DRC-2018-001374 - 0901a068807b40f9

State of Utah
GARY R HERBERT
Governor
SPENCER.I COX
Lieutenant Governor
Department of
Environmental Quality
Alan Matheson
Executive Director
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Scott T Anderson
Director
DRC-2018- 00
MEMORANDUM
TO:Project File C-2017-17
THROUGH: Russell J. Topham, PE
Phil Goble, Uranium Mill Section Manager //£
FROM: Heather Mickelson, PE
DATE: February 6, 2018
SUBJECT: January 26, 2018 Inspection of disposal of 1 le.(2) decommissioning debris from in situ
leach facilities at the White Mesa Uranium Mill. Radioactive Material License No. UT
1900479.
Authority
Radioactive Materials License #UT1900479 Amendment 8, 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 the following
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 P O Box 144880 • Salt Lake City', UT 84114-4880
Telephone [phone] • Fax [phone] • T.D D [phone]
www deq.utah.gm>
Printed on 100% recycled paper
is demonstrated to be impracticable or the advantages of onsite burial clearly outweigh the benefits of
reducing the perpetual surveillance obligations.”
Observations
First Quarter 2018 ISL Decommissioning Debris Disposal Inspection Report
February 6,2018
Page 2
Heather Mickelson, PE of the Utah Division of Waste Management and Radiation Control (the
Division), observed the disposal of nine (9) loads of 1 le.(2) byproduct material on January 26, 2018 at
the White Mesa Uranium Mill. The mill is owned and operated by Energy Fuels Resources (the
Licensee). Notifications of the disposals were received by the Division on December 7, 2017 and
January 16, 2018.
Operating Procedures and Records
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. Revision R-3.3,
dated November 13, 2014, is the most recent version.
The Licensee maintains hard copies of the buried 1 le.(2) material records onsite. The current year’s
disposal records are held inside the White Mesa office building and prior years’ records are located
within a storage container outside of the office building. The storage locations were reviewed with the
Licensee with this inspection. A copy of the data packet for each load is attached to this report.
The Licensee maintains a map of Tailings Cell 3 in the mill office that shows the dedicated disposal
locations for each 1 le.(2) byproduct material generator. The Licensee provided the Division an updated
version of this map during the inspection.
1 le.(2) Byproduct Material Disposal Activities and Description
Prior to January 26, 2018, disposal pit locations were determined, located by survey, and excavated.
The bottom of the excavations extended into the tailings sand. The 1 le.(2) byproduct material was
placed near the burial pits and processed for burial. Barrels were crushed and pipes were broken down,
as necessary, to minimize the void spaces of the compacted 1 le.(2) byproduct material.
During the January 26, 2018 inspection, the Division observed the final disposal activities. The depth
was surveyed prior to material placement into the excavation (Photo 1). Once the 1 le.(2) byproduct
material was in the excavation and compressed (Photos 9 and 11), the top of the material was surveyed
(Photos 5 and 8). Clean cover was then placed over the 1 le.(2) byproduct material and then compacted
to further minimize void space (Photos 3, 6, and 12). The lateral extent of the burial was below the top
of the tailings and above the bottom liner.
A summary description of the disposed 1 le.(2) byproduct material follows.
La Palangana/UEC (South Texas Benavides,
Mining Venture LLP)Texas
Cameco-Smith Ranch (Cameco Douglas,
Resources) Wyoming
Nichols Ranch (Energy Fuels Linch,
Resources)Wyoming
1 load Pipe, trash, and barrels (Photo 2)
4 Filter socks, barrels with trash, hoses, trash,
loads wires, pipe, and chip pipe (Photo 4)
2 Pipe, filter socks, and trash, and tote bags
loads (Photo 7)
First Quarter 2018 ISL Decommissioning Debris Disposal Inspection Report
February 6,2018
Page 3
Crow Butte (Cameco Resources- Crawford, 2 PVC pipe, tote bags, plastic sheets, and trash
Crow Butte Resources, Inc.) Nebraska loads (Photo 10)
Close Out Meeting
A close out meeting to discuss observations during the inspection included with Fleather Mickelson,
Logan Shumway, David Turk, Garrin Palmer, and Tanner Holiday.
Requirements and Compliance Determination
Radioactive Materials License #UT1900479, Condition 10.5B: “All ISL contaminated equipment shall
be dismantled, crushed or sectioned to minimize void spaces. Barrels containing waste other than soil or
sludges shall be emptied into the disposal area and the barrels crushed. Barrels containing soil or sludges
shall be verified by the licensee to be full prior to disposal. Barrels not completely full shall be filled
with tailings or soil prior to disposal.”
The activities observed and information gathered during this inspection supports a conclusion that the
Licensee is complying with this license condition. The 1 le.(2) byproduct material from the La
Palangana and Cameco Smith Ranch loads included barrels that were 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 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 No. 3.
Radioactive Materials License MJT1900479, 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 UUT1900479, Condition 10.5E: “ISL Disposal Requirements. The
licensee shall perform ISL disposal activities in accordance with the currently Director approved
Standard Operating Procedure (SOP) for ISL disposal. Said plan includes the following minimum
provisions:
(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 shall not exceed the plane or grade of the
elevations of the uppermost flexible membrane liner of the tailings cell;
(3) Such ISL byproduct material shall 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
First Quarter 2018 ISL Decommissioning Debris Disposal Inspection Report
February 6, 2018
Page 4
each in-situ leach source shall 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 four 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 Director
in writing at least seven 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
Director on or before November I of each calendar year.”
The activities observed and information gathered during this inspection supports the conclusion that the
Licensee is complying with this license condition. The Division received notice of the disposal on
December 7, 2017 and January 16, 2018 and, which are greater than 7 days in advance of burial on
January 26, 2018. The annual summary submittal will be evaluated by DWMRC separately from this
inspection.
Conclusions and Recommendations
The Licensee appears fully compliant with applicable laws, standards, requirements and License
Conditions with respect to disposal of 1 le.(2) byproduct material generated as decommissioning debris
from ISL uranium recovery facilities.
No new recommendations were identified during this inspection.
Attachments: 11 e.(2) Byproduct Receipt Notifications dated December 6,2017
1 le.(2) Byproduct Receipt Notifications dated January 12, 2018
Document packet for Crow Butte byproduct material bearing Bill of Lading Number W-01-18
Document packet for Crow Butte byproduct material bearing Bill of Lading Number W-02-18
Document packet for DEC La Palangana byproduct material bearing Bill of Lading number LP-026
Document packet for Cameco-Smith Ranch byproduct material bearing Bill of Lading number 2018-SR2-
0004
Document packet for Cameco-Smith Ranch byproduct material bearing Bill of Lading number 2018-SAT2-
003
First Quarter 2018 ISL Decommissioning Debris Disposal Inspection Report
February 6, 2018
Page 5
Document packet for Cameco-Smith Ranch byproduct material bearing Bill of Lading number 2018-SR2-
001
Document packet for Cameco-Smith Ranch byproduct material bearing Bill of Lading number 2017-CPP-
012
Document packet for Nichols Ranch byproduct material bearing Bill of Lading number NR-012-CPP
Document packet for Nichols Ranch byproduct material bearing Bill of Lading number NR-011-CPP
Photo 1. Measuring the bottom elevation of the burial pit for La Palangana 1 le.(2)
byproduct material. Photo taken on January 26, 2018.
Photo 3. Compacting clean cover and over the La Palangana 1 le.(2) byproduct
material. Photo taken on January 26, 2018.
'''■ L-'f* ^T'' j® j
m. r:% .
ii
I
W^;L
■' A, ■
h "•r*kTB
A____L f ^ LA ■..
Photo 2. La Palangana 1 le.(2) byproduct material to be buried. Drums have been
crushed to minimize void space. Photo taken on January 26, 2018.
Photo 4. Cameco-Smith Ranch 1 le.(2) byproduct material to be buried. Photo taken
on January 26, 2018.
Photo 5. Surveying the top of the Cameco-Smith Ranch 11 e.(2) byproduct material
prior to covering with clean cover. Photo taken on January 26, 2018.
Photo 7. Nichols Ranch 1 le.(2) byproduct material to be buried. Photo taken on
January 26, 2018.
Photo 6. Compacting the Cameco-Smith Ranch 1 le.(2) byproduct material and clean
cover. Photo taken on January 26, 2018.
Photo 8. Surveying the top of the Nichols Ranch 1 le.(2) byproduct material prior to
covering with clean cover. Photo taken on January 26, 2018.
Photo 9. Nichols Ranch 1 le.(2) byproduct material being covered with clean cover.
Photo taken on January 26, 2018.
Photo 11. Placing the Crow Butte 1 le.(2) byproduct material into burial pit. Photo
taken on January 26, 2018.
Photo 10. Crow Butte 1 le.(2) byproduct material to be buried. Photo taken on January
26, 2018.
Photo 12. Compacting the top of the Crow Butte clean cover Photo taken on January
26, 2018.
Energy Fuels Resources (USA) Inc.
6425 South Highway 191, PO Box 809
Blanding, UT. US, 84511
435 678 2221, fax [phone]
www.energyfuels.com
Div of Waste Management
and Radiation Control
December 6, 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,
7-00WI
Re: 11 e.(2) Byproduct Receipt Notification
Pursuant to Radioactive Materials License (RML) UT1900479 condition 10.5.F, Energy Fuels Resources
(USA) Inc. is hereby notifying the Division of Waste Management and Radiation Control that the White
Mesa Uranium Mill will be receiving and disposing of two loads by December 22, 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
/i w*
ENERGY FUELS
t—'W*
Energy Fuels Resources (USA) Inc.
