS RESOURCES (USA) INC STANDARD OPERATING PROCEDURES Title: lle.(2)BjproductDisposal | Page 13 of 13 2014 .L_. Manifest or BOL #:___1 (s °\ Are additional settlement monitors required to be placed for this generator? If required, where were settlement markers were placed? ___________________________________ Radiological receipt survey measurements: __S- o ^t-l _ ,/O _____ Breathing Zone: 1. Was a Breathing Zone Sample collected? Yes o 2. If yes, what were the results of the sampling? /l/A Was a photograph taken during the unloading activities? /Ves or No BILL OF LADING SHIPMENT ID# 169 SHIPMENT DATE: June 20. 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 PL CARRIER USDOT CARRIER HAZMAT REG. NO.: Trailer Container# GFLUDOfiB© ZOS Seal # Seal # DESCRIPTION OF MATERIAL AND PACKAGING VOLUME Cubic feet or QUANTITY CLASSIFICATION 1 pkg. RQ UN2912, Radioactive Material, Low Specific Activity (LSA-1) and soil, non-fissile,, Class 7 Dry 11 (E).2 By-Product materiaL EMERGENCY CONTACT: P. Luthiger: 1-361-816-0150 35,000 lbs. (gross) Low Specific Activity (LSA) waste material and soil Exclusive use shipment Placards applied 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 to the applicable regulations of the Department of Transportation. Shippers Signature: Driver’s Signature: Date: 'zADWT' Date: Energy Fuels Resources (USA) Corp. White Mesa Mill Transaction No. 6425 S. Highway 191 53149 Blanding UT 34511 ** Reprinted by 4 at 06/22/17 15:14:43 ** Vehicle ID: Trailer ID: Account ID: Order ID: Owner ID: Material ID: Destin. ID: t4 MESTENA AL MESTENA ALTA PROJECT 11(e)2 Mat 11(e)2 Material Receipt BLANDING Date Time Scale In: 06/22/2017 14:37 1 Out: 06/22/2017 15:14 1 Gross: 77860 lb (M) Tare: 44060 lb Net: 33800 lb Comments: Operator: Signature Charge! by Weight cR-M 61 Generator of Byproduct material: Mestena Controled Elevation used (Cell 3) 5613.04 Area Elevation Transit Shot Initial shot for trench 4.1 Top of trench 5610.19 6.95 Bottom of trench 5603.06 14.08 Initial shot used for material 4.1 Too of material in trench 5606.54 10.6 I Top of cell 3 Liner 5608.5 Feet below liner 1.96 ENERGY FUELS RESOURCES (USA) INC. STANDARD OPERATING PROCEDURES Title: 1 le.(2) Byproduct Disposal j Page II of 13 '• rNo.: ‘PBL-IO | Rev. No.: R-3.3 Date: November 13, 2014 ATTACHMENT 2 lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM Date: _£lz6iO- Name of employee receiving the load: £<xrr.^ Generator of the Byproduct Material: Shipper’s Manifest or Bill of Lading number: 2.0 16- __ Was the State of Utah given notice to the receipt/disposal activities associated with this loai No Who gave and when was the notification given? ___ J _ wlc. .t,_________----------------------------------------------------------------------------------- ir Description of byproduct material disposal areayactivities: . p. .U*_±g- £hJ=teL* Has each drum been inspected to identify the presence of any void spaces?___AJA _____ Have all drums with void spaces been filled with tailings sands or soil?_____A/A__________ Which tailings cell was the material placed in?____£-e-l t 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? _ __VOfvJ) I a____________________________________. T'-fi.S. 6-*^ As ,_______________________________________________________________ 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 Date: November 13, 2014 STANDARD OPERATING PROCEDURES Title: 1 le.(2) Byproduct Disposal Page 12 of 13 Zo '6 ■ Manifest or BOL #: c.(P - OQ& z- 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? '/es Documentation of approval //Vv^c. fjuT/909v7ct A~>~7 Was the ISL material segregated from disposed Mill material and other ISL material? /es Refer to plat(s) used to confinn. <f>// j j/e.z Art a 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 £V// 3 & Is the bottom of each disposal area at least 12 feet from the sides or dikes of the tailings cell? /es Refer to drawings used to confirm. Celt 3 if Will the elevation of the material exceed the plane or grade of the elevation of the uppermost flexible membrane liner of the cell? Mo How was this confirmed (e.g., survey or review) __________________________________________________________________ a 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 rc-^k__C f cA___________________________AvJi__ly, __fn ^6r- 1:^-4. Were void spaces filled with tailings? ____teX Was the shipment properly covered? .....Vc-.S , Scc^.cJr?eu (______ | No.: PBL-10 Rev. No.: R-3.3 ENERGY FUELS RESOURCES (USA) INC. STANDARD OPERATING PROCEDURES | Page 13 of 13 . J Date: November 13, i 2014 Title: 1 le.