DRC-2012-002112 - 0901a06880318da8

State of Utah
GARYR HERBERT
Governor
GREG BELL
Lieutenant Governor
department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADL\TION CONTROL
Rusty Lundberg
Director
C-201^n)02112
October 22, 2012
Jo Ann S Tischler, Director, Compliance
Energy Fuels Resources (USA) Inc
225 Union Boulevard, Suite 600
Lakewood, CO 80228
Subject Radioactive Matenal License No UTl900479
2012 Radiation Protection Inspection, Module RADMOD-SSS-01
Dear Ms Tischler
This letter refers to the inspection conducted at the Energy Fuels Resources (USA) facility m Blandmg, UT
on September 19 and 20, 2012 by a representative of the Division of Radiation Control (DRC), Utah
Department of Environmental Quality
The cooperation and hospitality afforded the DRC inspector by the personnel at the Blandmg uranium mill
dunng the inspection are appreciated
The inspection was an examination of your facilities as they relate to compliance with the Utah Radiation
Control Rules and the conditions of the Radioactive Matenals License Number UT 1900479 The
inspection consisted of personnel interviews, document reviews and direct observations by the inspector
The activities and practices reviewed dunng the inspection with respect to radiological surveys, shipping
conveyance and contamer releases, shipping papers, and radioactive calibration sources were found to be in
compliance with relevant requirements, however, there are several recommendations that may strengthen
the mill operations The recommendations are included m the enclosed Inspection Report
If you have any question, please contact Boyd Imai at [phone]
Sincerely,
Rusty Lundberg, Director
RL/BMI bl
Enclosure
cc/enc David Turk, Energy Fuels Resources (USA), Blandmg, UT
Shiya Wang, CDPHE, Denver, CO
195 North 1950 West • Salt Lake City, UT
Mailing Address P O Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax (801) 533^097 'TDD [phone]
www deq Utah gov
Pnnted on 100% recycled paper
INSPECTION REPORT
Inspection Module RADMOD-SSS-01 Surveys/Shipping Papers/Sources
Radioactive Matenal License No UT 1900479
Inspection Location Energy Fuels Resources (USA), Blandmg, UT
Inspection Date(s) September 19,2012 through September 20, 2012
Inspector Boyd Imai, Utah Division of Radiation Control (DRC)
Accompanied By Shiya Wang, Colorado Department of Public Health and Environment
(CDPHE)
Personnel Contacted Daniel HiUsten, Tanner Holladay, Ronnie Nieves, Justin Perkins, Chance
Singer, Terry Slade, David Turk
Inspection Summarv
The inspection was opened on September 19, 2012 v^ith a meeting among D HiUsten, R Nieves,
D Turk, S Wang and the inspector. (S. Wang had requested to accompany and observe a DRC
compliance inspection ) Inspection Objectives were stated which included.
1 Observe release surveys and preparation of product containers, equipment, conveyances
(general releases and DOT compliance)
2 Assess completion of shipping papers and supporting documentation
3 Inventory Sources
4 Review release and facility surveys
5 Time permitting, look at a penmeter air sampling station
Areas inspected included.
• Ore Truck Releases
• Product Drum Preparation
• Product Drum Shipping Papers
• Contamer Releases
• Source Inventory
• Penmeter Air Sampling Stations (informational only)
The inspector held a closeout meeting on September 20, 2012 with D Hillsten, R Nieves, T
Slade, and D Turk of Energy Fuels Resources and S Wang of the State of Colorado to review
the inspection activities, observations, and conclusions
Findings
No citable violations or deficiencies were observed dunng the inspection
Two minor items were addressed dunng the inspection 1) an operational procedure needs
Page 1 of 6
F \wp\Inspections\Energy Fuel, Blandmg, UTMnspectionReportRevO doc
updating and 2) a release survey form needs to be modified to document a 1-meter exposure rate
reading on product drums.
Inspection Items
Ore Truck Releases
Releasing empty ore trucks from the facility is a vexing regulatory problem. Compliance with
the regulations is dependent upon the approach the facility chooses to take Procedures indicate
that end dump trailers are released either for restncted or unrestncted use Two empty ore trucks
were observed exiting the facility The extenors of the conveyances were decontaminated and
radiological surveys were taken of the extenors Surveys of the intenors were not observed The
conveyances were marked with the wordings "For Radioactive Matenal (Use) Only" and
"Radioactive LSA" suggesting that the vehicles were being released under the provisions of 49
CFR 173 443(d) However, no shipping papers or documents were sent with the dnvers that
would indicate that the vehicles were transporting a Class 7 radioactive matenal It was not clear
whether the vehicles were released under restncted or unrestncted conditions If unrestncted, the
trailers should not be marked "Radioactive LSA "
Procedure titled End Dump Trailer Acceptance, Handling & Release, No. PBL-9 needs review
and updating, e g references to UN2910 with respect to "EMPTY" packages needs to be changed
to UN2908 and attached regulations are outdated
For restncted release, the Licensee must comply with all applicable requirements and not just
selectively choose provisions that provide relief from certain restnctions, e g applying conditions
found m 49 CFR 173.443(d) does not absolve the shipper from compliance with all other
hazardous matenal shipping requirements such as shipping papers, markings, labels, etc If the
Licensee makes the determination that the released conveyance is not a Class 7 radioactive
matenal transfer then 49 CFR 173 443(d) provisions cannot be applied and other release cntena
must be applied, i e more restnctive contamination release levels
Product Drum Preparation
The product, UaOg "yellow cake" is packed in 55-gallon metal drums Drums used are certified
Type A containers suitable for the shipment of Low Specific Activity (LSA-1) radioactive
matenals
A radiological survey was performed on each drum A contact dose rate survey and a
contamination survey were performed on each drum The contamination survey was done with a
direct frisk on each drum and a sample per load of drums had smear samples taken and analyzed
for venfication purposes, all documented on the "Drum Contamination Survey" form
Radioactive Yellow-H labels were not yet applied to the drums since it was only a partial load of
drums that were being prepared at the time ofthe inspection. Labels and markings were to be
applied later m the preparation process
Deficiencies
It was noted that a 1-meter dose rate was not measured dunng the drum preparation process
This measurement is necessary m determining which type of radioactive matenal label is
Page 2 of 6
F \vvp\Inspections\Energy Fuel, Blandmg, UTMnspectionReportRevO doc
appropnate, i e Radioactive White-I, Radioactive Yellow-E, or Radioactive Yellow-in as per 49
CFR 172 403(b) and (c) and 173 403, Transport Index Dunng the closeout meeting the
Licensee indicated that the measurement is taken before the drums are loaded onto the transport
vehicle
Product Drum Shipping Papers
From the previous inspection deficiencies were noted in the shipping paper information A
sample of the shipping papers of recent shipments was examined for completeness It was
venfied that the deficiencies identified in the pnor inspection were corrected The Licensee uses
a Straight Bill of Lading as the shipping papers and m those reviewed no discrepancies were
identified
However, there was a document associated with the Straight Bill of Lading that did not precisely
conespond with the information provided on the shipping paper Specifically, the document
titled "Shipping Paper" did not identify the category of label applied to each package in the
shipment as required in 49 CFR 172 203(d)(4) and it did not identify the chemical form as
specified m 49 CFR 172 203(d)(2) Further, the proper shipping name did not include the
"(LSA-1)" designation Apparently, this information is maintained on a spreadsheet for mtemal
purposes and is not utilized as the shipping paper prescnbed in 49 CFR 172 200 through 204
The dnver of the transport vehicle is provided with a "Dnver Routing Instruction" and "Camers'
Instructions."