6425 South Highway 191, PO Box 809
Blanding, UT. US, 84511
435 678 2221, fax [phone]
www.energyfuels.com
Div of Waste Management
and Radiation Control
January 12,2018
VIA Electronic Mail (PDF) and UPS
Mr. Scott Anderson
Director of Waste Management and Radiation Control
State of Utah Department of Environmental Quality
195 North 1950 West
PO Box 144880
Salt Lake City, UT 84114-4880
Dear Mr. Anderson,
Re: 11 e.(2) Byproduct Receipt Notification
Pursuant to Radioactive Materials License (RML) UT1900479 condition 10.5.F, Energy Fuels Resources
(USA) Inc. is hereby notifying the Division of Waste Management and Radiation Control that the White
Mesa Uranium Mill will be receiving and disposing of two loads by January 26, 2018.
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.
JAN 1 6 2018
yK^2Dl£rW(Pd?
cc: Denver Central Files
No.: PBL-10
Rev. No.: R-3.3
ENERGY FUELS RESOURCES (USA) INC.
j STANDARD OPERATING PROCEDURES
1
Page 11 of 13 1
Date: November 13,
2014
Title: 1 le.(2) Byproduct Disposal
ATTACHMENT 2
lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date: 1 llft/tS
Name of employee receiving the load: Go*cr\v\. ___
Generator of the Byproduct Material: Q /_*.
Shipper’s Manifest or Bill of Lading number: L_ P- 026_______
Was the State of Utah given notice to the receipt/disposal activities associated with this load?(Ye^pr
No
Who gave and when was the notification given?
... _t__JL_P"~ C>jL\___ ...
Description of byproduct material disposal area/activities:
Pr^e-, 4-r^tU. ..__Sg,g_
Has each drum been inspected to identify the presence of any void spaces? _______
Have all drums with void spaces been filled with tailings sands or soil? _____
Which tailings cell was the material placed in? It ^ ____________
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?
_fv 1._ __eL . jl-*-_____________i".?r_£.wk_x._Ls^... 4"-. a f Lo
__________________________________________________________
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 #: C P-Q3-&
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? V<r5
Documentation of approval tf-WOOnTy A™*'"?&
Was the ISL material segregated from disposed Mill material and other
ISL material?
Refer to plat(s) used to confirm. O// 3 He- Z. 0,'s&G*ui Ar-tct g?
Was the maximum lift thickness above tailings less than 4 feet thick?&
Was the maximum lift thickness of subsequent lifts less than 2 feet
thick?&
Has 4 foot of tailings sands been maintained under each disposal
area?^
Refer to drawings used to confirm <fW/ 3
Is the bottom of each disposal area at least 12 feet from the sides or
, dikes of the tailings cell? Ye ■>
Refer to drawings used to confirm. 3 S'tnsY &
Will the elevation of the material exceed the plane or grade'of the
elevation of the uppermost flexible membrane liner of the cell?
aJ>
How was this confirmed (e.g., survey or review)
Jiitri/t .v &
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?
p wC~4-W t*._4^3 Ccn_£*.4__l caJ f___ht__11 ^t_ffxr- >
Were void spaces filled with tailings?
YxJL
Was the shipment properly covered?
'JtS____________
I
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: I le.(2) Byproduct Disposal
Page 13 of 13
i No.: PBL-10
i Rev. No.: R-3.3
Date: November 13,
2014
Manifest or BOL #:
Are additional settlement monitors required to be placed for this generator?/I/A-
If required, where were settlement markers were placed?
-a/a.
Radiological receipt survey measurements:
m.» , *«g-/tur- pr f>-£>
Breathing Zone:
1. Was a Breathing Zone Sample collected? Yes o
2. If yes, what were the results of the sampling?
Was a photograph taken during the unloading activities? (Yesj)r No
Shipment Number
BILL OF LADING • LICENSED MATERIAL SHIPPING FORM
24-HOUR EMERGENCY CONTACT NUMBER/PROVIDER & CONTRACT NAME OR No.
>830) 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 - Standing, Utah
ADDRESS: 5781 FM 3196 Benavides, TX 78341 ADDRESS: 6425 S Highway 19 Standing, UT 84511
SHIPPER TELEPHONE No.: [phone] CONSIGNEE TELEPHONE No.: [phone]
SHIPPER/TRANSPORTER INFORMATION
R06062 CONSIGNEE NRC/STATE UCENSE No.: UT1900479
SHIPPER PHMSA REGISTRATION No.: 071111550027TV
CARRIER ADDRESS: 601S 200 E Blanding, UT 84511
CARRIER PHMSA REGISTRATION No.: 071113550019V
SHIPPER NRC/STATE LICENSE No.:
SHIPPER USDOT No.: 148604
CARRIER NAME: Cosby Trucking
CARRIER USDOT No.: 298957
NUMBER
OF UNITS HM
DESCRIPTION OF MATERIAL, ARTICLES, SPECIAL MARKS, EXCEPTIONS
UN PSN CLASS
GROSS
WEIGHT
KG (LBS)
1
TRAILER
UN 2912 RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY (LSA-1)
(Solid Byproduct Material)
Activity 37 Mba ( (Y OOl Cil
Curie x 3.7E4 = 1 Megabecquerel
Volume 459 cubic feet
7 Estimated
18,143
(40,000)
♦♦♦•EXCLUSIVE USE SHIPMENT****
CATEGORY OF LABEL(S) APPLIED TO PACKAGE - RADIOACTIVE LSA,
EMERGENCY RESPONSE DOCUMENT ATTACHED - 2016 ERG Section 162
This is to certify that the above-named articles are properly classified, described, packaged, marked, and labeled, and are in proper condition
for transportation according to the applicable j^gul^tions of the Department of Transportation.
SHIPPER'S SIGNATURE - DATE
DRIVER'S SIGNATUR^ _________________________ DATE,
DATEDESTINATION SIGNATURE OF
1-16-18
1-16-18
I- I ? -I ^
INDICATION OF LEAKAGE YES, EXPLAIN
Controled Elevation used (Cell 3)
UEC La-Palangana
5612.6
Area Elevation Transit Shot
Initial shot for trench 2.23
Top of trench 5607.4 7.43
Bottom of trench 5600.81 14.02
Initial shot used for material -2.23
Too of material in trench 5605.82 9.01
Top of cell 3 Liner 5608.5
Feet below liner 2.68
Energy Fuels Resources (USA) Corp.
White Mesa Mill Transaction No.
6425 S. Highway 191 53322
Blanding UT 84511
** Reprinted by 4 at 01/30/18 14:03:24 **Date Time Scale
In:01/18/2018 07:38 1
Out:01/18/2018 08:13 1
Vehicle ID:
Trailer ID:
815 COSBY TRUCKING
Gross:60720 lb (M)
Account ID:UEC MNT LU UEC LA PALANGANA Tare:33100 lb
Order ID:
Owner ID:
Material ID:11(e)2 Mat 11(e)2 Material Receipt
Net:27620 lb
Destin. ID:BLANDING
SU ptA*.
Comments: TRL# 5
Operator: 4 Charge by Weight
Signature:
(
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INrC.
Rev. No.: R-3.3 STANDARD OPERATING PROCEDURES
Date: November 13, Title: 1 le.(2) Byproduct Disposal
2014
Page 11 of 13 !
ATTACHMENT 2
lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date: kltflzet
Name of employee receiving the load: Tusir*- tc,
Generator of the Byproduct Material:
Shipper’s Manifest or Bill of Lading number: F -S fix- oo'-l
Was the State of Utah given notice to the receipt/disposal activities associated with this load'^Yesjor
No
Who gave and when was the notification given?
"Oavv - A-Tur f) I jiT-IZ&t % ________________________________________
Description of byproduct material disposal area/activities:
b-e-e. t— <1 ................... .........................
Has each drum been inspected to identify the presence of any void spaces? ______ juA
Have all drums with void spaces been filled with tailings sands or soil?_____ 'ki&______
Which tailings cell was the material placed in?______3 _________________ _ ___
Was the material placed on a tailings beach area of the cell or on an area of the cell that was underlain
by tailings sands?
. '/YVfeT.tJC.Le<.,(—uVa. s—fi a~t- — .a-—l~-. L LsA-f T a___4~^- e S .
Was the material segregated from any Mill material or equipment disposed of in the cell?
.. -V.)_______ _______________________________..
Was the material segregated from by-product material from other ISL sources disposed of in the cell?
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3.3 STANDARD OPERATING PROCEDURES Page 12 of 13
Date: November 13,
2014
Title: lle.(2) Byproduct Disposal
Manifest or BOL #: -o«W
Have the thickness and placement measurements been verified and documented for the disposal area
by the engineer, specifically:
1
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 V77 7
Was the ISL material segregated from disposed Mill material and other
ISL material? Ye-s
Refer to plat(s) used to confinn. &// 3 /A- A Peters*! /br'*-&
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? Ye 5
Refer to drawings used to confirm Pr// 3 &
Is the bottom of each disposal area at least 12 feet from the sides or
dikes of the tailings cell? Yc y
Refer to drawings used to confirm. Cri! 3
!
&
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?
r. a, la a \t^s 't- _ H 4Vt^ve^ p
Were void spaces filled with tailings?
___'Ls_____
Was the shipment properly covered?
"No.: PB1.-10 " f ENERGY FUELS RESOURCES (USA) INC
Rev. No.: R-3.3 ! STANDARD OPERATING PROCEDURES
Date: November 13, ! Title: 1 le.(2) Byproduct Disposal
2014 _ _._j_ __ _ ___________________
Manifest or BOL #:
Are additional settlement monitors required to be placed for this generator?
/t/A_____________________________________
i
i Page 13 of 13
If required, where were settlement markers were placed?
Radiological receipt survey measurements:
O-H /L^ __P rp - c&c>
Breathing Zone:
1.
2.
Was a Breathing Zone Sample collected? Yes o
If yes, what were the results of the sampling?