(2) B>product Disposal ! i ! Manifest or BOL #: Zcfc- cN~ooQ "z- Are additional settlement monitors required to be placed for this generator? AJA______________________ 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 o£No!> If yes, what were the results of the sampling? Was a photograph taken during the unloading activities^lor No Shipper No. 2016-CPP-0002 STRAIGHT BILL OF LADING ORIGrNAL—NOT NEGOTIABLE Carrier No. N/A GREENFIELD LOGISTICS (NAME OF CARRIER)(SCAC) Date Time 6/23/2017 16^0 Collected on Delivery shipments, the letters COD must appear before consignee's name or as otherwise provided m item 430, Sec. I. 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 Vehicle Number N/A No.of units & container type HM Basic Description Proper Shipping Name. HaardCiass.Idcntificaiion Number (DM « NA), Pxkinggioup, per 172 101 172 202 172203 Total Quantity (WaghL Volume, Gallon!, etc) Weight (Subject to Correction) Rate Charges (ForCamcr Use Only) Roll Off UN2912, RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY (LSA-1), CLASS 7 18.9 m* (24.7 yd") RADIONUCLIDE: NATURAL URANIUM, THORIUM-230 AND RADIUM- 226 PHYSICAL FORM: SOLID CHEMICAL FORM; UNAT WITH DAUGHTERS TOTAL ACTIVITY: 1.25E8 Bq (0.00337 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: PHIS 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 Notc<(1) When the rale it dependent on value, shippers an nquind to state specifically on writing the agreed nr declared v «lue of the property as follow v The igreed or declared value of the property is hereby specifically itaied bv the shipper to be not exceedingj«cr_______ (2) Where ihe applicable tariff provisions specify a limitation of the earner’s liability absent a ideese or a value deefaraimn by ihe shipper and the shipper dots not release the earner s liability or declare a value, the carrier’s liability shall be hnulcd to Uic evtcrn provrdedby such provisions. SceNMFLnem 172 (3) Commudines requiring special or additional .’arc or attention in handling or stowing mud be so mailed and packaged as to ensure safe iroupartaiion Sec Secuon 2(c) of item 360 Bills of Lading. Freight Bills, tod batemcnis of Charges and Section l(a)ol the Conn act terms and conditions for a list of such articles. 1 hochy declare ihnl (he conlents of this consignment are fully ard accurately described above by the proper shipping name and sc classified, packaged, marked, and labcted/^riacaf d. and are m all respects in proper coodmon for transport according to applicable international and national governmental regulation*. ON BEHALF OF SHIPPER Sulijoa to Saoioin of H e coniiilions n ifcis shipmeni is to be delivered to (he const pee without recourse on the consignor the consignor ahull sign the following statement. The carrier shall not make delivery of this shipment vnihout payment of freight and all other lawful charge* fSiKmuiBi: of Cornimiorl PREPAID u COLLECT TOTAL CHARr.FS FREIGHT CHARGES FREIGHT PREPAID except when Check bo\ ifchaiges box si nght □ are to be collected is checked RECEIVED. nb)C<.i ioiIk cUnifcaiwa tod unlliln efted on ■!* dale ut iaaic ofihii Bill ol Laduv ibe property dewnbed sbon: a apporcnl food order cvccpi at noted (ronienu «nd ccniiimn ol Mjn’tnw oi pnUgoi unLnoway. marked, uMwp'ud, and dcstusd u* aiduiad tbux '‘.tiicli uid earner (i be ■aord vtrrsei banj ink.ULud 'hini^KouMlat eenirw* rKviing any n (u>ict«uii id'lk'r |nup>nly u-akn ll>« von(>»1) Bgirx-s kM^orv turliUMl p'M uf dcltwiv nio-J UcrtinaUun, if on n» nwle olher»ik* to irijvet to tioiho earner on Ihe route lo Mid dulnulion ll » irvliully ■|;nu.1 a% lo r»Oi isuiw: ul'atlui ui) cl. nitj p<upcriy over all or ui> purtior of nwj route in deUmtian uid ai so each party M my time talereaiod in all or am u>d piopcrri ihai every icivmio be perlormed licieurdci xhaH be mbfcel n»N ihcbiS ol ladiap Kmutnd vOodiuaunilK gmcm-ngi.b^iru'iMraiikcdiiicofthc •Jnraiiovi Skipper bvietiv vxnifat thtl he n LamiSar'with ail ihe Udiiq u-mi and ixndilkau in lEc lovcnun* ehujliialon and Ihe mxJ icmn nl unlit oro are ketch)-agreed lob> lie vtuppci and aevepted for hnxlfaad hiaasv^n SHIPPER:CAMECO RESOURCES