Deficiencies
The instructions provided to the dnvers should include the information specified in 49 CFR
173 403 Exclusive Use and required by 173 427(a)(6)(iv)
Container Releases
Three intermodal containers GFLU001035, GFLUOOl 180, and GFLUOOl 1801 were qualified
for unrestncted release Release surveys of these containers are documented on "Energy Fuels
Resources (USA) Inc , Equipment Survey for Unrestncted Release" forms
No containers were bemg released as "EMPTY" UN2908 dunng the inspection
Deficiencies
None
Source Inventory
The Source Inventory list was checked against the sources in storage The Licensee indicated
that only two of the sources on the list are used to check detection instruments, the remainder are
not utilized for any purposes
The Licensee provided documentation for source leak testing performed by Ronan Engineenng
Co
Deficiencies
The Source Inventory list did not identify four check sources m storage* Bi-210 (0 053 |LICI),
Page 3 of 6
F \wp\Inspections\Energy Fuel, Blandmg, UTMnspectionReportRevO doc
Cl-36 (0 0182 nCi), Pm-147 (0 096 jiCi), and C-14 (0 165 \iCi) And there was one missmg Th-
230 source no 5995-09 (on the list but not m storage) None of these sources are used
Perimeter Air Sampling Stations
As a courtesy, the Licensee escorted the inspector and S Wang to an air sampling site to see how
a station is configured and assembled Samples are collected for particulate monitonng, radon
monitonng, and gamma dose at each of five sampling locations ;
Closeout Meeting
The inspector held a closeout meeting with D Hillsten, R Nieves, T Slade, and D Turk of
Energy Fuels Resources (USA) and S Wang of CDPHE on September 20,2012 The
observations descnbed above were summanzed dunng the meeting
Recommendations to the Licensee
Operating Procedures
It IS strongly recommended that operating procedures No PBL-2, Intermodal Container
Acceptance, Handling & Release and No PBL-9, End Dump Trailer Acceptance, Handling &
Release be reviewed and updated There have been changes to the U S Department of
Transportation (DOT) hazardous matenal transportation regulations since the procedures were
first implemented and those changes need to be reflected in the procedures, including the
attached DOT excerpts
Of particular importance, in this regard, is the change to the contamination limits table found m
49 CFR 173 443 (Table 11 m the old regulations. Table 9 m the current regulations) Outwardly
it appears that the limits were increased by a factor of 10 However, this is not the case
Essentially, the limits are the same but a distinction is made between smearable/wipeable
contamination (Table 11) and total removable contamination (Table 9) In Table 11a wiping
efficiency (0.10) is factored in the table values, whereas, the shipper must adjust the survey
results to convert smearable/wipeable contamination to total removable contamination before
companng numbers with the Table 9 limits The shipper may use actual wipe efficiency or may
use an assumed efficiency of 0 10
It IS a suggested that the procedural requirements for releasing conveyances and packagmgs as
"EMPTY" be revised to conespond with the requirements specified in 49 CFR 173 428
including contamination and dose rate limits The UN number for empty packagmgs changed
from UN 2910 to UN 2908 Although not prohibited, the notice "This package conforms to the
conditions and limitations specified m 49 CFR 173 428 for radioactive matenal, excepted
package-empty packaging, UN 2908" is no longer required to accompany the shipment (formerly
specified in 49 CFR 173 422, last appeanng in the 2003 edition) Although this notice is
cunently applied to the outgoing empty containers and contains the four digit UN identification
number for empty packagmgs, for bulk containers there is a size requirement for the UN 2908
marking (49 CFR 172 302 and 173 332) which the number on the notice does not conform
As was discussed in the closeout meeting, caution is encouraged when releasing end dump trucks
and other conveyances that transported the uranium ores, especially with "restncted" releases
Page 4 of 6
F \wp\Inspections\Energy Fuel, Blandmg, UTMnspectionReportRevO doc
Release cntena may depend upon the classification of the ore when it amved at the Licensee's
facility A DOT regulated Class 7 radioactive matenal shipment upon amval may dictate what
levels of radiological contamination and exposure rates are permissible for release. The Licensee
may have a number of options but must apply all the cntena that correspond to the option
selected For example, a shipper may apply the provisions found in 49 CFR 173 443(d) but
cannot ignore the other radioactive matenal. Class 7 requirements found m 49 CFR Subchapter
C Unfortunately, when the DOT changed the defimtion of "radioactive matenal" from a
concentration of 2000 pCi/g of any radionuclide to radionuclide specific concentrations and
consignment activity limits conesponding changes were not made to accommodate special
provisions such as 49 CFR 173 443(d). Shippers are left to figure it out for themselves Full
compliance is a difficult task that takes carefbl assessment and scrutiny The Licensee indicated
that the "lawyers" might need to get involved in this matter
The Licensee should use the term "exclusive use" cautiously The t6rm has several meamngs and
could impact compliance issues if not used in the proper context, especially if it is in reference to
the provisions m 49 CFR 173 443(d).
It is recommended that, because the regulations have changed since the procedures were first
implemented, a careful review of the current regulations be performed and that the procedures be
revised to capture all applicable options that the Licensee may choose to take m releasing
conveyances It should be kept m mind that when doing the review there are multiple options for
a "restncted release" each with separate and distinct radiological release and hazardous matenal
shipping cntena
Shipping Papers
It appears that the shipping paper deficiencies identified in the previous inspection have been
corrected As stated above, the Licensee's "Shipping Paper" information did not accurately
reflect the information provided on the Bill of Lading. Fortunately, the official document, the
Bill of Lading, contained the necessary information. But to avoid compliance problems the
documents should contam the same information It is recommended that all documents
associated with a shipment of the product matenal be consistent with one another.
Additionally, 49 CFR 173.427(a)(6)(iv) states
"Specific instructions for maintenance of exclusive use shipment controls shall be
provided by the offeror to the earner Such instructions must be included with the
shipping paper mformation"
The Licensee does provide the earner with "Dnver Routing Instruction" and "Camers'
Instructions", however, it is recommended that the information specified in 49 CFR 173 403,
Exclusive Use be included m those dnver's instructions That being
"The consignor and the earner must ensure that any loading or unloading is performed by
personnel having radiological training and resources appropnate for safe handling ofthe
consignment. The consignor must provide to the initial earner specific wntten
instructions for maintenance of exclusive use shipment controls, including the vehicle
survey requirement of §173 443(c) as apphcable, and include these instructions with the
shipping paper information provided to the earner by the consignor "
Page 5 of 6 s
F \wp\Inspections\Energy Fuel, Blandmg, UTMnspectionReportRevO doc
Radiological Surveys
When Class 7 radioactive matenals are shipped and the packages require Class 7 labels, the
highest exposure rate measurement taken one meter from the surface of each package is required
to determme which Radioactive Labels (White-I, Yellow-II or Yellow-IE) are to be applied
The Licensee mdicated that the measurements are taken but the results were not documented
The Licensee indicated that a line item could be added to the survey form indicatmg the
measured 1-meter exposure rate It is recommended that this addition to the form be made and
that the survey readings be documented there
It is recogmzed that staffing is a challenge for the Licensee with respect to Radiation
Techmcians The health physics management is encouraged to be vigilant in recruiting quality
techmcians, m providing trainmg (initial, on-the-job, and continual), in mentonng, and in taking
every opportumty to remforce radiological release limits and survey techmques
The bnef observations of the staff conducting radiological surveys indicated that the radiation
techmcians performed the basic radiological survey functions adequately and mamtamed the
necessary documentation
Routme facility contamination surveys are performed weekly It is recommended that this
practice continue
Source Inventory
Because only two ofthe sources on the inventory list are actually used for checking survey
instruments it is recommended that all extraneous sources be examined for then exempt status
and eliminated from the source inventory and disposed m an appropnate manner
Portable gauge sources are regulated imder a separate license and should continue to be
controlled accordingly. The management of portable gauges will be evaluated when the Licensee
is inspected for compliance with the conditions of the portable gauge license.
Recommendations for the Next Inspection
• Assess revisions to the operating procedures
• Venfy the container survey form includes 1 -meter exposure rate measurements
• Evaluate consistency in the product shipment file
• Evaluate dnver instructions for exclusive use controls
Recommendation to the DRC Director
Although there were areas where process improvements could be made, nothing observed dunng
the inspection appeared to directly violate license or regulatory requirements It is therefore
recommended that no enforcement action be taken at this time
Prepared By BoydM Imai (dy^l^U^ October 19,2012
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Inspection Keport
ana
Inspection Moilule
MDMoa-sssoi Checklist
INSPECTION REPORT
Inspection Module. RADMOD-SSS-01 • Surveys/Shipping Papers/Sources
Radioactive Matenal License No UT 1900479
Inspection Location: Energy Fuels Resources (USA), Blandmg, UT
Inspection Date(s) September 19,2012 through September 20,2012
Inspector Boyd Imai, Utah Division of Radiation Control (DRC)
Accompamed By Shiya Wang, Colorado Department of Public Health and Environment
(CDPHE)
Personnel Contacted: Daniel Hillsten, Tanner Holladay, Ronme Nieves, Justin Perkins, Chance
Singer, Terry Slade, David Turk
Inspection Summarv
The inspection was opened on September 19,2012 with a meeting among D Hillsten, R Nieves,
D Turk, S Wang and the inspector (S Wang had requested to accompany and observe a DRC
compliance inspection ) Inspection Objectives were stated which included
1 Observe release surveys and preparation of product containers, equipment, conveyances
(general releases and DOT compliance)
2. Assess completion of shipping papers and supporting documentation
3 Inventory Sources
4 Review release and facility surveys
5 Time permitting, look at a penmeter air sampling station
Areas inspected included
• Ore Truck Releases
• Product Drum Preparation
• Product Drum Shipping Papers
• Container Releases
• Source Inventory
• Penmeter Air Sampling Stations (informational only)
The inspector held a closeout meeting on September 20, 2012 with D Hillsten, R Nieves, T
Slade, and D Turk of Energy Fuels Resources and S Wang ofthe State of Colorado to review
the inspection activities, observations, and conclusions
Findings
No citable violations or deficiencies were observed dunng the inspection
Two minor items were addressed dunng the inspection 1) an operational procedure needs
Page 1 of 6
F \v^Mnspections\Energy Fuel, Blandmg, UTMnspectionReportRevO doc
updating and 2) a release survey form needs to be modified to document a 1-meter exposure rate
reading on product drums
Inspection Items
Ore Truck Releases
Releasing empty ore tmcks from the facility is a vexing regulatory problem Compliance with
the regulations is dependent upon the approach the facility chooses to take Procedures indicate
that end dump trailers are released either for restncted or imrestncted use Two empty ore trucks
were observed exiting the facility. The extenors of the conveyances were decontaminated and
radiological surveys were taken of the extenors. Surveys of the intenors were not observed The
conveyances were marked with the wordings "For Radioactive Matenal (Use) Only" and
"Radioactive LSA" suggesting that the vehicles were being released under the provisions of 49
CFR 173 443(d) However, no shipping papers or documents were sent with the dnvers that
would indicate that the vehicles were transporting a Class 7 radioactive matenal It was not clear
whether the vehicles were released under restncted or unrestncted conditions If unrestncted, the
trailers should not be marked "Radioactive LSA "
Procedure titled End Dump Trailer Acceptance, Handling & Release, No PBL-9 needs review
and updating, e g references to UN2910 with respect to "EMPTY" packages needs to be changed
to UN2908 and attached regulations are outdated
For restncted release, the Licensee must comply with all applicable requirements and not just
selectively choose provisions that provide relief from certain restnctions, e g applying conditions
found in 49 CFR 173.443(d) does not absolve the shipper from compliance with all other
hazardous matenal shipping requirements such as shipping papers, markings, labels, etc. If the
Licensee makes the determination that the released conveyance is not a Class 7 radioactive
matenal transfer then 49 CFR 173 443(d) provisions cannot be applied and other release cntena
must be applied, i e. more restnctive contamination release levels.