Was a photograph taken during the unloading activities? (^Ysjor No
STRAIGHT BILL OF LADING
ORIGINAL-NOT NEGOTIABLE
Shipper No. 2018-SR2-004
Carrier No. N/A
GREENFIELD LOGISTICS
(NAME OF CARRIER)(SCAC)
Date 1/17/2018
Time
Collected on Delivery shipments, the letters COD must appear before consignee's name or as otWwise
provided in 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:1 [phone]
Mr. John Zaidan; Contractual Agreement with Quantum Murray
Route: See map Vehicle.
Number N/A
No of units &
container type HM Basic Description
Proper Stappiti Heme, Hind Number (UM or NA). Pbdrinj group, per 172.101, 172 202, 172 20J Total Quantity
(Wetgbl. Volume. Callonl, elc )
Weight
[Sulgecl lo
Correction)
Rate Charges
(For Carrier Use Only)
i Roil oir UN2912, RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY (LSA-1),
NON FISSILE, CLASS 7
RADIONUCLIDE: NATURAL URANIUM, TH6RIUM-230 AND RADIUM-
226
14.8 m’ (19.38 yd1)
PHYSICAL FORM: SOLID
CHEMICAL FORM: UN AT WITH DAUGHTERS
TOTAL ACTIVITY: 9.8E7 Bq (0.00265 Ci)
EXCLUSIVE USE SHIPMENT: THIS VEHICLE IS ASSIGNED FOR
EXCLUSIVE USE OF CAMECO RESOURCES, INC. UNDER PROVISIONS
OF 49 CFR 173.427 INCLUDING EXEMPTING FROM MARKING AND
DO NOT LOAD OTHER FREIGHT IN THIS VEHICLE, TRANSFER EN
ROUTE, OR BREAK SEAL__________________________ ______
PLACARDS TENDERED:YES: X NO:ADDRESS N/A
tae-O) Where the nue la dependent on value, ilitppenire required tosutc
specifically oo wiung the agreed or declared value of the property, as follows: The
agreed or declared value of the property t» hereby specifically dated by the shipper to
pc not exceeding per_________
(2) Where the applicable larifT provisions tpcofy a limitation of the carricA liability
absent a release or • value declaration by the shipper and the shipper does not release
the aimer's liability or declare a value, the earner's habUKy shall be limited to the
c*tcnl provided bv such previstom See NMFL itan 172.
(3) Commodities requmng spedsl or additional care or attention in handling or
stowing ram be to marked sod packaged as to ensure safe transportation Sec
Section 2(e) of item 360. Bills tfLafing. Freight Bills, and Statetnenls of Charges
nnd Scctno 1(a) of the Contract tenrs and conditions for a list of such arudes
COD Amt J
hereby declare tluu iIk contents of this consignment are fully arel accurately described above
by the proper shipping name and are dtsdfled. packaged, marked, and labdeeV/placard, and
arc is all respects m proper condition for transport according u> applicable inlcrrairenal and
ml govcntmemal regulations.
ON BEHALF OF SHIPPER
'^ubjecTto Section 1 oflte'cothblww d Urn-------
shipment is to be delivered to the consignee
without recourse on the coraignor. the consignor
shall sign the following statement
The carrier Shalt sol make delivery of this
shipment without payment of freight and all other
lawful charges.fcJ/A
iSLuaiure of Cousin**!
C.O D FEE
PREPAID □ N/A
COLLECT
□
TOTAL
NM
FREIGHT CHANGES
FREIGHT PREPAID
except when Check box if charges
hnulnfH_______
RF.CEIVEDi Htafcd K» ibe cb*H(ic*uii tod toidi m tSS& on lh« iBW of US#* of lhi» maoMAiiaa. ihe prc^eriy de«cnM ab^.i* qipocnt food eider, oupiai Md fcntmaal eonliun cfcoricBa of (aceape* *»iluw»n). mertad, ud fcitmed O w&Mmi «tov. .AkSi nd crar (|M cjrrki bciflj
thii oo#tree) m fDBaiageny pmo* oreerponiion in pOMcanon of ihn propertj Hndtrtfic ianUsct)ofre(t toesny toib unui pt>c< oTddibvy at aid d^aiMw, tU reM, ethcrww^deliwrTto oaoWcerwon th« n»»* to wid deamdwi !l n EniUilly (grtod utoodt c^ncrofoU voy si; taid
purport* o*oi •> cm oay porticocf row*»dcmuiiea snd u to each (any (t *»y im ■torcssd a rii or tov radpn>f«ny-lhaimry wo totaepEriumed brnnidtr bo nikjea toil iW bJ rfbd»mHrin»uumlrnitinlh»ywcumg ttontljaeaii «atti»4»Uof iho Uuynwm,
Stopper hereby cunfto UiM h* U balilsv *ilb «D iho t«» ood a » wid the Bid tcmui ad ccndilm ore hereby •tread toby lha itoppci and acopred lor hireadfud hii i
SHIPPER:CAMECO RESOURCES CARRIER:GREENFIELD LOG1SJICS
PER ^Vv'v-, r PER
DA3E DATE A/S'-/S'
RSO:
Operations:
Elution No.
Rev 5 - October 19, 2017
Page 1 of 1
WYO-RPP-FORM-031 Bill of Lading.xlsx
Energy Fuels Resources (USA) Corp.
White Mesa Mill
6425 S. Highway 191
Blanding UT 84511
Vehicle ID:
Trailer ID:
Account ID:
Order ID:
Owner ID:
Material ID:
Destin. ID:
1001
11(e)2 WYO SMITH RANCH
In:
Out
11(e)2 Mat 11(e)2 Material Receipt
BLANDING
Comments:
Operator:
Signature:
TRL#GFLU1560
4 Charge by Weight
Transaction No.
53323
Date Time Scale
01/18/2018 11:59 1
01/1-8/2018 12: 48 1
Gross:
Tare:
Net:
49960 lb (M)
40620 lb
9340 lb
Smith Ranch
Controled Elevation used (Ceil 3) 5612.6
Area Elevation Transit Shot
Initial shot for trench 2.23
Top of trench 5608.94 5.89
Bottom of trench 5601.53 13.3
Initial shot used for material 2.23
Too of material in trench 5606.41 8.42
Top of cell 3 Liner 5608.5
Feet below liner 2.09
s U'l
No.: PBL-10
Rev. No.: R-3.3
Date: November 13,
.2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 Ie.(2) Byproduct Disposal
Page 11 of 13
ATTACHMENT 2
ile„(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date:__dullS
Name of employee receiving the load: T^rry <C|a.<>Jl/’. ______
Generator of the Byproduct Material: ,.g ~
Shipper’s Manifest or Bill of Lading number:
Was the State of Utah given notice to the receipt/disposal activities associated with this load?(Ye^ or
No
Who gave and when was the notification given?
_Dau 1 A- _llLzaIci
Description of byproduct material disposal area/activities:
Er&.i'L. _ pU^»4r>f - yte.'H'*-
Has each dram been inspected to identify the presence of any void spaces? i/A-
Have all drams with void spaces been filled with tailings sands or soil?A/Ar~
Which tailings cell was the material placed in?___| ( ^ _______
Was the material placed on a tailings beach area of the cell or on an area of the cell that was underlain
by tailings sands?
/-A £.1 _iCsc. as—__________ujaj eXa 4~o »- ^
Was the material segregated from any Mill material or equipment disposed of in the cell?
iVcU________________________________________ ____________,
Was' the material segregated from byproduct material from other ISL sources disposed of in the cell?
-V'cJ______ -........................-____________ ___________________________________
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3.3 STANDARD OPERATING PROCEDURES Page 12 of 13
Date: November 13,Title: 1 le.(2) Byproduct Disposal
2014
Manifest or BOL #:ZOlt-sAVZ-COZ
Have the thickness and placement measurements been verified and documented for the disposal area
by the engineer, specifically:
!
!Engineer’s or
1 Environmental
Coordinator’s
Initials
Was the material placed in a cell approved by the executive Secretary
for ISL waste disposal? fry
Documentation of approval -fi ^Tic/06 lt7‘f 7 &
Was the ISL material segregated from disposed Mill material and other
ISL material? i^-5
Refer to plat(s) used to confirm. -5 j/e.z £>,$,3030/ /he^jr
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? Yr <
Refer to drawings used to confirm £0,^1
Is the bottom of each disposal area at least 12 feet from the sides or .MZy-----------------------------------------------
dikes of the tailings cell? fv ■;
Refer to drawings used to confirm. £e H 3 f
Will the elevation of the material exceed the plane or gracle 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?
....^ V-__________H- 4" - £ b ■"•HU- (Xo 2.CTL
Were void spaces filled with tailings?
__yfes...................
Was the shipment properly covered?
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 13 of 13
: No.: PEL-10 | Rev. No.: R-3.3
; Date; November 13,
2014
Manifest or BOL #: 4-0 1 g -SAVT.-OG'^
Are additional settlement monitors required to be placed for this generator?_____i/A ______________________________
If required, where were settlement markers were placed?_ yt/A___ ____
Radiological receipt survey measurements:
PiTD- O < M-c> UM. 12-/ Ur'
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 activitievr YeNor No
STRAIGHT BILL OF LADING
ORJGINAL-NOT NEGOTIABLE
Shipper No. 2018-SAT2-003
Carrier No. N/A
GREENFIELD LOGISTICS
(NAME OF CARRIER) (SCAC)
Date 1/9/2018
Collected oii Deli’vay shipments, rhe letters COD must appear before consignee's name or as otherwise
provided in item 430, Sec. 1
Time ZO
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:1 [phone]
Mr. John Zaidan; Contractual Agreement with Quantum Murray
Route: See map Vehicle:
Number N/A
No of units &
container type HM Basic Description
Proper Stupfing Name, HazaniClaa.tdentiriail'cn Number (UM or NA). Packing group, per 172 101, 172 202, 172.203 Total Quantity
(Weigh!, Volume. Gallons, clc.)