CARRIER:GREENFIELD LOGISTICS PER Y V PER y DATE DATE Rev 41une 09, 2016 Page 1 of 1 WYO-RPP-FORM-031 Bill of Lading.xlsx e hihy RSO: Operations: Smith Ranch Controled Elevation used (Cell 3) Area Elevation 5612.27 Transit Shot Initial shot for trench 6.38 Top of trench 5607.83 10.82 Bottom of trench 5602.55 16.1 Initial shot used for material 6.38 Too of material in trench 5606.69 11.96 Top of cell 3 Liner 5608.5 Feet below liner 1.81 Energy Fuels Resources (USA) Corp. White Mesa Mill 6425 S. Highway 191 Blanding UT 84511 ** Reprinted by 4 at 06/26/17 07:34:08 ** Vehicle ID: Trailer ID: Account ID: Order ID: Owner ID: Material ID: Destin. ID: 13 11(e)2 WYO SMITH RANCH 11(e)2 Mat 11(e)2 Material Receipt BLANDING Comments: container gflu001235 1 £ Transaction No. 53153 .3 In: Out: Date Time Scale 06/26/2017 07:08 1 06/26/2017 07:33 1 Gross: 63440 lb (M) Tare: 44600 lb Net: 18840 lb ■V 4^'- a.■jd•3•4 a J"3 ■ft ’Sfl ■ft 4.^ I*1 [No.: -PBL-lCf | Rev. No.: R-3.3 j Date: November 13, 2014 ENERGY FUELS RESOURCES (USA) INC STANDARD OPERATING PROCEDURES Title: 1 le.(2) Byproduct Disposal Page 11 of 13 i ATTACHMENT 2 lle-(2l BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM Date:__t.LzsllJ___ Name of employee receiving the load: _ T^rfW. SltscLc Generator of the Byproduct Material: I'V Shipper’s Manifest or Bill of Lading number: rZol~? - CPP- 0OO3> 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? ..IflirJC, Description of byproduct material disposal area/activities: ^ f 4- Has each drum been inspected to identify the presence of any void spaces?___Ay1 A ____ Have all drums with void spaces been filled with tailings sands or soil? ,aJA Which tailings cell was the material placed in? f \ ( _________________ 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? __ovf CJ-*, i* l iQ gi-r tk __f-r- U..... __yu-t. __________________________________________________________ Was the material segregated from any Mill material or equipment disposed of in the cell? Yo:____________________________________________________________________ ___________ Was the material segregated from byproduct material from other ISL sources disposed of in the cell? . __Yti_______________________________________________________________ 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 1i Manifest or BOL #: -2 o i~7 - lPP-0C>C)3 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? /ej Documentation of approval UT/?0d</7r/ 7 Was the ISL material segregated from disposed Mill material and other ISL material? Refer to plat(s) used to confirm. CcJ/3 Hc-Z fliteosz/ &/■*#& Was the maximum lift thickness above tailings less than 4 feet thick?\k? 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 ^// 3 e? Is the bottom of each disposal area at least 12 feet from the sides or dikes of the tailings cell? yes Refer to drawings used to confirm, yyi! 3 Will the elevation of the material exceed the plane or grade of the elevation of the uppermost flexible membrane liner of the cell? ASe 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? I f-gj.--ke. f U frr___Ll&AC--__(fcJr__ -pcsz____LlC_L__________________________________________________________ Were void spaces filled with tailings? _____Aas____________________________________________________________________ Was the shipment properly covered? ______^45, juLL__._____________ No.T.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 i Page 13 of 13 —i Manifest or BOL #: 'ton - c^PP- Are additional settlement monitors required to be placed for this generator? If required, where were settlement markers were placed? _______UA_____________________________________ Radiological receipt survey measurements: ___PXD___£_g_ ________“jL U~r Breathing Zone: 1. 2. Was a Breathing Zone Sample collected? Yes or( If yes, what were the results of the sampling? Was a photograph taken during the unloading activities? /Yes)or No Shipper No. 20I7-CPP-00Q3 STRAIGHT BILL OF LADING ORIGrNAL—NOT NEGOTIABLE Carrier No.N/A GREENFIELD LOGISTICS (NAME OF CARRIER)(SCAC) Date Time 6/27/2017 ColInMuJ on Delivery shipments, the letters COD must appear before consignee's name or as olherwise provided in item 430, Sec 1 ~I,.SQ 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 Vehicle- Number N/A No.of noils & container type HM Basic Description Proper Shipping Ntme. Haz*rt Cltts.McnufictOon Numbei (UM or NA). Packing group per 172 101. 