Product Drum Preparation
The product, UsOg "yellow cake" is packed m 55-gallon metal drums Drums used are certified
Type A containers suitable for the shipment of Low Specific Activity (LSA-1) radioactive
matenals
A radiological survey was performed on each drum A contact dose rate survey and a
contamination survey were performed on each drum The contamination survey was done with-a
direct fiisk on each drum and a sample per load of drums had smear samples taken and analyzed
for venfication purposes, all documented on the "Drum Contamination Survey" form
Radioactive Yellow-H labels were not yet applied to the drums since it was only a partial load of
drums that were being prepared at the time of the inspection Labels and markings were to be
applied later m the preparation process
Deficiencies
It was noted that a 1-meter dose rate was not measured dunng the drum preparation process
This measurement is necessary m determining which type of radioactive matenal label is
Page 2 of 6
F \wp\Inspections\Energy Fuel, Blandmg, UTMnspectionReportRevO doc
appropnate, i e Radioactive White-I, Radioactive Yellow-H, or Radioactive Yellow-IH as per 49
CFR 172 403(b) and (c) and 173 403, Transport Index Dunng the closeout meeting the
Licensee indicated that the measurement is taken before the drums are loaded onto the transport
vehicle
Product Drum Shipping Papers
From the previous inspection deficiencies were noted in the shipping paper information A
sample of the shipping papers of recent shipments was examined for completeness It was
venfied that the deficiencies identified m the pnor inspection were corrected The Licensee uses
a Straight Bill of Lading as the shipping papers and m those reviewed no discrepancies were
identified
However, there was a document associated with the Straight Bill of Lading that did not precisely
conespond with the information provided on the shipping paper Specifically, the document
titled "Shipping Paper" did not identify the category of label applied to each package in the
shipment as required in 49 CFR 172 203(d)(4) and it did not identify the chemical form as
specified in 49 CFR 172 203(d)(2). Further, the proper shipping name did not include the
"(LSA-1)" designation Apparently, this information is maintained on a spreadsheet for intemal
purposes and is not utilized as the shipping paper prescnbed in 49 CFR 172 200 through 204
The dnver of the transport vehicle is provided with a "Dnver Routing Instruction" and "Camers'
Instructions "
Deficiencies
The instructions provided to the dnvers should include the information specified in 49 CFR
173 403 Exclusive Use and required by 173 427(a)(6)(iv).
Container Releases
Three intermodal containers GFLU001035, GFLUOOl 180, and GFLUOOl 1801 were qualified
for unrestncted release Release surveys of these containers are documented on "Energy Fuels
Resources (USA) Inc , Equipment Survey for Unrestncted Release" forms
No containers were being released as "EMPTY" UN2908 dunng the inspection
Deficiencies
None
Source Inventory
The Source Inventory list was checked against the sources in storage The Licensee indicated
that only two of the sources on the list are used to check detection instruments, the remainder are
not utilized for any purposes
The Licensee provided documentation for source leak testing performed by Ronan Engineenng
Co.
Deficiencies
The Source Inventory list did not identify four check sources in storage Bi-210 (0 053 |iCi),
Page 3 of 6 '
F \wp\Inspections\Energy Fuel, Blandmg, UTMnspectionReportRevO doc
Cl-36 (0 0182 ^Ci), Pm-147 (0 096 ^iCi) , and C-14 (0 165 ^iCi) And there was one missing Th-
230 source no 5995-09 (on the list but not m storage) None of these sources are used
Perimeter Air Sampling Stations
As a courtesy, the Licensee escorted the inspector and S Wang to an air sampling site to see how
a station is configured and assembled Samples are collected for particulate monitonng, radon
momtonng, and gamma dose at each of five sampling locations
Closeout Meeting
The inspector held a closeout meeting with D Hillsten, R Nieves, T Slade, and D Turk of
Energy Fuels Resources (USA) and S. Wang of CDPHE on September 20,2012 The
observations descnbed above were summarized dunng the meeting
Recommendations to the Licensee
Operating Procedures
It IS strongly recommended that operating procedures No PBL-2, Intermodal Container
Acceptance, Handling & Release and No. PBL-9, End Dump Trailer Acceptance, Handling &
Release be reviewed and updated There have been changes to the U S Department of
Transportation (DOT) hazardous matenal transportation regulations since the procedures were
first implemented and those changes need to be reflected m the procedures, including the
attached DOT excerpts
\
Of particular importance, in this regard, is the change to the contamination limits table found in
49 CFR 173 443 (Table 11 m the old regulations. Table 9 in the cunent regulations) Outwardly
it appears that the limits were increased by a factor of 10 However, this is not the case
Essentially, the limits are the same but a distinction is made between smearable/wipeable
contamination (Table 11) and total removable contamination (Table 9) In Table 11a wiping
efficiency (0 10) is factored in the table values, whereas, the shipper must adjust the survey
results to convert smearable/wipeable contamination to total removable contamination before
companng numbers with the Table 9 limits The shipper may use actual wipe efficiency or may
use an assumed efficiency of 0 10
It IS a suggested that the procedural requirements for releasing conveyances and packagmgs as
"EMPTY" be revised to conespond with the requirements specified in 49 CFR 173 428
including contamination and dose rate limits The UN number for empty packagmgs changed
from UN 2910 to UN 2908 Although not prohibited, the notice "This package conforms to the
conditions and limitations specified in 49 CFR 173 428 for radioactive matenal, excepted
package-empty packaging, UN 2908" is no longer required to accompany the shipment (formerly
specified m 49 CFR 173 422, last appeanng in the 2003 edition) Although this notice is
cunently applied to the outgoing empty containers and contains the four digit UN identification
number for empty packagmgs, for bulk containers there is a size requirement for the UN 2908
marking (49 CFR 172 302 and 173 332) which the number on the notice does not conform
As was discussed m the closeout meeting, caution is encouraged when releasing end dump trucks
and other conveyances that transported the uramum ores, especially with "restncted" releases.
Page 4 of 6
F \v\T)Mnspections\Energy Fuel, Blandmg, UTMnspectionReportRevO doc
Release cntena may depend upon the classification of the ore when it amved at the Licensee's
facility A DOT regulated Class 7 radioactive matenal shipment upon amval may dictate what
levels of radiological contamination and exposure rates are permissible for release The Licensee
may have a number of options but must apply all the cntena that conespond to the option
selected. For example, a shipper may apply the provisions found in 49 CFR 173 443(d) but
cannot ignore the other radioactive matenal. Class 7 requirements found m 49 CFR Subchapter
C. Unfortunately, when the DOT changed the defimtion of "radioactive matenal" from a
concentration of2000 pCi/g of any radionuclide to radionuclide specific concentrations and
consignment activity limits conesponding changes were not made to accommodate special
provisions such as 49 CFR 173 443(d) Shippers are left to figure it out for themselves Full
compliance is a difficult task that takes careful assessment and scrutiny. The Licensee indicated
that the "lawyers" might need to get involved in this matter.
The Licensee should use the term "exclusive use" cautiously The term has several meamngs and
could impact compliance issues if not used in the proper context, especially if it is in reference to
the provisions m 49 CFR 173 443(d)
It is recommended that, because the regulations have changed since the procedures were first
implemented, a careful review of the cunent regulations be performed and that the procedures be
revised to capture all applicable options that the Licensee may choose to take in releasing
conveyances It should be kept in mind that when doing the review there are multiple options for
a "restncted release" each with separate and distinct radiological release and hazardous matenal
shipping cntena
Shipping Papers
It appears that the shipping paper deficiencies identified m the previous inspection have been
conected As stated above, the Licensee's "Shipping Paper" information did not accurately
reflect the information provided on the Bill of Lading Fortunately, the official document, the
Bill of Lading, contained the necessary information But to avoid compliance problems the
documents should contain the same information It is recommended that all documents
associated with a shipment of the product matenal be consistent with one another
Additionally, 49 CFR 173 427(a)(6)(iv) states.
"Specific instructions for maintenance of exclusive use shipment controls shall be
provided by the offeror to the earner Such instructions must be included with the
shipping paper information"
The Licensee does provide the camer with "Dnver Routing Instruction" and "Camers'
Instructions"; however, it is recommended that the information specified in 49 CFR 173 403,
Exclusive Use be included in those dnver's instructions That being.