Weight
(Subjed to
Conwuon)
Rate Charges
(For Cirricr Use Only )
I Roll Off UN2912, RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY (LSA-1),
NON FISSILE, 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)
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
DO NOT LOAD OTHER FREIGHT IN THIS VEHICLE, TRANSFER EN
ROUTE, OR BREAK SEAL
PLACARDS TENDERED:YES' X NO:ADDRESS N/A
NoM 1) Where tlie nle it dependent cm value sbippen are required to state
specifically on writing (he agreed or declared value of the property, as follows The
agreed or declared value of the property is hereby specifically slated by the shipper to
be not exceeding____________ _ act.
(2) Where the pppbcabie urifT provisions specify a limitation of the carrier's liability
absent a release or a value declaration by the shipper sod the shipper does noi release
the carrier's liability or declare a value, the earner's liibaby shall be limited to the
extent provided by such provisions See NMFL item 172
(3) Commodities requiring special oraddukmal care or eitentjon in handling or
stowing nwsi be to marked and packaged ns to ensure safe transportation See
Section 2{c> of «iem 360, Bills of Lading. Freight Bills, and Statements of Charge*
Kid Section Ua) of Ihe Contract terms and conditions for a list of sodi articles.
I hereby declare Hist (he contents of this consignment are Hilly and accurately described above
by the proper abipping name and are clarified packaged, marked, and labdedVpIacird. and
are ia all respods in proper condition for transport according to applicable international and
national governmental regulations.
ON BEHALF OF SHIPPER
Subject (o Section / 0i Lte conditions it ihn
shipment is lo be delivered to ihe consignee
without recourse on iIk consignor the consignor
shell sign the following statement:
The earner shall not make deliwnr of this
shipment withoil payment of freight and all other
brwfiil diarges.
--..... N/A............. __
■ iStgn'durc ofConugiorj'' • •' .
TOTAL
CHARGES
FREIGHT CHARGES
FREIGHT PREPAID
except when Check bov if charges
1 »I*J iotiatd M indcitsl uhm* which aid eam« (ihe wwd amtr boi«vRECEIVED iut)evt lo I hr diwifie»i>o« trd anil* rr cftccl no lha date ofi-uwC of ihu Bill of Lading, ihe pruftny duenbed abo\« in apparent t^ud oidcr cmcjiI n iMled (aailcuu ■ndcnndiUOtl orcoRIUS ufpactxm unLfuwn). mail*
undorflrod ihcoalNju* lhi» cwrraei a» n*cirw»g *fiv p*rm a cuponitiua ni poumwim oftbi* preperty L-*dcr tbc crmrndxgrou tu cany mas areal ptiMofdHoafvaiMiddM'irutiwv ilnnibcnXB, odicrwiM u deliver tottoUier earner oe lit nMle to Mnd destiwln. Ii u miuully »$re«l at loach wrrwrui'nilorMy of wid
rmpcnyoverillQf aiy p>nr>,nid‘«nJ mule indminium nut u to each p3rt> stony niae iniemial in ill or an) said profxny. lhai avtrvscivmo Oepertoreud hereunder dull be ubycEl to oil ibc bull orbOingicrini and Mndilwas ia ihe aovwaagctaMijeiUcnoci (kcdaieol tie ih^vwnl
Shipper hereby otrlifen Uu> h:« boiiliar uid* >3 Ite loibni urn's snd eunditnis in Mk j^ernlrrj clasilieniwn end ihe Mid term* sod eonivoej are hereby agnod tuby ibe shipper and accepted for himself seid his aac|ci
SHIPPER:CAMECO RESOURCES CARRIER:GREENFIELD LOGISTICS
PER
\\ql7.QiSr
PER -T7 £<^
DATE DATE /1
RSO:
Operations:
Elution No.
Rev 5 - October 19, 2017
Page 1 of 1
WYO-RPP-FORM-031 Bill of Lading.xlsx
Energy Fuels Resources (USA) Corp.
White Mesa Mill
6425 S. Highway 191
Blanding UT 84511
Vehicle ID:
Trailer ID:
Account ID:
Order ID:
Owner ID:
Material ID:
Destin. ID:
In:
Out
1001
11(e)2 WYO SMITH RANCH / HIGHLAND
11(e)2 Mat 11(e)2 Material Receipt
BLANDING
Comments: TRL # GFLU001041
Operator: 4 Charge by Weight
Signature:
Transaction No.
53313
Date Time Scale
01/11/2018 07:20 1
01/11/2018 07:52 1
Gross: 50460 lb (M)
Tare: 44320 lb
Net: 6140 lb
2.6 I?' SAT2-003
Smith Ranch
Controled Elevation used (Cell 3) 5612.6
Area Elevation Transit Shot
Initial shot for trench 2.23
Top of trench 5608.94 5.89
Bottom of trench 5601.53 13.3
Initial shot used for material 2.23
Tod of material in trench 5606.41 8.42
Top of cell 3 Liner 5608.5
Feet below liner 2.09
Z0\$- sA~Cz ' 00 3
No.: PBL-10 ; ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3.3 STANDARD OPERATING PROCEDURES
Date: November 13, Title: 1 le.(2) Byproduct Disposal
2014 _______
Page 11 of 13
ATTACHMENT 2
lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date: ij^lxai^r
Name of employee receiving the load: it-______
Generator of the Byproduct Material: _ /(- ■ -1
Shipper’s Manifest or Bill of Lading number: Zoi r-Sei. )
Was the State of Utah given notice to the receipt/disposal activities associated with this load?(^Y^ or
No
Who gave and when was the notification given?
ATU/W______\\J__________________________________________________
Description of byproduct material disposal area/activities:
lt-A *~-<i )_____________________________....
Has each drum been inspected to identify the presence of any void spaces?
Have all drums with void spaces been filled with tailings sands or soil?__
Which tailings cell was the material placed in? C^[j ________
-Mb.
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?
. AAfvEtrlLfoi—trOfej Lu^-1 uJtvT 4-q 4-U<.
Was the material segregated from any Mill material or equipment disposed of in the cell?
_________kL__:______________________
Was the material segregated from byproduct material from other ISL sources disposed of in the cell?
....... .Vo............... ......... ..._ .
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 #: ?ct9-se.7-'C>ct
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 M bf/‘t Vovyi &
Was the ISL material segregated from disposed Mill material and other
ISL material? yr<.
Refer to plat(s) used to confirm. OH 3 7/e- 2- Artn &
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? pV r
Refer to drawings used to confirm Ct!/ 3 C&'>sf Ora—->*y &
Is the bottom of each disposal area at least 12 feet from the sides or
dikes of the tailings cell? A-c s
Refer to drawings used to confirm. 3
Will the elevation of the material exceed the plane or grade of the
elevation of the uppermost flexible membrane liner of the cell?
A/a,
How was this confirmed (e.g., survey or review)
J£L____:______
T7'
How was the area compacted? Was each lift compacted by heavy equipment (such as a Cat D-6) at
least 4 times prior to placement of subsequent lifts?
Arc,fry-__u; fU A ___y__f-c-T
Were void spaces filled with tailings?
'JtS
Was the shipment properly covered?
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC.!
Rev. No.: R-3.3 STANDARD OPERATING PROCEDURES Page 13 of 13 ,
Date: November 13,Title: lle.(2) Byproduct Disposal
2014
Manifest or BOL #: ?oi SZ7.-G0 (
Are additional settlement monitors required to be placed for this generator?
J/A
If required, where were settlement markers were placed?
a/a ___________________________
Radiological receipt survey measurements:
Q>of' ___ 9ZP 'OOP---------------
Breathing Zone:
1. Was a Breathing Zone Sample collected? Yes of1^q3
2. If yes, what were the results of the sampling?
Was a photograph taken during the unloading activities?,/?^ or No
STRAIGHT BILL OF LADING
ORIGIN AL-NOT NEGOTIABLE
GREENFIELD LOGISTICS
Shipper No.2^>11?-<5&2-
Carrier No. N/A
Date I ,3>201S
(NAME OF CARRIER)(SCAC)
Time
Collected on Delivery shipments, ihe letters COD must appear before consignee's name or as otherwise
provided in itera 430, Sec 1.
To: Consignee Energy Fuels
Street: 6425 South HWY 191
City: Blanding State: UT Zip Code: 84511
From: Shipper Cameco Resources
Street: 762 Ross Road
City: Douglas State: WY Zip Code: 82633
24 hr Emergency Contact Tel. No:1 [phone]
Mr. John Zaidan; Contractual Agreement with Quantum Murray
Route: n/a
Vehicle:
Number N/A
No.of units &
container type HM Basic Description
Proper Slipping Name. HazjnJ Clis.lilcroincalKni Number (UM or NA), Paddng group, per rn 10], 172.102. 172 20]Total Quantity
(Weight, Volume, Gallon, dc )
Weight
(Subjtstio
Correcuoa)
Rate Charges
(For Gamer Use Only)
I Roll Off UN2912, RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY (LSA-1),
NON FISSILE, CLASS 7 27.8 m* (36.4 yd’)
RADIONUCLIDE: NATURAL URANIUM, THORIUM-230 AND RADIUM-
226
PHYSICAL FORM: SOLID
CHEMICAL FORM: UNAT WITH DAUGHTERS
TOTAL ACTIVITY: 4.62E7 Bq (0.001 Ci)
EXCLUSIVE USE SHIPMENT: THIS VEHICLE IS ASSIGNED FOR
EXCLUSIVE USE OF CAMECO RESOURCES, INC. UNDER PROVISIONS
OF 49 CFR 173.427 INCLUDING EXEMPTING FROM MARKING AND
DO NOT LOAD OTHER FREIGHT IN THIS VEHICLE, TRANSFER EN
ROUTE, OR BREAK SEAL
PLACARDS TENDERED:YES: X NO:ADDRESS N/A
Noie-{ 1) Where the rate is dependent on value, tUppcit are required to State
specifically oa writing the agreed or declared value of the property,« follow*: The
agreed or declared vxlne of the property u hereby ipecifltally stated by the chipper to
be not e«ee<ljngper•
(2) Where the applicable tariff provisions speofy ■ limitatioo oftbe carnert liability
absent a release or a value declaration by the shipper and the chipper does not refcace
ihe aimer’s liability or declare a value, the carrier's liability shall be limited lo the
extent provided by such provisions. See NMFL item 172
(3) Commodities requiring special or additional care or attention in handling or
flowing must be k> marked and packaged as lo ensure saTe transportation See
Section 2(e) ofiiem 360, Bills of Lading. Freight Bills, and Staiementc of Charges
and Section 1(a) of the Contract terms and conditions for ■ tisl of nidi articles.
hereby declare that Ihe contents of thit consignment are Fully and accurately described above
by the proper chipping name and are elassi/led. packaged, marked, and labelcd'/placard, and
arc in all respects in proper condmon for transport according to applicable international and
national governmental rcgalationi.