172-202, 172.203 Total Quantity CW.tf.1, Volume, Callous, etc.) Weight (Subject to Concctton) Rate Charges (For Camer Use Only) Roll Off UN29I2, RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY (LSA-1), CLASS 7 18.9 m* (24.7 yd*) RADIONUCLIDE: NATURAL URANIUM, THORIUM-230 AND RADIUM- 226 PHYSICAL FORM: SOLID CHEMICAL FORM; UNAT WITH DAUGHTERS TOTAL ACTIVITY: 1.25E8 Bq (0.00337 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 Nole-(l) When the rate is dependent on value, shippers are required to stale specifically on writing the agreed or declared value of the property, as follows. Dm agreed nr declared value of the property is hereby specifically stated by tbe shipper to be not CMenduut i*i______ (2) Where the applicable tanlTprovisions speedy a lumtalion of (he earner’s liability absent a release or a value declaration by the shipper and the shipper doc* not release the carrier's liability or declare a value, the caniA'l liability shall be limited to the Odenl provided bj such provisions SeeNMFL hem 172 P) Commodities requiring ipedal or atfirional care or attention in handling or stowing mini be ao marked and packaged as to ensure soft transportation See Section 2(e) of hem 360 Bills of Lading. Freight Bills, and Statements ofChargcs and Section I (a) of the Contract terms and conditions for a list of such snicks hereby declare that the ecnteius of this consignment are futtv tad accurately described above by the proper shipping name and are classified, packaged, marked, and labdcd'/plaurd. and are in all respects to proper condiliem for transpan according to applicable interim tonal and national governmental regulations ON BRHAl.F OF SHIPPER PREPAID □ COLLECT Signage ubjed to 5cction • ol i he conditions d ihrs tupmenl is to be delivered to the consignee withoul recourse on the consignor, the consignor shall sign the following statement* The earner shall not make delivery oftbis shipment Tvilhoct paymoit of fnaghi and all other lawful charges. N/A FREIGHT CHARGES FREIGHT PREPAID p< «hcn bos at nghl uchecked Check box if charges 3 ire to be collected RFCFTVFJ), adijeui 1o live i:IuuficaiKins ind twitTi >n cFa.t on lb* Out ol tuoe of rfeii Bit] rf Lodcaa- Ibe properly detenbod above *frp*rCTl gont cuefX ruled (ccwUetU ml ocodnun of oonicn] of pacLipcs snbtcrti), nurlccj. Mr.* urdcrtiood ihroughoat Ubi onniivuliSBic—^ciyFeratfi wwoipommiw wpawrwion nfOmprercrty yaderfte c<wtnid)«ycei loe»nv fcuttiaual pbw (if delivciy «mrfieihnniiw> ifnnilwarte glhrrW* to 4<lim to unba earner on ihe pmperty over •Ilor wv'^rtioaot'MidroulalorUvtinatHUavd pany««ay limcoKcreitediialloran'mdivofcrtv ihelewry aerner la he (nrfmiiBd kereundei ihafl be MitjKS loaP (ha Ulof ladta lena> md ocnfaliooi i» Ihcgmeiiuu duvluu Shipper tenbycerutk* that ha a feailiar wift all ihe lading temu and uoiditm ai (he gotcmnG daiitKaln nl die od icrmi mti coodiboni ore beiaby agraad In by (he thrppcr and atKCfled far tumidf ai4 hn armpn dcmneS a, ■rtMtcrf abow »hith and eanv rubai tl n mutually agreed at lo ca »ihe dtfe ollhe darmal r (ihe word omer being l k«mer ol alt nr n) of. md SHIPPER:CAMECO RESOURCES PER DATE CARRIER:GREENFIELD LOGISTICS per ft/E cL DATE C-ZF-IT- Rev4Iune09, 2016 Page 1 of 1 WYO-RPP-FORM-031 Bill of Lading.xlsx RSO: Operations: Energy Fuels Resources (USA) Corp. White Mesa Mill 6425 S. Highway 191 Blanding UT 84511 ** Reprinted by 4 at 06/28/17 07:26:58 ** 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: Transaction No. 53157 Date Time 06/28/2017 06:57 06/28/2017 07:26 Gross: Tare: Net: 63600 lb (M) 44820 lb 18780 lb Comments: TRL # GFLU 001041 Operator: 4 Charge by Weight Signature: Smith Ranch Controled Elevation used (Cell 3) 5612.27 Area Elevation Transit Shot Initial shot for trench 6.38 Top of trench 5607.83 10.82 Bottom of trench 5602.55 16.1 Initial shot used for material 6.38 Too of material in trench 5606.69 11.96 Top of cell 3 Liner 5608.5 Feet below liner 1.81 SU. ^ ' <ZCrn -C ??' 0003 Feed Material Receipt Name of generator of shipment: Bill of Lading #: Activity in Curies: Radionuclides:_________________________________ The amount of material that leak out of the package (if known): The amount of material that leak out of the conveyance (if known): Can it be determined when the leak occurred? Corrective Actions: RSO: (Print Name)(Signature)