"The consignor and the camer must ensure that any loading or unloading is performed by
personnel having radiological training and resources appropnate for safe handling ofthe
consignment The consignor must provide to the initial camer specific wntten
instructions for maintenance of exclusive use shipment controls, including the vehicle
survey requirement of §173 443(c) as applicable, and include these instructions with the
shipping paper information provided to the camer by the consignor "
' Page 5 of 6
F \wpMnspections\Energy Fuel, Blandmg, UTMnspectionReportRevO doc
Radiological Surveys
When Class 7 radioactive matenals are shipped and the packages require Class 7 labels, the
highest exposure rate measurement taken one meter from the surface of each package is required
to determine which Radioactive Labels (White-I, Yellow-H or Yellow-IH) are to be applied
The Licensee indicated that the measurements are taken but the results were not documented
The Licensee indicated that a line item could be added to the survey form indicating the
measured 1-meter exposure rate It is recommended that this addition to the form be made and
that the survey readings be documented there
It IS recognized that staffing is a challenge for the Licensee with respect to Radiation
Techmcians The healjh physics management is encouraged to be vigilant in recruiting quality
techmcians, in providing training (initial, on-the-job, and continual), in mentonng, and m taking
every opportunity to reinforce radiological release limits and survey techniques
The bnef observations of the staff conducting radiological surveys indicated that the radiation
techmcians performed the basic radiological survey functions adequately and maintained the
necessary documentation
Routine facility contamination surveys are performed weekly It is recommended that this
practice continue
Source Inventory
Because only two of the sources on the inventory list are actually used for checking survey
instruments it is recommended that all extraneous sources be examined for their exempt status
and eliminated from the source inventory and disposed in an appropnate manner
Portable gauge sources are regulated under a separate license and should continue to be
controlled accordingly The management of portable gauges will be evaluated when the Licensee
IS inspected for compliance with the conditions of the portable gauge license
Recommendations for the Next Inspection
• Assess revisions to the operating procedures
• Venfy the container survey form includes 1-meter exposure rate measurements
• Evaluate consistency in the product shipment file
• Evaluate dnver instructions for exclusive use controls
Recommendation to the DRC Director
Although there were areas where process improvements could be made, nothing observed dunng
the inspection appeared to directly violate license or regulatory requirements It is therefore
recommended that no enforcement action be taken at this time
Prepared By BoydM Imai October 19,2012
Page 6 of 6
F \wpMnspections\Energy Fuel, Blandmg, UTMnspectionReportRevO doc
UTAH DIVISION OF RADIATION CONTROL
RADIATION PROTECTION INSPECTION MODULE RADMOD-SSS-01
SURVEYS/SHIPPING PAPERS/SOURCES
DENISON MINES - WHITE MESA URANIUM MILL
RADIOACTIVE MATERIAL LICENSE UTl900479
References Radioactive Matenal License UTl900479, License Renewal Application dated February 28,
2007, Radiation Protection Manual, Section 5,10CFR20, NRC Regulatory Guide 8 30, NRC Regulatory
Guide 8.31, Utah Admimstrative Code R313-15
DATE ?//?//2^
OPENING MEETING
MEETING MEMBERS
,,:;.^Tei^)K0i^ ^EmailAdcffim r-.''^
Bi^ra,w ^t}c\^
U \rad\COMMON\Uranium millsM le(2)UTl 900479 EnergyFuels Resources (Denison Mines) - White Mesa UMillMIP Inspection modules\2012Mnspection
ModulesMiADMOD-SSS-02 rev 1 doc
JV^^\>t<-nr- DISCUSSION
4p {e<2i-g XS^ <ft>^ Cu^V's^vcijM.
(Qj^ysjuc^rwsg ^^•^ysg/y-v^ ^tAea-^g SAjov-v>gA4 3'^ ^
SITE STAFF COMMENTS ^ JrLjk^ /^f^.,^
U \rad\COMMON\Uranium millsM le(2)UTl900479 EnergyFuels Resources (Denison Mines) - White Mesa UMill\HP Inspection modules\2012Mnspection
ModulesMlADMOD-SSS-02 rev 1 doc
DATE ^/^//
CLOSEOUT MEETING
MEETDSTG MEMBERS
NAME COMPANY CONTACT ESfFORMATION
r I
U \rad\COMMON\Uranium millsM le(2)UT1900479 EnergyFuels Resources (Denison Mines) - White Mesa UMillNHP Inspection modules\2012Mnspection
Modules\RADMOD-SSS-02 rev 1 doc
RELEASE SURVEYS for Product Drums, Intermodals and Ore Trucks
Radiation Protection Manual Section 2 6 Equipment Release Surveys and 2 7 Product Shipment Surveys
(Appendix E 2007 license renewal)
1. Observe the RSO or designee perform a release survey on the filled product drums Descnbe what
they did
Comments-
2. Observe the RSO or designee perform an unrestricted release survey on the Intermodals. Descnbe
what they did
Comments* .
-L ^ \ r
d T\ M Bo \
3 Observe the RSO or designee perform a DOT Empty release survey on the Intermodals Descnbe
what they did
Comments. r
4 Observe the RSO or designee perform a release survey on an Ore Truck Descnbe what they did
Comments i>'t " (^-s^J^v^cJ^^'^ I^^VY^-Z^VS- U-S^ <3>uJ-t^ ' ':CV--a<--oi_ S^-^^-r
5. Perform an independent Survey on each ofthe above items and descnbe how you did your survey
and document the results
Comments. (Product Drums)
Comments (Unrestncted Intermodal)
S<-CA-VAgv^3
U \rad\COMMON\Uranium millsM le(2)UTl900479 EnergyFuels Resources (Denison Mines) - White Mesa UMill\HP Inspection modules\2012Mnspection
Modules\RADMOD-SSS-02 rev I doc
Comments. (DOT Empty Intermodal)
Comments: (Ore Truck) ^ . r
6. Was a survey (dose rate measurement) taken of the transport vehicle mtenor surfaces'^
Comments: ^
7. How did the RSO or designee document their surveys'^
Comments*
8. Review the release surveys for the past year.
Comments*
Q^-^i^ju^y-JiJi ^£^v^ (fr^ /to^ ca^^-t-%>utAour3' -ft^'^^A'^ ^jj^g^^v^s- V^e-a,A-v^
SHIPPING PAPERS. LABELING AND PACKAGING "T^^/LJ S^fg.Ae_ DO"r3
9. Observe an Ore Tmck(s) Descnbe how they are labeled/placard. (49 CFR 172)
Comments r-*:^^^^ ,V-ir- ^ ^
U \rad\COMMON\Uranium millsM le(2)UTl 900479 EnergyFuels Resources (Denison Miries) - White Mesa UMillMlP Inspection modules\2012Mnspection
ModulesM^DMOD-SSS-02 rev 1 doc
10 Observe Yellowcake drums how are they labeled (49 CFR 172)
Comments ^
^uQ^ s-A^.^i/rKiLA^ Kjcj^ -a^u-g^iis- UU iue.J.
11. Observe Yellowcake shipment truck how is it placard. (49 CFR 172)
Comments. C ' f) -
2^ice_
Date on shippmg paper
Descnption
(UN#, Proper shipping
name, hazard class)
Physical and/or
Chemical form
Radionuclide
Activity
Class
Emergency phone #
Exclusive shipment
(Y/N) V
Certified
Comments:
^^r-<g|^c<.A.>v^ x^t^^^/^u^^o^aJ-^ /ry Y9 Cfp~ 2LO<:>
Date on shippmg paper
Descnption
(UN#, Proper shipping
name, hazard class)
Physical and/or
Chemical form
U \rad\COMMON\Uranium millsM le(2)UTl 900479 EnergyFuels Resources (Denison Mines) - White Mesa UMillMIP Inspection modules\2012\Inspection
ModulesMlADMOD-SSS-02 rev 1 doc
Radionuclide
Activity
Class
Emergency phone #
Exclusive shipment
(Y/N)
Certified
Comments*
SOURCE CHECKS. INVENTORY AND SECURITY
Radiation Protection Manual Section 3.0 Equipment/Calibration (Appendix E 2007 hcense renewal)
14 Observe the RSO or designee perform an Instrument Source Check Descnbe what they did
Comments.
15. How do they document their source Inventory
Comments.
\ \AJLj::4..a;^| <^-AJOv/rc^ n"(^-z-:s>e> <j^Sf^6'09 4oo O^'/H
16. Where are the sources kept*^
Comments
V
17. Any new source received*?
Comments
lO
U \rad\COMMON\Uranium millsM le(2)UTl900479 EnergyFuels Resources (Denison Mines) - White Mesa UMill\HP Inspection modules\2012Mnspection
ModulesMlADMOD-SSS-02 rev 1 doc
Dnno f. r.f\t\
18 Any source disposed of?
Comments
/J6
19. Were leak tests performed on the sources?
Comments: /,
g^3^(CA^ Sf>yCM^ C^^-g^CKT^ C2_7-^(l^Kr
Release Limits
Alpha (Umestncted and Product)
Beta-Gamma (Unrestncted Only)
Ore Trucks (Sole Use Transport)
49CFR173.443(d)
Average
Maximum
Removable
Average
Maximum
Intemal Surfaces
Extemal Surfaces:
5,000 dpm//:
15,000 dpi
1,000 dpi
0.2 mr/hr
1.0 mr/hr or 15,000 dpm/cm^
10 mR/hr 7 contact 2 mR/hr 7 at 1 meter
22,000 dpm/lOOcm^ a Removable
0 dpm/cm^
49CFR173.443(d)(1) states* ^4 .sMrvey of the interior surfaces ofthe empty vehicle shows that the
radiation dose rate at any pomt does not exceed 0.1 mSv per hour (10 mrem per hour) at the surface or
0 02 mSv per hour (2mrem per hour) at 1 m (3 feet) from the surface
U \rad\COMMON\Uranium millsM le(2)UTl900479 EnergyFuels Resources (Denison Mines) - White Mesa UMillXHP Inspection modules\2012Mnspection
Modules\RADMOD-SSS-02 rev 1 doc
Interview with the Radiation Safety Tech.(s)