^ VN BfcON BEHALF OF SHIPPER
.vtejecl to bfetion Tai Lie contDIaou li tKis
shipment is to be delivered to the consignee
wfaboui recourse oa (he consignor, (ho consignor
Stull sign the following statement
The carrier shall not make delivery of Ihis
shipment without payment of freight and ill other
lawful charges
___miSmiutiirt at fomu.'nnri
C.OD FEE. PREPAID o K/A
COLLECT
TOTAL
CHARGES
FREIGHT CHARGES
FREIGHT PREPAID
except when Check box if charges
talV4ln»N _ Jti Ip N- I’l.hftfrd
RECEIVED, to the tt • •od lanl&neAKluoibokUBl'martbiiDiDofLadij^.Airvupaty doenbed msppveni arto. isnMl (conloCiaa4 ceMblksofcurtcriioriacLas*! wtau**), miad,«auigiwd. nd desneed a* mdicaied above bxC cams <lbs ml earner t»n
docMirad n uty pBrv^oeeorporMjoo b po««»unof iiu*p«Jf>«ny u»«kr tfw tueiny b na uual pbc««fddi%«y ai widde^waiun, ifoo Os luutc, ethsrwiM W ddmt to (iwtkocvnce c« the to Mid da&MMii. huniauitly epvdutocacbeaimrufelloraayot
ony ponion »f»<droul«todouatoLo»f>d u tooch pany »i «iyun« i»umtod a all ot anymd juf eny iteMry b> b< perfumed bacoadcriUll b« lufajM wall ihe b3l aflatas twm* uid mAbmib ihe pwiing cktsfeaiutca ihcdaieatTIwdapmcM.
Shipper e«m6a thj] he u Eviutar with dl the kding ton« and omduiom in ttie pmcmiAi cknrficaiiiM. and ihe o<d torui* aad oMidibonsare benby epaad w by lb* Utpper and acequed for hnudfand hs amiiaL
SHIPPER:CAMECO RESOURCES CARRIER:GREENFIELD LOGISTICS
PER
DATE
per /
DATE
e™x
\\nltoxr
RSO:
Operations:
Elution No.
Rev 5-October 19, 2017
Page 1 of 1
WYO-RPP-FORM-031 Bill of Lading.xlsx
Energy Fuels Resources (USA) Corp.
White Mesa Mill
6425 S. Highway 191
Blanding UT 84511
** Reprinted by 4 at'01/04/18 11:24:10 **
Vehicle ID:
Trailer ID:
Account ID:
Order ID:
Owner ID:
Material ID:
Destin. ID:
1001
11(e)2 WYO SMITH RANCH
11(e)2 Mat 11(e)2 Material Receipt
BLANDING
In:
Out
Comments: CONTAINER 12
Operator: 4
Signature:
Charge by Weight
Transaction No.
53304
Date Time Scale
01/04/2018 10:46 1
01/04/2018 11:23 1
Gross: 56300 lb (M)
Tare: 42540 lb
Net: 13760 lb
Smith Ranch
Controled Elevation used (Cell 3) 5612.6
Area Elevation Transit Shot
Initial shot for trench 2.23
Top of trench 5608.94 5.89
Bottom of trench 5601.53 13.3
Initial shot used for material 2.23
Tod of material in trench 5606.41 8.42
Top of cell 3 Liner 5608.5
Feet below liner 2.09
^OlS' -S&Z-O&l
<
. No.: PBL-10
; Rev. No.: R-3.3
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDUPFS Page 11 of 13
Date: November 13.
2014,
Title: 1 le.(2) Byproduct Disposal
ATTACHMENT 2
lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date:__i z / 77, /17
Name of employee receiving the load:__Tc.ct_y—________
Generator of the Byproduct Material: -i-lv.
Shipper’s Manifest or Bill of Lading number:;__Zo Cf' cPf-naiZ-
Was the State of Utah given notice to the receipt/disposal activities associated with this load?/<Ye^or
No
Who gave and when was the notification given?
__uMzjih^-------------------------------------------------------------------------
Description of byproduct material disposal area/activities:
, ftl4u— s*>iksi s U .
Has each drum been inspected to identify the presence of any void spaces? Vt-j *■ t*'**
Have all drums with void spaces been filled with tailings sands or soil?
Which tailings cell was the material placed in? f- c ff ___________
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?
/^A fy» <» l _ O' t ^
-----------------------------------—-------------------------------------------------------------------------------------------------------
Was the material segregated from any Mill material or equipment disposed of in the cell?
........ ■ ic.3________________________________________________________________________
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 #:
Have the thickness and placement measurements been verified and documented for the disposal area
by the engineer, specifically:
I 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 # ur /9ao^7j ~7 &
Was the ISL material segregated from disposed Mill matenal and other
ISL material? /n
Refer to plat(s) used to confinn. £,// 3 //*- 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?
Refer to drawings used to confirm £>// 3
Is the bottom of each disposal area at least 12 feet from the sfdes or
dikes of the tailings cell? y, s
Refer to drawings used to confirm. At ft 3 93 J&.
Will the elevation of the material exceed the plane or grade of the
elevation of the uppermost flexible membrane liner of the cell?
AA
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.—c&o-jLttz—Cvdh—U- -t—'d—4:jV«- f<jr:
__LLfet.:______________________________________________________________
Were void spaces filled with tailings?
_________________________________________________________________________________________
Was the shipment properly covered?
,____'isJi______________
1 No.: PBL-10 ; ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3.3 STANDARD OPERATING PROCEDURES j Page 13 of 13
Date: November 13, j Title: 1 le.(2) Byproduct Disposal12014______________|____________ _________________________
Manifest or BOL #: "T-OSl l^-
Are additional settlement monitors required to be placed for this generator?
aM................—.......................................................................................
If required, wheije^were settlement markers were placed?
Radiological receipt survey measurements:
. UP ^$-1 Ur- * 1 2
Breathing Zone:
1. Was a Breathing Zone Sample collected? Yes o^
2. If yes, what were the results of the sampling?
Was a photograph taken during the unloading activities^y es^r No
STRAIGHT BILL OF LADING
ORIGINAL-NOT NEGOTIABLE
Shipper No.^n-CPP-CPt?
Carrier No. N/A
QjjiSr:r" .<1-1 ^
(NAME OF CARREER)(SCAC)
Date \2\^a|cv
Time
Collected on Delivery shipments, the letters COD must appear before consignee's name or as otherwise
provided in item 430, Sec 1
To: Consignee _ ^ ,Energy Fuels
Street: 6425 South 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: 1 [phone]
Mr. John Zaidan; Contractual Agreement with Quantum Murray
Route: n/a nrtiip Vehicle:
Number N/A
No of units &
container type HM Basic Description
Piopei Shipping Nrme, Hazard ru«,!dreilirialion Number (Uhf or NA) Packing group, per 172 101, ) 72.202, 172.202
Total Quantity
(Weight. Voturae, Gallom, etc.)
Weight
(Subject to
Correct cn;
Rate Charges
(For Otmer Use Onh)
1 Roll Off X UN2912, RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY (LSA-1),
NON FISSILE, 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)
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
DO NOT LOAD OTHER FREIGHT IN THIS VEHICLE, TRANSFER EN
ROUTE, OR BREAK SEAL
PLACARDS TENDERED: YES: X NO:ADDRESS N/A
Nctc-t 11 Where ibe rate i» dependent ou value, shippers tn; required to rtate
specifically on writing the agreed or declared tehie cf (Sc prjpcity, as follows The
agreed or declared value of the piepeny ts hereby ipccineally fltied by the shipper ro
be not evceoluiK per
(2) Where the applicable tanff provisions qjceiF.- a llmiutkin cf the earner's habtliiy
abscai a release or a value dedsraUcn b> the shipper and the shipper docs not release
the earner's liability or decUre a value, the Larder's liability kial! be lutulod i« the
eviem provided W soch pravisioas. See KMFL Bern 172
(3) CcunmorijUesmjntnAgspefJJi <v nddmonal care orathnlnn in hindltngor
slowing uust be so marked and packaged as to en?uic sale iransporution See
See bn ?(c) of iieni 360. Bills of lading. Fretfihl Bills, and Statements of Charges
and Seaton 1(a) of the Coclraa terras sad oouditnas for a hst of such imdtv
l nereby declare dial the eoatims cf this concignirent are fulH rod scritrilrtv dornbed ahrve
by the proper ihipping name and are ducifnd packaged, marked, and hbcled/^iaurd, and
are in all reaped! in proper CDfidihon for iranspori ■cao'ding to ipplicxhle iitferitaDoual and
COD Amr $N/A COD FEEPREPAID □ N/A
coiIect
HIPPER
atAjcct Ui season i ol tlie cor-iiltora ti ibis
Shipment tsto be delivered to the consignee
without recourse on theuumgncx. ihcairndgnor
shall sign the following statement
The earner shall aol tnaXe deliver)' of ibis
shiptiwnt wiihout payment <rf freight and all other lawful charges
N/A
tS* jniture of ConsiK.wi
TOTAL
alAMfi N/A
<" ----~W1N BEHALF Of S
Signature
FREIGHT CHARGES
FREIGHT PREPAID
cjtceplubcn Check bos if charges
RLCtiVLU. nb)Mlto;Hc cUiMfturwraand unTimeftel enth«dak«ifsiusorihi> Bill oTLaJ-ng. dc inpnw clocnM »l*nc in arpiw t (n<>iiuda.c'w:|n uoaudfinteawnwl tondiUunot curieni of unlrvwn), ouited cou |nsd. n»Jee«s-»<i m c>rier(ih« eacrcthai;
u.-dt-iBA>d Ihruuahoul lha oontmclui nwaruai onv per«* u* oxputnfcoe m fgnadofi vftFu stjpoty wdc lheowi>tia*.t)naioe» k»c*n> to I'uereu* ^oce uf delivery a« uid dusiutM*. Tv» its reut^ ,aVa>«< lodcnvcr lu nnothcr ar>cr ua lt>c rant4 M n»J debliaxtMA h u nulualty nprac u tocaeheauKTufalltvnnvuC « d property WrnD«»ny ooft-on uf (rxd i« each f*rfy «i nay ’unc inxraad uintlff *ns twd pnT*R>‘ iHit every t*r*S* io b> peifeoturi bemuOa «haO he nuhraa «> «■ the h?II of Wng Icon* »nd urn is the govomea dnnwf edww on *»4nW of lh« tbpox-AShippet hersby cca'ilitn Itmi Se i. fitsSinr witi nil l>« IwWa hntivand oouduwni m [ovem pj <Uuif>uhcn«it<] *e udic'mtawJ cucdiUno ne hnxOy nercod t» fay the (happrrnDd neetTied fur kir-welfand h<i«i(rt>.