1 Name: ^ ft^rfc-iiA^
2. Job Title* K-j MisAc ^
3. How long have you been a Radiation Safety Tech? ^ u/i^^_
4. How were/are you trained to be a Radiation Safety Tech? OJT
5. How long did your traimng lasf? ^ ^o^)b^
6 Descnbe how you would survey product drums before they leave the restncted area?
7 What are the release limits for productdrums? /^t^e^ Ju^t^Z/ttjis^^^ ^ cJ^z/v^
8 Descnbe how you would survey an Ore Truck out of the restncted area"?
I^V*^ ^Tr^^ii. ^ />r .e-a.e,C^^^cgX (^fvc-^oC^ v^Nj^JiL^ l:'qtbJi=^
9. What are the release limits for the Ore Truck? ^ /^>A|a-g "Z f JO^^^AP- —Agx-^^ »
10 Descnbe how you would perform an uamstficted release survey on an Intermodal Container*?
11. What are the release limits for an unrestncted release? ^ f<^^^^^M. 3 <s>^<:^ (5<5-<^o
12. Have them demonstrate how to^ou^^check an mstrume^
13 How often are instruments source checked?
14 Where are the procedures kept that tell you how to perform a survey or source check an mstrumenf?
K'^t^-W.oC^ ?T-A^-Ui>l^ \M.2Av^-^t — (l^P/^^
15 Have you read those procedures'? V-e^
16. If you have a question about your lop, how would you get it answered*? 9^^^^ A-^ R P K ^
Comments* \ -
U \rad\COMMON\Uranium millsM le(2)UTI 900479 EnergyFuels Resources (Denison Mines) - White Mesa UMill\HP Inspection modules\20I2\Inspection
Modules\RADMOD-SSS-02 rev 1 doc
ProHnct Shipping Papers
Page 1 of 1
STRAIGHT BILL OF LADING
ORIGINAL-NOT NEGOTl^U
RSB Logistics RSBI
Shipper No
Cam^ No,
Date 9/10/2012
Be of Camef) (SCAQ
on coStictim iMHvenreliipRieats, me letcefis G(X> nnist ^?pearii^^
othoTOiIss pnwkieCI ui^tem439. 1 From- ShfbDer ENERGY FUELS RESOURCES USA INC.
To. Consianee CAMECO CORPORATION Street 6425 SOUTH HWY 191
Street HIGHWAY 10 Qtv BLAMDING State UT ZioCode B4S11
Citv BUND RIVER state ON. CANADA Zip Code 99352 24 hr Ernergency Contact tfiJ No CHEMtREC 1-8D0w|24-93eft
Route NOTIFY UPON ARRIVAL DIANE FOtCO @705/356-1498 EXT 3285 Vehicle
Number
No ofunits&
container ^pe HM Basic Description
Proper St^ifwig Name, Hazani Oass.
iCai >ti{iuat>on Number (UN WAj.fmidngGroup, pgr 172101,172^02,172203
Totaf Quantity
OVeight, Votutne.
Gedfons, ete)
Weight
(Sufatectto
Coiiuvbun)
fUCfE Charges
(For CanTer
XX na UN2»12, RAOIOACTiVE IMTERIAt, LOW Sf»EClFie ACnvlTY
(L8A-1). iWZ^ CUSS 7 QROSS 42995 LBS
19516 K6S
UftANIUM ORE CONCENTRATE AS URANIUM OXIPE U-308
PHYSICAL FORM: SOUD
CHEMiCALFQRM: OXB»E
ACtlVrrY: 46bq {.19 Cl) PER DRUM
iJBgLS AH>UEd: RADldACtfve YELL^r
TRANSPORT fNPEX; 0.4 PER^RUM
PLACA3WS.1tM10ACTIVE
mis VEHICLE IS ASStGMED FOR EXCHJSJVE USE OF ENERGY
FUELS RESOURCESt USA INC. UNDER PROVISIOHS OF 49 CFR
OO NOT LOAD OTHER FREIGHT IHTHiS VEHICLE. TRANSFER EN
ROUTEtt^ BI^AK SEAL
TRUCK SEAL NUM&ER:
PLACARDS TENDERED- YES: X NOO
Npt©-(^)\Wl?I9t^eraleISdepefldflraonra6Je shipper;arfrequkedtQSatespecHlc^flyon
a*4l)ng 9m s3E4«d or iia(:lsied
of fts |M|ieily a hereby ispeciflcaBy alBiEd iqr Sie il^^
1 hflreby dedare Sist 4ie contenis of IM^ . eapdprnemmftiByuirf^aaicptclydes^^ dxne fay tie ]Xtiper dt^fbig nanta and are cMEcned, packaged, moiked, avil 1siMled/4ibcndL Old aS lespetit*
appfteeUe Hi^tenraQpiu? andijatfonaf
govefumeirial laspdationa.
ON BEHALF OF SUFFER
COO AtntS COS) Fge.
couECTi e
{2)VmOT'aieSp^EcsiU»lsi«{inn@anG^ped^«1mVESoncaihe«t^^
BsbH^f <r oecterg s yisKm, to ccntei^lbbffiy Et)tf to lk?d^
pioyCEtons. S89 NKR. Ksm 172.
^CamafiSesmfilitv^^eelalciaiSt^KittsmvsSiitS^
b» so marked and ps«9csged seta ensure eaDitrsnspartaStin. See Section 2(e} of ten 36o
Bni'of Isttig. Fre^ and S(Btefl)snt5 ol Chais» and SecS^ iBnns and ecndUcns fcrs fistof sud> arddoa.
1 hflreby dedare Sist 4ie contenis of IM^ . eapdprnemmftiByuirf^aaicptclydes^^ dxne fay tie ]Xtiper dt^fbig nanta and are cMEcned, packaged, moiked, avil 1siMled/4ibcndL Old aS lespetit*
appfteeUe Hi^tenraQpiu? andijatfonaf
govefumeirial laspdationa.
ON BEHALF OF SUFFER
sl0n thalofiaittiB ckflunni^
Tb^frtBttJB#nrfw^fitdrfiiwjirfff^>WiyflflBt^M(fMwl]wp'wt<rf
TOTAL
CHARGES «
FREIGHT CHARGED
acotudMnbiatd b tniKibB
{2)VmOT'aieSp^EcsiU»lsi«{inn@anG^ped^«1mVESoncaihe«t^^
BsbH^f <r oecterg s yisKm, to ccntei^lbbffiy Et)tf to lk?d^
pioyCEtons. S89 NKR. Ksm 172.
^CamafiSesmfilitv^^eelalciaiSt^KittsmvsSiitS^
b» so marked and ps«9csged seta ensure eaDitrsnspartaStin. See Section 2(e} of ten 36o
Bni'of Isttig. Fre^ and S(Btefl)snt5 ol Chais» and SecS^ iBnns and ecndUcns fcrs fistof sud> arddoa.
TOTAL
CHARGES «
FREIGHT CHARGED
acotudMnbiatd b tniKibB
REMITCOD TO
/UIIDRESS
RBCBVEO miieAloimdas^SceSamaadisiBanfSieamfheiaSBillv^ exceptasnoWCconlxnlssidcanBtaafcnnlcnbafpsdiagesu^^ and
dastMdasln<8iaM abawwWch said canier^iiard
im^inub>,t<hM«iM>Mi<iiH>wrJiiiiti>.ih«rr^^ Itisiiuti^^.^n»dastoead)tanferirf«Hdr.aoy(A«ailp^^
propel^ lhataigytaaice to liapartannadlagacindaf doll tojut^^
St^iperhMel^cariahbBkdlwteteBsrwftaaflwtaftiateiinsaBduiiiUt^ stilipeFandaceapaBd for Mmsa); and lis assigns.
SHIPPER. ENERGY FUELS RESOURCES USA INC CARRipRr^ LOGISTICS, INC, TRANSPORT #0612-730
PER]^^{$~^^(9f
DATE rAiT-io-t2. DATE
r
WorkCentre 7346
Transmi ss i on Re port
G3 I D 435 678 2224 Date/Time 09/14/2012 05 58AM
Page 1 (Last Page)
Local Name Denison Mines
Logo White Mesa Mill BlancJing Ut
Document has been sent
Document Size 8 5X11"SEP
Energy Fuels Resources
(USA) Inc.
642JS HigtR«ayl91 POBox809
Bland]iig,UT84Sll
Tel [phone]
FAX. [phone]
Facsimile Transmittal
Pu
Compiw C,^ nomber ) r^cS" rZZ%
Fnm. Ti^lT^I, PaKalofi Z-
^^<:.•(• Cu$(.a,.-5 Weft
Total Pages Scanned 2 Total Pages Sent
No Doc Remote Station Start Time Duration Pages Contents
1725 7053561223 5 56AM
Note RE Resend MB PG Pol I ing RB SA Send Again EN
Send to MaiIbox Relay Broadcast Engaged
BC Broadcas t RS Re I ay Send
AS Auto Send
MP MuIti Polling BF Box Fax Forward TM Terminated
RV CP Remote Service CompIe ted
Fuels Resources
(USA) Inc,
6425 S Highway 191, PO Box 809
Blandmg, UT 84511
Tel [phone]
FAX [phone]
Facsimile Transmittal
To: -TN. ^ . Date.
Fax
Company: C^^^^^r^ number:
From: "l^cju^^lTU 1/ Page 1 of:
Re: ?,0L Lv- B^^^ U4 U
us DEPARTMENT OF COMMERCE-EcwmMsarulSlaisticsAfcninis!^ CENSUS BUREAU - BUREAU OF EXPORT ADMIMlSTRATlON
FORM7525"V(7-I8>2003) SHiPPER*S KCPOBT DECLARATION QMB NO 0307^152
ta. U S PFUNdPJM. PARTY IN (H7ERES7 (U^rKCoi^ name snd akbsss)
ENERGY FUELS RESOURCES USA INC
6425 SOUTH HWY 191
BUNDING, UT
b. USPPI'S BN ORS) OR iO MO
84-1372857
ZIP CODE
84511
C PARTIES TO TRAMSACTKHii
@R^led
4a.(A.T|MATEGON8)aNEE «kmplete name and adifressi
CAMECO CORPORATION, ONE ELDORADO ROAD
BLIND RIVER, ONTARIO. CANADA
IfcfNTERMECaATECONSfeNEE (Comply name ml adtkess}
Sa. FORWARDING AGENT (Cmjplete name tmd atkfrgis)
RSB LOGISTIC SERVICES. INC
2425 SOUTH 4TH STREET
PADUCAH,Ky 42003
ll. FORWARDING AGE^f^S EiN (IRS) NO
54-1243432
ZOATE(»=eXK)RTAT!ON
10 SEPTEMBER 2012
3. TRANSPORTATON REFERENCE WO
0612-730
0. POINT (STAH) OF ORIGIN FTZNO
UT
7. COUNTRy OF ULTIMATE OESmKfm
CANADA
B.LOADING PIER (Vasselonly} B^vEnmt^TmmmmiitfSm^
TRUCK
f*. CPSmm lOBfTIFtCATtON CODE
RSBI
iS. SHIPMENT REFERENCE NO
0612-730
10. E}ff>QRnNQ CARRIER
RSB LOGISTIC
11. PORT (^EXPORT
a^ULTSTE MARIE
tBi^rrRY NUMBER 17, HAZARDOUS MATERIALS
Wives DNO
ia. IN BONO CODE ift, ROUTED EXPORT ITWJSACnON
•YTO
12. PORT OFmOADtNG (Vissseiandaira^ 13. C0NTAlNEffi2El><V«s$e/«>$^
•Y«8 DNO
20. SCHEDULE B DESCRIPTION OF COMMODmES (tJsetxjkmsZZ^)
DIP orM
(21)
SCHSHJLEBNUKffiER (WANTTTV-SCtOlA£BlMlT($) SKIPPiNQ WEIGHT
ttStan
VffMPROOUCTMftKfV VEHICLETITIE NUMBER
VALUE (U.8do«af£,
2844102010
URANIUM ORE CONCENTRATE
43 DRUMS
LOT 88
17932 KGS 19516 KGS $2,045,833 00
27. UCENSE NOAIOEKSE EXCEPTK»4 SVMBOiAUTHORiZA'nON
XSOU8798
39, Duly (smtbetteffleei or«iQ)loy0e
KATHRYN WALTERS
28. ECCN {Wlm require^
90M fceiMythataiiaailemeft&roaaeattii and vmeistsnd <tw instiuctons lh» mtppM'* EXpMt deeUiral sala, may oe impaaed fat maieng fstae
souse fi^SAlO]
, actask>!WuSitigaguiito(e}^conMaitd I customs putpo8e$
MomtatmcorOatwaJm^mebuoemtlcottectaniiViailitaverexl afon erf (hia ifocuimitf. 9^ forth in^ N$«f*«eCw«y nu Owi
Of ftmKfutoit ^atemsnts herein, MM to pfovida Ifte reqw anexpoAaiioflOSUSC Seei.3as;22U9C sea407 lausc Sec
CUSTOWERACCREP
10 SEPTEMBER 2012
Tele{rfiatta Na dlmSata Ama Code)
270-444-6004
««n«M«M- aqDpeftBgiMtOdClaia^CeranytucMSsaf
dMunM«« HtotM^ iiMaM «>iett W Jrsm put«» «^
the Setntaiy detntes 9t>i $uch «iaiRpew wsuU be cot^^ i)tfen« ^tmt (TH* 19. Ctiapter 9. SMMn 301 (d!>.
ifttl^ OSce at Eiqport EiAi<a)inent
Setrice
M, AUTHEHTfCATKW ^Mto »HJ{/;/KO
E-fnail address
pa<Jucah@rsbloglsttc com
TM$ fomt fsvsf be ptstfed by private parties prcnildedl it conlotms to the official foim Far sale by the StqperintendEnt erf Dooimeite, ^emtn«nt
P^StS^a^ce Wfe£tegt(« QC20402,a(iaics3!Cuaem-s0i£tftetBl{e<3QTS.Th«^e«%sftW^to1«ftitifteS^^
Etedinattet^ is ^t^klble from d» U.S, Coisus Bufeau, Washing OC 20233
I
ftevi^nu^ Canada
Customs and Excise
^AN/y^A CUSTOMS INVOICE 1 Ofl
1. Vendor (Name and Addiess)
ENERGY FUELS RESOURCES USA INC.
6«S SOUTH HWr IBI
BRANDING. W 84511
2. Date of Oirect Shipment to Canada
SEPTQHBQ21D,2012
3. Other References (Include Purchaser's Order Na)
LOT da
4. Cims^tiBs tNatnB.and Addrssi^
CAMECO CORPORATION
ONE ELDORADO ROAD
BLIND RtVER, ON, CANADA
5 Purcfiaa«fs Name and Address oiherthan Coiafi^iefe^ 4. Cims^tiBs tNatnB.and Addrssi^
CAMECO CORPORATION
ONE ELDORADO ROAD
BLIND RtVER, ON, CANADA
& ^ouittry of Tf aishqsnent
NONE
4. Cims^tiBs tNatnB.and Addrssi^
CAMECO CORPORATION
ONE ELDORADO ROAD
BLIND RtVER, ON, CANADA
7 Cdiffllryiif Orl^of Coj»ds
U.SA
T.ltansportaBon GtveModetrndnaceiiiDirei^SiilPBienttoCanaite
I^LOGlSTiClNC.
ROAD TRANSPORT CROSSING AT
SAULTSfE.MAl%IE»MI
a CondHions of Sale and Terns of Payment (ije.Sai«^Con^ini»nt3hipiii«nt.tjeasea
Ooods^etc)
FOR PROCESSING AND RETURN
T.ltansportaBon GtveModetrndnaceiiiDirei^SiilPBienttoCanaite
I^LOGlSTiClNC.
ROAD TRANSPORT CROSSING AT
SAULTSfE.MAl%IE»MI
10 Currency of SutUuiri»ut
USD
11.Ng<rf
4i
12.gtW6»H;att<w<rfCwampdMg9tWnd<fyaclca9B^Msilw
Descffptlon and CluHBCteitetles,Grade, 4luOTtit^
DRUMS
URANIUM ORE CONCaiTRATi
NET WEIGIfT CONCENTRATE: 39533 L^
17932 KGS
Cameco is importer of Reoortland e taking care of all Charges witti
regards to Customs aaarance Near North is the broker on behalf of
Cameco.
PatriGlcPlourtle
Near Nof^ Custonv Brewers Inc
1855JLasaHefilvd
Sudbury, ON, P3A 2A3, Canada
rm 1-705-560-24G0
Fax# [phone]
Emaifc. patrtckp@neamorthaistoms com
19. Quantify
(StatoUnit)
39533 LBS
Setting Prtee
14.
Price
UnH
$51.75A3
19w Totaf
$24I45,B33.^<
10 if4ny«f fields 1t» 17 are kieluded on on ^tteehed commercial Inveloe, cheek box D
CommencNi Invoice No. ,
10 Total Vlfef^
Net 39533 LBS Qrass 42995 LBS
17 Invoice Total
$?^5,833,^Q
19 Bqiotttf*ifr Niank^^^ Ad«fi«&s ^ other UuA Vehdv)
SAMEAS^SNDOR
20 Originator (H»ne and Adifiess)^
David Turk
21 DepaftmenttaRtdingOfapplteabto) 22.lffteMs23to2SaronotappBcafiifa,<Aw;kgasbox
23 irincbufedlhfield 17 Indicflte amount
(I) TramportaUon daarqes, expBtisBs, and
insurance from the place ^ dir^aJiqunent to Canada
incwred afler ^portidfon Itito Canat^
$
Qi^EjqpigyitpacMRS
24w tf not Ineftided on field 17 indicafB amowt:
OfTraasportBiton tiierges, expenses and {nsursice
ty the place of direct shipment taCanada
(d) Amounts for commisskHe other than faiq^ng
commfsslofls
fH0Ejq}ortPa<3dtt<f
25. <3ieck ^ appflcahfe}
0) Royalty payments or subsequent proceeds are
panf or payalile Iqr 0»f»ncliaser
(G) Tbe laifchaser has^ suy^iied goodsisr services for
use In the |vo(faictfon of these goods
www.rsbloglsticcom
RSB LOGISTIC INC Phone [phone]
219 Cardinal Crescent TolI-Fr«e 800-667-3934
Saskatoon, SK S7L7K8 Fax [phone]
Canada
September 05,2012
Robert Caldwell, Chief
Fuel Cycle Security and Transportation Branch
U.S Nuclear Regulatory Commission
Office of Nuclear Security and Incident Response
Division of Security Policy
RSB Reference No.. 0612-730F
ADVANCE NOTIFICATION OF EXPORT SHIPMENT
In accordance with the requirements for implementation of the Convention on the
Physical Protection of Nuclear Material, we are submitting the following
1) Shipper. Receiver and Carner
Energy Fuels Resouces (USA) Inc 435-678-2221
Formerly Denison Mines Corporation
6425 South Highway 191
White Mesa Mill
Blanding, UT
Cameco Corporation 705-356-1496
Highway 17 West
Blind River, ON, Canada POR 1B0
RSB LOGISTIC INC. 306-242-8300
219 Cardinal Cr
Saskatoon, SK S7L 7K8
2) Physical Descnption
This shipment will consist of 43 Drums of Uranium Ore Concentrate (U-30B) in 1 x
53' trailer The total weight of the shipment is 17,932 kg of U-308 Lot 88
SASKATOON, SK PADUCAH, KY
Robert Caldwell
September 05, 2012
Page 2
3) Transportation and Route Schedule
The surface transportation from Blanding, UTto Blind River, ON will be the
responsibility of RSB LOGISTIC INC. Export from the United States will occur at
Sault Ste Marie, ON on or about September 14,2012.