SHIPPER: CAMECO RESOURCES CARRIER: R-C^«rfer
pra( >-4\PER
olwl r\date Z-ZO-ll
Rev 5 - October 19, 2017
RSO:
Operations:
Elution No.
Page 1 of 1
WYO-RPP-FORM-031 Bill of Lading.xlsx
Smith Ranch
Controled Elevation used (Cell 3)5612.6
Area Elevation Transit Shot
Initial shot for trench 2.23
Top of trench 5608.94 5.89
Bottom of trench 5601.53 13.3
Initial shot used for material 2.23
Tod of material in trench 5606.41 8.42
.v
Top of cell 3 Liner 5608.5
Feet below liner 2.09
5 U'.f 'i'
Energy Fuels Resources (USA) Corp.
White Mesa Mill
6425 S. Highway 191
Blending UT 84511
Vehicle ID:
Trailer ID:
Account ID:
Order ID:
Owner ID:
Material ID:
Destin. ID:
In:
Out
1413
11(e)2 WYO SMITH RANCH
11(e)2 Mat 11(e)2 Material Receipt
BLANDING
Comments: GFLU001235
Operator: 4 Charge by Weight
Signature:
^ jBAjnA.;
zoiy-^f-0012-
Transaction No.
53299
Date Time Scale
12/22/2017 07:19 1
12/22/2017 08:11 1
Gross:60920 lb (M)
Tare:46340 lb
Net:14580 lb
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC.
! Rev. No.: R-3.3 STANDARD OPERATING PROCEDURES
Date: November 13, i Title: lle.(2) Byproduct Disposal
2014
ATTACHMENT 2
IU.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date:iferknZ___
Name of employee receiving the load:_____
Generator of the Byproduct Material:____NvcLoU
Shipper’s Manifest or Bill of Lading number: vag--orz-- cpP
Was the State of Utah given notice to the receipt/disposal activities associated with this loadT^^^e^or
No
Who gave and when was the notification given?
■- 1-Thi k, ______________________ _________________________________________
Description of byproduct material disposal area/activities:
___fr- ^ _________________________________
Has each drum been inspected to identify the presence of any void spaces? nj/j.
Have all drums with void spaces been filled with tailings sands or soil?flj <4
Which tailings cell was the material placed in?C-e-ll J?
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?
-A't *• t____ _____tt-Vr Gl f- r- l. ^ 4-« TU-c gAjyJtJ.
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?
_______Vo________ _____ __________________________________________________________________
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 #: QiZ-c?(?
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?, ''Id
Documentation of approval & uTi^OO y /y ^&
Was the ISL material segregated from disposed Mill material and other
ISL material? Y?'t
Refer to plat(s) used to confirm. {t f / 3 iU-Z~ /),#/«** i
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? yv ^
Refer to drawings used to confirm ft 3 /Low.
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. 3 vs
Will the elevation of the material exceed the plane or grade of the
elevation of the uppermost flexible membrane liner of the cell?
,U
How was this confirmed (e.g., survey or review)
s'
&
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?
fe. Aolcjr- M t, C p /r- t « Ci.______
Were void spaces filled with tailings?
.>/<J__________________________________________________________ _______________________________________
Was the shipment properly covered?
____'fcJ___________________
ENERGY FUELS RESOURCES (USAJ’INC.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
No.: PBL-10
Rev. No.: R-3.3
Date: November 13, ,
2014
Page 13 of 13
CManifest or BOL #: K\<L-6tz.- r
Are additional settlement monitors required to be placed for this generator?
_______Ay'Ar______________________2____________________________
If required, where were settlement markers were placed?
AA .
Radiological receipt survey measurements:
Pito .pogiY ____
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?es)or No
Uranerz
ZHiROV CORPORATION
STRAIGHT BILL OF LADING
ORIGINAL-NOT NEGOTIABLE
GREENFIELD LOGISTICS
Shipment No.: NR-012-CPP
Date: January 23, 2018
(Name of Carrier)
24 HR. EMERGENCY CONTACT NUMBER: [phone]
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 Z1P:82640
Route: Nichols Ranch to White Mesa Mill, Blanding, UT.Vehicle:
Number T-3
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 U04-2H20
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, described, packaged, marked and labeled, and are in proper condition for transportation according to the
applicable regulations of the Department of Transportation.
Name:Date:
—CARRIER: (^JlJ
SHIPPER: UranerzEnergy-Qorp., an Energy Fuels Company
PER PER “77
DATE I / ^3 'JO I ?DATE
I vM.
Energy Fuels Resources (USA) Corp.
White Mesa Mill Transaction No.
6425 S. Highway 191 53328
Blanding UT 84511
** Reprinted by 4 at 01/25/18 07:58:57 **
Vehicle ID:
Trailer ID:
Account ID:
Order ID:
Owner ID:
Material ID:
Destin. ID:
1001
11(e)2 WYO NICHOLS RANCH
11(e)2 Mat 11(e)2 Material Receipt
BLANDING
In:
Out:
Date Time Scale
01/25/2018 07:27 1
01/25/2018 07:58 1
Gross: 57360 lb (M)
Tare: 44020 lb
Net: 13340 lb
Comments: TRL # 011168
Operator: 4 Charge by Weight
/
Signature
Uranez
Controled Elevation used (Cell 3)
Area Elevation
5612.6
Transit Shot
Initial shot for trench 2.23
Top of trench 5608.31 6.52
Bottom of trench 5602.12 12.71
tial shot used for material 2.23
Too of material in trench 5606.49 8.34
Top of cell 3 Liner 5608.5
Feet below liner 2.01
MV-
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3.3 STANDARD OPERATING PROCEDURES Page 11 of 13
| Date: November 13, *Title: 1 le.(2) Byproduct Disposal
2014 !i
ATTACHMENT 2
lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
o
Date: \d,%in
Name of employee receiving the load: TVr-r-y
Generator of the Byproduct Material: xyi>.Lol.£
Shipper’s Manifest or Bill of Lading number: VQ.-c>M' C-PP
Was the State of Utah given notice to the receipt/disposal activities associated with this load^Yelpr
No
Who gave and when was the notification given?
- _______________________________________________________________________________________________ __________________________ _____________________________ __
Description of byproduct material disposal area/activities:
__Uaho_________________________^ Lv'f-fc.
Has each drum been inspected to identify the presence of any void spaces?mA
Have all drums with void spaces been filled with tailings sands or soil?j/A
Which tailings cell was the material placed in? j { ^
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?
't*tjuii%:F______________f __«j5s=__•v. Lj L ^ 4-p 4-U.
________________________________________ ____________________________________________________
Was the material segregated from any Mill material or equipment disposed of in the cell?
____tcJ__________________________________________________________________
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 #: /jT2 -<g((-£.rY
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 *
Documentation of approval / ,-f uf ! 100 <V 71 A nr* Y
Was the ISL material segregated from disposed Mill material and other
ISL material? Y-e<,
Refer to plat(s) used to confirm. ^// 3 2
Was the maximum lift thickness above tailings less than 4 feet thick?
Was the maximum lift thickness of subsequent lifts less than 2 feet
thick?■Gt?
Has 4 foot of tailings sands been maintained under each disposal
area? Y-t5
Refer to drawings used to confirm Y* // 3 Are* s'S*P
Is the bottom of each disposal area at least 12 feet from the siefes or
dikes of the tailings cell? Yr-5
Refer to drawings used to confirm. 3 Coe-sh
Will the elevation of the material exceed the plane or grade of the
elevation of the uppermost flexible membrane liner of the cell?
/ISO
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 r1 ^_(keXcj-' 4-___lc-axH____________
^ e-i— ____________________________________________________________________________________________________________________________ _____________________________________________________________________
Were void spaces filled with tailings?
Vet ___________________________________________________________
Was the shipment properly covered?
___±tl
No.: PBL-10 | ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3.3 STANDARD OPERATING PROCEDURES
Date: November 13. Title: 1 le.(2) Byproduct Disposal
2014 1
Manifest or BOL #: ^IZ-^l)
Are additional settlement monitors required to be placed for this generator?