Shipment Routing
Departs Blanding, UT September 10,2012
Arrives Sault Ste Mane, ON September 14,2012
Arrives Blind River, ON September 15, 2012
4) Export License: NRC License No XSOU8798
This shipment will be protected dunng transport in accordance with Annex 1 to the
Convention on Physical Protection of Nuclear Materials
Sincerely,
Helge Struthers
Int'i Transportation Specialist
RSB LOGISTIC SERVICES INC
SASECATOON, SK PADUCAH, KY
\
ss LOGISTIC
www.rsbIogistic.com
RSB LOGISTIC INC
219 Cardmal Crescent
Saskatoon, SK S7L 7K8
Canada
Phone
Toll-Free
Fax
306-242-8300
800-667-3934
306-242-2311
ATTACHMENT 1
RE Energy Fuels Resources (USA) Inc - Lot # 88
Certification of Export Filing:
THESE COMMODITIES, TECHNOLOGY OR SOFTWARE WERE EXPORTED FROM THE
UNITED STATES IN ACCORDANCE WITH THE EXPORT ADMINISTRATION
REGULATIONS DIVERSION CONTRARY TO U S. LAW PROHIBrrED. NO SED
REQUIRED-AES-132637752-RFI162362.
AES-ITN-X20120906034794
SASKATOON, SK PADUCAH, KY
Denison Mines (USA) Corp.
White Mesa Mill
Notice of Product Shipment Date lO-Sep-12
Product:
Lot No.: 88
Trans. No. 638
Customer P.O. or Order Number:
U3O8
VA"
AMV'
Other
X
Gross Weight
Tare Weight
Net Weight
NetMafl Weight (lb) '
Weight as U3O8 (lb )
Weight as U-Nat (lb ) "
Net Mat'l Weight (kg) [
Weight as UjOg (kg)
Weight as U-Nat (kg)
N/A
Destination: Cameco Corporation
328 Eldorado Road
Blind River, ON POR IBO
Canada
77,860
34,380
43,480
40,844 0
39,533 0
33,524 0
18,526 0
17,932 0
15,206 0
Shipper Energy Fuels Resources via RSB Logistics
Shipment No YC-88
Shippers Paper
Shipper
Energy Fuels Resources HOLDINGS CORP
6426 SOUTH HIGHWAY 191. P O BOX 809
BLANDING. UT 84512
CONSIGNEE
Cameco Corporation
328 Eldorado Road
Blind River, ON POR 1 BO
Canada
DELIVERING CARRIER
DATE
CONTRACT NO
LOT NO
9/10/2012
97-538
YC-88
RSB Logistics
TRACTOR NO
TRAILER NO
SEAL NO
53809
253128
7804
Seal# 007804
PARTIAL LOT
COMPLETE LOT
GROSS WEIGHT (lbs / kg)
XXX
77,860 35,317
Matenal Shipping Description
EXPULSIVE USE SHIPMENT
Radioactive Matenal, low specific activity
Activity 8 GBq - Transport Index 0 4
Class7UN2912
43 Drums of Natural Uranium (U-Nat) Solid Form
Received in good condition, except as noted
Emergency Contact Phone Number:
Chemtrec 1-800-424-9300
Account # 223794
Signature of Driver
Received By
This IS to certif ly 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
Date
Signature
urces^€ Energy Fuels Resourcesflepresentative
Date
Denison iVitnes Corp
6425 S Highway 191, PO Box 809
Blandmg, UT 84511
USA
Tel 435S78-2221
Fax [phone]
wvm denisonmlnes com
SHIPMENT SURVEY
CONTRACT NO
TRACTOR NO
LOT NO
TRUCK CARRIER
TRAILER NO
ili.
MODEL NO
SERIAL NO
CALIBRATION
EFFICIENCY
FACTOR
MDA
ALPHA SURVEY INSTRUMENTS
TOTAL
MODEL NO
SERIAL NO
CALIBRATION
EFFICIENCY
FACTOR
ALLOWABLE LIMITS (FIXED) 5,000 PPM AVG 15.000 PPM MAX (REMOVABLE) 1,000 PPM
REMOVABLE
10 feu l-L^
ikl
1 0
SURFACE AREA OF PROBE
100 cm^
X EFFICIENCY OF INSTRUMENT (%) = FACTOR
100
(EFFICIENCY/1 OOcm^)
Factor X counts/minute = Pisintegrations/minute/IOOcm'
INSTRUMENT NO
SERIAL NO
CALIBRATION
TRAILER SURFACE
SIX FEET DISTANCE
DRIVERS SEAT
SLEEPER
3
GAMMA SURVEY (49 CFR 173 441 (b) (1))
MEASURED IN MILLIREMS/ HOUR
9 - Xtj\/^-;z7 (MR/HR)
200 MR/HR ALLOWABLE
10 MR/HR ALLOWABLE
2 MR/HR ALLOWABLE
2 MR/HR ALLOWABLE
ALL DRUMS WERE INSPECTED PRIOR TO LOADING ALL DRUMS WERE TIGHTLY
SEALED NONE LEAKED AND THERE WAS NO LOOSE MATERIAL IN THE VEHICLE
INSPECTOR SIGNATURE DATE ^-l£?-(Z^
lype Of Shipment Vg^uQU fxi^tcg^ Lot# ^2
Drum
#
Total Alpha
dpm/100 cm^
Top Sides
Removable Alpha
dpm/100 cm^
Top Sides
p/Y
Average
mrem/hr
1
2
t^X.CL. M 1
2 VLV (.
3 be 4
4
5 i-B ^ to (.
6 ^gl/^
7
8 //'^
9
10
11
12
13
14 \ / \ \ /
15
16
17
18
19
20 1
21
22
23
24
•\
N /
25 '3
If total Alpha is greater than or equal to 1,000 dpm/100 cm^ a removable smear is required
Alpha Meter
Model #
SN#
Removable Alpha
Cai Date \')
Model #
SN#
Beta/Gamma Meter
1_ Model #
SN#
Check Date )? pg^l
Cal Date 10
Th 230 @ 33.000 dpm
dpm Average ^ ooo
Efficiency \gr \
Bkg ^0
Check Date i/} Aoci \^
Th 230 @ 33,000 dpm
Efficiency XS- ^^^o
Bkg iiA\ .
Cal Date IMJV^LT 1^^
Check Date 7 T)eC.
Cs137 SN#2
Reading 1. M.r| wt^
Bkg c) c H Mr| tV\i^
Drum
27
28
29
30
31
32
33
dprn/100 cm^
Top Sides
^^^^ RemovaPe Alpha
dpm/100 cm^
"op Sides
Pages
|3/Y
i/era
mrem/hr
3Z 34
35
36
37
38
39
40
41
42
43
44
45
46
47
48
49
50
Comnnents:
DOE/NRG FORM 741
(6-2011) Previous editions are obsolete
MANDATORY DATA COLLECTION
AUTHORIZED BY 10 CFR 30 40 60 70 72 74 75 150
Public Laws 83-703 93-438 95-91
US DEPARTMENT OF ENERGY AND US NUCLEAR REGULATORY COMMISSION
NUCLEAR iVIATERIAL TRANSACTION REPORT
APPROVED BY OMB NO 3150-0003 EXPIRES 05/31/2014
Estimated burdenper response to comply with this mandatory collecbon request 1 hour and 15 minutes This information IS required for IAEA accounting reports that show changes in inventory of nuclear matenals Send comments regarding burden estimate to the Information Services Branch (T-5 F53), U S Nuclear Regulatory Commission Washington DC 20555-0001, or by internet e-mail to infocollects resource@nrc gov, and to the Desk Officer Office of Information and
Regulatory Affairs NEOB-10202 (3150-0003), Office of Management and Budget Washington, DC 20503 If a means
used to impose an information collection does not display a currently valid OMB control number fhe NRC may not
conduct or sponsor and a person ts not required to respond to, the mformation collection
1 SHippEirsRis 2 RECEIVER SRIS 3 TRANSACnON NO 4 CORRECTION NO 5 PROCeSSINO CODE « ACTION CODE 7 DOCUMENTATION (Only If documm* ii dntllM SECRET)
XRA RDLA 00638 I SHIPPER A L SHIPPER A PAGES COPY COPIES SERIES
Energy Fuels Resources (USA) Inc
6425 South Hwy 191
Blanding, Utah 84511
cATTEHTioM David Turlc
d TELEPHONE [phone]
10 NO OF DATA UNES 01
Cameco Corporation
Eldorado Road
Blind River, Ontario, Canada
12jt SHIPPED FOR ACCOUNT OF
c ATTENTION-
d TELEPHONE
11 NATURE OF TRANSACTION
13J SHIPPED TO ACCOUMf OF
14 TRANSFER AUTHORITY-CONTRACT NM DRAFT OR ORDER NUMBER 15 EXPORT OR IMPORT TRANSFERS UCENSE NO
XSOU8798
NO DISTRIBUTION OF COPIES
XRA
NMMSS
RDLA
16 MATERIAL TYPE ANO DESCRIPTION
43 Drums of Natural Uranium (Split US and Canadian Obligated matenal)
01 32 193
OBLIGATED ISOTOPE WEIGHT For Enriched Uranhan Orly
22. ACTION OATE
09 10 2012
23a MISCELLANEOUS b CONCISE NOTE ATTACHED •
REPORTABLE? | | YES ^ NO