___/J&.-----------------------------------------------------------_
Page 13 of 13
If required, where were settlement markers were placed?
—juh. . -. ______________________________
Radiological receipt survey measurements:
__ftXD-/!)_______[.A ^vi5./Uv—
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?(^es^r No
rr? Uranerz
ENERGY CORPORATION
Shipment No.: NR-011-CPP
STRAIGHT BILL OF LADING
ORIGINAL-NOT NEGOTIABLE
GREENFIELD LOGISTICS_________ Date: Dec. 14 2017
(Name of Carrier)
24 HR. EMERGENCY CONTACT NUMBER: [phone]
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 ZlP:82640
Route: Nichols Ranch to White Mesa Mill, Blanding, UT.Vehicle: ?Numbei^^T-a^-/^^ S
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 UO^HzO
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 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, described, packaged, marked and labeled, and are in proper condition for transportation according to the
applical^rejpi]atans_pf the Department of Transportation.
Name: Date: /.l? - /l/~ 7
SHIPPERMJxarrerg'Energy CCrph-^m Energy Fuels Company CARRIER: J QU
PER per /iSQxz /AkMsV
DATE DATE 7 ?.-/<-/-/7_______________________
Energy Fuels Resources (USA) Corp.
White Mesa Mill Transaction No.
6425 S. Highway 191 *53296
Blanding UT 84511
** Reprinted by 4 at 12/18/17 08:25:38 **Date Time Scale
In:12/18/2017 07:35 1
Out:12/18/2017 08:24 1
Vehicle ID:TRI 1413
Trailer ID:Gross:56060 lb (M)
Account ID:11(e)2 WYO NICHOLS RANCH Tare:45040 lb
Order ID:Net:11020 lb
Owner ID:
Material ID:11(e)2 Mat 11(e)2 Material Receipt
Destin. ID:BLANDING
Comments:
Operator:
TRL # GFLU 2052
4 Charge by Weight
Signature JLAJ\A5 1LJ,JL
Uranez
Controled Elevation used (Cell 3) 5612.6
Area Elevation Transit Shot
Initial shot for trench 2.23
Top of trench 5608.31 6.52
Bottom of trench 5602.12 12.71
Initial shot used for material 2.23
Too of material in trench 5606.49 8.34
Top of cell 3 Liner 5608.5
Feet below liner 2.01
5U:fv^*
oil'll'
<
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3.3 STANDARD OPERATING PROCEDURES Page 11 of 13
Date: November 13,Title: 11 e.(2) Byproduct Disposal
2014
ATTACHMENT 2
lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date:i fg/]g
Name of employee receiving the load: Tlrt-y ^1 r
Generator of the Byproduct Material:
Shipper’s Manifest or Bill of Lading number: u) -Ol — M?
Was the State of Utah given notice to the receipt/disposal activities associated with this load? (^fe^or
No
Who gave and when was the notification given?
T^cJL t__U Izilo.
Description of byproduct material disposal area/activities:
Has each dmm been inspected to identify the presence of any void spaces? ■ I /i JA~
Have all drums with void spaces been filled with tailings sands or soil?__________//Ac
Which tailings cell was the material placed in? [ t 3 ____________
Was the material placed on a tailings beach area of the cell or on an area of the cell that was underlain
bv tailings sands?
rhrJ^. ---{ Urt-AtfL...ihv. u^ir. i -fa -t-Lc
Was the material segregated from any Mill material or equipment disposed of in the cell?
_______& J__________________________________. _________________
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 #: UJ -O
Have the thickness and placement measurements been verified and documented for the disposal area
by the engineer, specifically:
Engineer’s or
Environmental
Coordinator’s
Initials
Was the material placed in a cell approved by the executive Secretary
for ISL waste disposal? ylr^
Documentation of approval UVJ9&d V/7
Was the ISL material segregated from disposed Mill material and other
ISL material? , fry Ut.'L.
Refer to plat(s) used to confinn. r,l( 3 Atb&zfet/ A-r*-*
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?X
Has 4 foot of tailings sands been maintained under each disposal
area?
, Refer to drawings used to confirm 3 Cough A?
Is the bottom of each disposal area at least 12 feet from the sides or
dikes of the tailings cell? A 5
Refer to drawings used to confirm. /,// J Corgh,at
Will the elevation of the material exceed the plane or grade of the
elevation of the uppermost flexible membrane liner of the cell?
jtA>
How was this confirmed (e.g., survey or review)
, .y i/z-vr y-z.__________
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 <^,__uSj&vJI__________________________A,<*Lg Z e-r- <b.Jr .. H .
1_______________—__________—______________________________________
Were void spaces filled with tailings?
ScS_________________________________________________
Was the shipment properly covered?
-----Se t.------------tt=JetouUjt^-----
I 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) Byproduct Disposal
Manifest or BOL #: tO -0l "l $
Are additional settlement monitors required to be placed for this generator?
_____Mk._______________________________________________________
If required, where were settlement markers were placed?
.....na
Radiological receipt survey measurements:
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?(^es^r No
STRAIGHT BILL OF LADING
ORIGINAL-NOT NEGOTIABLE
Page 1 of__1_Greenfield Logistics. LLC Date 1/5/18
{Name of Carrier)(SCAC)
on CoUoot on Delivery shipment*, the letter* COD must appear before consignee’* name or as otherMtee
provided in Item 430, Sec 1.
To: Consignee Energy Fuels Resources (USA) Inc.
Street 6425 S. Hwv 191
City Blending . State UT Zip Code 84511
From: Shipper Crow Butte Resources. Inc.
Street:______86 Crow Butte Rd.__________
City Crawford State NE Zip Code 69339
24 hr. Emergency Contact Tel. No: (3081665-1393
Route.Vehicle:
Nmber
No. or units &
container type HM Basic Description
Proper Shipping Name, Hazard Class,
Identification Number (UN or NA), Packing Group, per 172.101,172.202,172.203
Total Quantity
(Weight Volume,
Gallons, etc.)
Weight
(Subject to
Correction)
RATE Charges
(For Carrier
Use Only)
1 rolloff XX UN2912, RADIOACTIVE MATERIAL, Low Specific Activity (LSA-1),
CLASS 7
30 cubic yards
Natural Uranium, Thorium-230 and Radium-226
PHYSICAL FORM: Solid byproduct material
CHEMICAL FORM: NATURAL URANIUM OXIDE U04-2H20
LABELS APPLIED: N/A per 49 CFR 172.203 (d)(4)
TRANSPORT INDEX: N/A per 49 CFR 172JQ3(d)(5)
ACTIVITY OF SHIPMENT: _8.47x107_Bq
EXCLUSIVE USE SHIPMENT
THIS VEHICLE IS ASSIGNED FOR EXCLUSIVE USE OF CAMECO
RESOURCES UNDER PROVISIONS OF 49 CFR 173.427 (a)(vi)
INCLUDING EXEMPTION FROM MARKING AND LABEUNG
REQUIREMENTS
DO NOT LOAD OTHER FREIGHT IN THIS VEHICLE, TRANSFER EN
ROUTE, OR BREAK SEAL
CBR SHIPMENT #: W-01-18 CB2
Note-{1} Where the rate te dependant on vahis, shippers are required to state specrficsUy on
wrltng the agreed or declared value of toe property, es foCom- The sgwod or dec la rod
vaue of toe propetty Is heresy epecillcefly Basted by toe stopper to be not
(2} Where the epplfcaU© tanfi provtsione specify a rm!tabor of the camer'a tfabtlty ebeent a
retoase or a value dectaredcn by the stopper and the shipper does not reteasa the carrier's
liabfity or dedare a value, toe earner’s Babiirty shell be Smitad to the extent provided by met
prreskm. See NMFl tern 172
(3) Commcdites nwulring specW or additional care or attention In handling or stow rig must bo so marited and padagedas to ensure safe trarmporteton. See Section 2(e) of Item 300,
B/Ss of Lading, Fre&it Bis, and Statements of Charges and Section 1 (a) of the Contract
terms and conditions tar a te of such artdes.
I hereby deefare that tne contents of this
consignment ere Mly end accuretefy described
store by toe proper ihtpplhfi name and ere
ctssAad, packaged, marked, and
tabefedf/ptacara, sno are In all respects in
proper oondrton for transport aocoTflng to
appTcabie irrtametonal end naborel
governmental regulations
ON BEHALF OF SHIPPER
ggnsiturB *
COD Amt S C.O.D FEE
PREPAID □
COLLECT D $
Sut** to Stctm 7 o( m ctttdtfent V Ms tffen»r* ft tt be
O0ntipirsh>9dsntoiUMtnsiteUcwr total
TT* csito <fe 1« nm ttttary of Cn yrttmi peynwlof and al ether t»««4 «fvg»CHARGES, i
FREIGHT CHARGESFRBOKF PREPAID CtecfclntfEl*nP>
l5555»ofcinKin«5 cReptwtMftbnai 0 aratobaripvteehadwd csfea
HEiG&VED. sub^icttD theoMseificsboReandtartfrsineffact on thedetaaf issueof ttosBiflaf Ladffig. the property described eboro In ^paront good order, ecroept es ncted (contents and candtian of contents of pa nn rked, con&fioed,and destined as indicated above which sad earner (the vrord carrier being understood throughout this contract as meamng any porson oroorpowtun m poaseoeion of too property under the conbacQ agrees to carry to Its usual place of delivery st said
destsnaticn, f on/Is route, otherwsetodelrvo,* to anothef Cameron toe route to said dostinaton. It rs mutuary agreed as to each carrier of si! or any of, oaid propert>- ever all or any portion of sold route to destination and as to «eh party at any frna
interested in all or any ea d property, tost every service to be performed hereunder fthas! be subject to all toe bil of lading term* end conditions in the gowning cJaeeificatton or the date o* the sftprnert
Shipper hereby oertiSes teat he is tenter with all the lading teTns and conditions in the governing cfas&.’flcation and the uid tatma and conditions are Serooy agreed to by the shipper and accepted tor hlmeefand hsctssignv
SHIPPER: Crow Butte Resources, Inc.CARRIER: Greenfield Logistics, LLC
per:PER ' W-- / >
DATE: ,DATE: 1 „ fjfc; '
Energy Fuels Resources (USA) Corp.
White Mesa Mill
6425 S. Highway 191
Blanding UT 84511
Vehicle ID:
Trailer ID:
Account ID:
Order ID:
Owner ID:
Material ID:
Destin. ID:
In:
Out
1001
11(e)2 NEB CROWE BUTTE
11(e)2 Mat 11(e)2 Material Receipt
BLANDING
Comments: TRL # TR4
Operator: 4 Charge by Weight
Signature:■ fl J\K ^ J_. J\
n
Transaction No.
53309
Date Time Scale
0
01/08/2018 08:58 1
** Manual Weight **
Gross: 51640 lb (K)
Tare: 43260 lb (K)
Net: 8380 lb
Generator of Byproduct material: Crow Butte
Controled Elevation used (Cell 3)
Area Elevation
5613.04
Transit Shot
Initial shot for trench 2.23
Top of trench 5610.04 5.23
Bottom of trench 5601.27 14
Initial shot used for material 2.23
Too of material in trench 5607.38 7.89
Top of cell 3 Liner 5608.5
Feet below liner1.12
it
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.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date:
Name of employee receiving the load: _______
Generator of the Byproduct Material: £?J f+c.
Shipper’s Manifest or Bill of Lading number: pj -O'Z- ~ 1 B
Was the State of Utah given notice to the receipt/disposal activities associated with this load? (Ye^ or
No
Who gave and when was the notification given?
. ----11 I 'Z.A 11 "7__________________________________________
Description of byproduct material disposal area/activities:
Toft- U.—jtffjj-Lu___f.L^tc
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?__
/i/A
/f/A
Which tailings cell was the material placed in? f .s L( 3*
Was the material placed on a tailings beach area of the cell or on an area of the cell that was underlain
by tailings sands?
LULi U
Was the material segregated from any Mill material or equipment disposed of in the cell?
-.................YCX.................................. ..............................................................—________. _
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: lle.(2) Byproduct Disposal
Manifest or BOL #: 7 a-) —O "2." tC
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? Ye
Documentation of approval M uT/‘fOO Ae»~< 7
Was the ISL material segregated from disposed Mill material and other
ISL material? Ye-',
Refer to plat(s) used to confirm. /? -3 IU. ? $rec.
** s ---------
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 3 £0,^ 0,a.^-'^4S &
Is the bottom of each disposal area at least 12 feet from the sides or
dikes of the tailings cell? Kr5
Refer to drawings used to confirm, / / 7 !^a.S &
Will the elevation of the material exceed the plane or grade of the
elevation of the uppermost flexible membrane liner of the cell?
AJo
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?
Axuh__A- skotcj- C-4__________________H.__4-t'^c-S Ot-r trt j
Were void spaces filled with tailings?
............. ........................
Was the shipment properly covered?
.________________________________________________________
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3.3 STANDARD OPERATING PROCEDURES j Page 13 of 13
Date: November 13, : Title: 1 le.(2) B>product Disposal
2014 !
Manifest or BOL #: JU2^
Are additional settlement monitors required to be placed for this generator?
yt/A_________________________________________________
If required, where were settlement markers were placed?
_yi/A______________________________
Radiological receipt survey measurements:
Breathing Zone:
1. Was a Breathing Zone Sample collected? Yes or
2. If yes, what were the results of the sampling?
Was a photograph taken during the unloading activities?eaor No
STRAIGHT BILL OF LADING
ORIGINAL-NOT NEGOTIABLE
Page 1 of 1 Greenfield Logistics. LLC Date 1/12/18
(Name of Carrier)(SCAC)
on Collect on Dottvery shipments, the tottere COD must appear before consignee's name or as otherwise
provided In Item 430, Sec. 1.From: Shipper Crow Butte Resources. Inc.
To: Consianee Enerav Fuels Resources fUSAI Inc.Street:86 Crow Butte Rd.
Street 6425 S. Hwv 191 City Crawford State NE Zip Code 69339
City Blandina State UT Zio Code 84511 24 hr. Emerqencv Contact Tel. No: [phone]
Route:Vehicle:
Nmber
' No. of units &
container type
HM Basic Description
Proper Shipping Name, Hazard Ctass,
Identification Number (UN or NA), Packing Group, per 172.101,172.202,172.203
Total Quantity
(Weight, Volume,
Gallons, etc.)
Weight
(Subject to
Conecfion)
RATE Charges
(For Carrier
Use Only)
Iroll off XX UN2912, RADIOACTIVE MATERIAL, Low Specific Activity (LSA-1),
CLASS 7
30 cubic yards
Natural Uranium, Thorium-230 and Radium-226 l
PHYSICAL FORM: Solid byproduct material
CHEMICAL FORM: NATURAL URANIUM OXIDE UO4-2H2O
LABELS APPLIED: N/A per 49 CFR 172.203 (d)(4)
TRANSPORT INDEX: N/A per 49 CFR 172.203(d)(5)
ACTIVITY OF SHIPMENT: _8.47x107_Bq
EXCLUSIVE USE SHIPMENT
THIS VEHICLE IS ASSIGNED FOR EXCLUSIVE USE OF CAMECO
RESOURCES UNDER PROVISIONS OF 49 CFR 173.427 (a)(vi)
INCLUDING EXEMPTION FROM MARKING AND LABELING
REQUIREMENTS
*
DO NOT LOAD OTHER FREIGHT IN THIS VEHICLE, TRANSFER EN
ROUTE, OR BREAK SEAL
CBR SHIPMENT #: W-02-18 CB R1
Note»(1) Where the rate t* dependant on value, shippers are required to state specifically on
writing the agreed or declared value c# the property, as fellows. The agreed or declared value of the property is hereby spectflcaify stated by the shipper to be not
1 hereby declare that the contents of Mi
consignment are fully and accurately deecribed
abore by the proper shipping name end are
classified, packaged, marked, and
COO Amt*C.O.D. P&
PREPAID □
COLLECT 0 S
(2) Where the applicable tariff provistons specify a Irritation of the carnet's liabilty absent a
release or a value dedarabon by the shipper and the ahlpper does not release the earner's
liability or declare a valtre, the carrtor'e Kabilfty stall be Imitad to the extent provided by such
proper condition for transport aocordtoQ to
applicsbto International raid national
SutfM M S«ta 7 tf m Mntom r tta b ■» bedtovered ts the coreigree eaheu noom on me wratoMr. Be
camiSMr dal dv l» iteoMro katenert-.TOTAL
CHARGES iprovwcns see NMrL ttem 1 rz.
(3) Commodbes requiring special or additional care or attention fn handEng or stoning must
ON BEHALF OF SHIPPER
in* estmt mu netmea —iw> cin» unvwtianrf Httt and *1 other taWU eterpH cup
be eo marked and packaged as to ensue aofe transportation See Section 2(e) of itam 3S0,
, Brls of Lading. Frei^ Brigand Statements of Charges and Section 1(a) of the Contract
terms and condrtkins tor a 1st of such aiticlea.-FREIGHT CHARGES
FREIGHT PREPAID OwehbtxVcharges
(aeraUre efAcS^nor)rto«bch«kMl oefed
Signature 1
RECEIVED, subject to the dasstflcatoni end tairffa In effect on the date of issue of this BU cf Lading, the property described above in apparent good order, except as noted (contents and condBon of contents at pacftages unknown), marked, consigned,
and destined as indicated above which said earner (the word cantor being understood throughout Ms contract as meaning any pereon or corporation in possession of the property under the contract) agrees to carry to its usual place of ddrvey at said
dcstinatron, If on its route, otherwise to deliver to another cantor on the route to said destination It b mutually agreed as to each canter of aU or any of, said property ewer all or any portion of saU route to destination and » to each party at any time
interested in ell or any said property, that every eervice to bo perfremed hereunder shall be subject to eH the bill of fading terms and conditions in the governing ciaosifkaSon on the date of the shipment
Shipper hereby oerttftos that he Is tamlBar with all the lading terms and conditions in the governing ciassffication and the said terms and conditions are hereby agreed to by the shipper and accepted tor hlrrsatt and his assigns.
SHIPPER: Crow Butte Resources, Inc.CARRIER: Greenfield Logistics, LLC
PER:PER: -77 l&'J/yZ ^
_________________________________
“DATE t (-/?'/£
l- Is-S'
Energy Fuels Resources (USA) Corp.
White Mesa Mill
6425 S. Highway 191
Blanding UT 84511
** Reprinted by 4 at 01/15/18 14:09:49 **
In:
Out
Vehicle ID:
Trailer ID:
Account ID:
Order ID:
Owner ID:
Material ID:
Destin. ID:
1001
11(e)2 NEB CROWE BUTTE
11(e)2 Mat 11(e)2 Material Receipt
BLANDING
Comments: TRL # CB1
Operator: 4
Signature:
Charge by Weight
Transaction No.
53318
Date Time Scale
01/15/2018 13:18 1
01/15/2018 14:09 1
Gross: 55100 lb (M)
Tare: 42900 lb
Net: 12200 lb
LO -oz
Generator of Byproduct material:Crow Butte
Controled Elevation used (Cell 3)
Area Elevation
5613.04
Transit Shot
Initial shot for trench 2.23
Top of trench 5610.04 5.23
Bottom of trench 5601.27 14
Initial shot used for material 2.23
Too of material in trench 5607.38 7.89
Top of cell 3 Liner 5608.5
Feet below liner 1.12
-5lo f +'
LO-o?--1*