b SMPPEirS CORRECTION
d RECEIVER-S MEASUREMENT
: RECEIVERS CORRECTION
24 TOTAL GROSS WEIGHT 19,516 25 TOTAL VOLUME (Wkste Tmatm Only)
BACK
REFERENCE NUMBER
TYPE
OF INV
CHANGE
MATE
RIAL
TYPE
COMP/
FACIUTY
CODE
KEY
MEAS
POINT
OMP METHOD
GROSS WEIGHT ELEMENT
UUITOF
ERROR
ISOTOPE
UMIT OF
ERROR
01 YC Lot 88 43 N 032 15,206
26s SHIPPERS DATA S/GNATURE OF AUTHORIZED OFFICIAL AND DATE SIGNED
4» 4^ 4» 27s RECEIVER'S DATA SIGNATURE OF AUTHORIZED OFFICIAL AND OATE SIGNED
WARNING FALSE STATEMENTS IN THIS CERTIFICATE MAY BE SUBJECT TO CIVIL AND/OR CRIMINAL PENALTIES NRC REGULATIONS REQUIRE THAT SUBMISSIONS TO THE NRC
BE COMPLETE AND ACCURATE IN ALL MATERIAL RESPECTS 18 U S C SECTION 1001 MAKES IT A CRIMINAL OFFENSE TO MAKE A WILLFULLY FALSE STATEMENT OR
REPRESENTATION TO ANY DEPARTMENT OR AGENCY OF THE UNITED STATES AS TO ANY MATTER WITHIN ITS JURISDICTION
DOE/NRC FORM 741 (6-2011)
OOE/NRC FORM 741
(6-2011) Previous editions are obsolete
MANDATORY DATA COLLECTION AUTHORIZED BY 10 CFR 30 40 50 70 72 74 75 150 Public Laws 83-703 93-438 95-91
US DEPARTMENT OF ENERGY
ANO
U S NUCLEAR REGULATORY COMMISSION
NUCLEAR MATERIAL TRANSACTION REPORT
APPROVED BY OMB NO 3150-0003 EXPIRES 05/31/2014
Estimated burden per response to comply with this mandatory collecbon request 1 hour and 15 minutes This information IS required for IAEA accounting reports that show changes in inventory of nuclear matenals Send comments regardinq
burden estimate to the Infonnation Services Branch (T-5 F53), U S Nuclear Regulatoiy Commission, Washington, DC
20555-0001, or by internet e-mail to infocollects resource@nrc gov, and to the Desk (jfficer Office of Information and
Regulatory Affairs, NEOB-10202, (3150-0003), OfRce of Management and Budget Washington, DC 20503 If a means
used to impose an informabon collection does not display a currently valid OMB control number, the NRC may not
conduct or sponsor, and a person is not required to respond to, the information collecbon
1 SHIPPER'S RIS 2 RECEIVER'S RIS 9 TRANSACTKIN NO 4 CORRECTION NO 5 PROCESSING CODE 6 ACTION CODE 7 DOCUMENTATION (Only »dacunKnll.diwnW SECRET)
XRA XRA 638 iM PASES COPY COPIES SERIES
»a NAME ANO ADDRESS
Energy Fuels Resources (USA) Inc
6425 South Hwy 191
Blandmg, Utah 84511
0 ATTENTION David Turk
d TELEPHONE [phone]
10 NO OF DATA UNES 01
12a SHIPPED FOR ACCOUNT OF
c ATTENTION
d TELEPHONE
11 NATURE OF TRANSACTION
13J SHIPPED TO ACCOUNT OF
14 TRANSFER AUTHORITY CONTRACT NM DRAFT OR ORDER NUMBER 15 EXPORTORIMPORTTRANSFERS UCENSE NO
Gen Lie
XRA
NMMSS
DISTRIBUTION OF COPIES
16 MATERIAL TYPE AND DESCRIPTION
43 Drums of Natural Uranium (U S matenal) ELEMENT WEIGHT
OBLIGATED ISOTOPE WEIGHT For Eitficbed Uianiun Only
22. ACTION OATE
23a MISCELLANEOUS b CONCISE NOTE ATTACHED •
UK REPORTABLE? | [ YES | NO
b SHIPPERS CORRECTION
09 04 2012
d RECEIVERS MEASUREMENT
• RECEIVERS CORRECTION
24. TOTAL GROSS WEIGHT 19,516 25 TOTAL VOLUME OMstt Tnm/an Only)
BACK REFERENCE
NUMBER
TYPE OF INV
CHANGE
MATE
RIAL TYPE
COMP/
FACILITY CODE
KEY
MEAS POINT
OMP METHOD
GROSS WEIGHT ELEMENT
UMrroF ERROR
ISOTOPE
UMrroF ERROR
26s SHIPPER'S DATA SIGNATURE OF AUTHORIZED OFFICIAL ANO DATE SIGNED 4^ 4» 4^ 27s RECEIVER'S DATA SIGNATURE OF AUTHORIZED OFFICIAL AND DATE SIGNED
01 34 YC Lot 43 N 32 15,013
WARNING FALSE STATEMENTS IN THIS CERTIFICATE MAY BE SUBJECT TO CIVIL AND/OR CRIMINAL PENALTIES NRC REGULATIONS REQUIRE THAT SUBMISSIONS TO THE NRC
BE COMPLETE AND ACCURATE IN ALL MATERIAL RESPECTS 18 U S C SECTION 1001 MAKES IT A CRIMINAL OFFENSE TO MAKE A WILLFULLY FALSE STATEMENT OR
REPRESENTATION TO ANY DEPARTMENT OR AGENCY OF THE UNITED STATES AS TO ANY MATTER WITHIN ITS JURISDICTION
DOE/NRC FORM 741 (6-2011)
WorkCentre 7346
Transm i ss o n Re port
G3 I D 435 678 2224. Date/T i nn« 09/10/2012 06 57AM
Page 1 (Last Page)
Local Name Denison Mines
Logo White Mesa Mi I I Blanding Ut
Document has been sent
Document Size 8 5X11"SEF
Total Pages Scanned 2 Total Pages Sent
No Doc Remote Station Start Time Duration Pages Con tents
1307 3019031998
Note RE Resend MB PG Po I I I ng RB SA Send Again EN
Send to Ma i I box Relay Broadcast
Engaged
BC Broadcast RS Re I ay Send AS Auto Send
MP MuIti Polling BF Box Fax Forward TM Terminated
RV
CP
Remote Service CompI e t ed
Enm'Qu Fuels Rsources IU5R) Inc.
mmmm
6425 S Highway 191
PO Box809
Blanding, Ut 84511
USA
YC Lot 88
Tel [phone]
Fax [phone]
www energyfuels com
96 79 % U3O8 Est grade Forgin
Oper Production 82 08 %U Gross Gross Net lbs Net Kg Net lbs Net Kg Obligated U
Initial Dates Tare lbs Tare Kg lbs Kg Net lbs Net Kg U3O8 U3O8 U U Kg by Drum
OK 28-Aug 1 50 23 1,000 454 950 431 920 417 780 354
CK 2 50 23 1,000 454 950 431 920 417 780 354
OK 3 50 23 1,000 454 950 431 920 417 780 354
CK 4 50 23 1,000 454 950 431 920 417 780 354
JB 5 50 23 1,000 454 950 431 920 417 780 354
JB 6 50 23 1.000 454 950 431 920 417 780 354
JB 7 50 23 1,000 454 950 431 920 417 780 354
JB 8 50 23 1,000 454 950 431 920 417 780 354
JB 9 50 23 1,000 454 950 431 920 417 780 354
CK 29-Aug 10 50 23 1,000 454 950 431 920 417 780 354
CK 11 50 23 1,000 454 950 431 920 417 780 354
CK 12 50 23 1,000 454 950 431 920 417 780 354
JB 13 50 23 999 453 949 430 919 416 779 353
JB 14 50 23 1,000 454 950 431 920 417 780 354
JB 15 50 23 1,000 454 950 431 920 417 780 354
JS 30-Aug 16 50 23 1,000 454 950 431 920 417 780 354
JS 17 50 23 1,000 454 950 431 920 417 780 354
JS 18 50 23 999 453 949 430 919 416 779 353
JS 19 50 23 1,000 454 950 431 920 417 780 354
JS 20 50 23 999 453 949 430 919 416 779 353
JS 21 50 23 1,001 454 951 431 920 417 781 354
JS 22 50 23 997 452 947 429 917 415 777 352
JS 23 50 23 1,001 454 951 431 920 417 781 354
CK 24 50 23 1,000 454 950 431 920 417 780 354
CK 25 50 23 1,000 454 950 431 920 417 780 354
CK 26 50 23 1,000 454 950 431 920 417 780 354
CK 27 50 23 1,000 454 950 431 920 417 780 354
CK 28 50 23 1,000 454 950 431 920 417 780 354
CK 29 50 23 1,000 454 950 431 920 417 780 354
CK 30 50 23 1,000 454 950 431 920 417 780 354
JB 3-Sep 31 50 23 1,000 454 950 431 920 417 780 354 193
JB 32 50 23 1,000 454 950 431 920 417 780 354
JB 33 50 23 1,000 454 950 431 920 417 780 354
JB 34 50 23 1,000 454 950 431 920 417 780 354
JB 35 50 23 1,000 454 950 431 920 417 780 354
PK 36 50 23 1,000 454 950 431 920 417 780 354
PK 37 50 23 1,000 454 950 431 920 417 780 354
PK 38 51 23 1,000 454 949 431 919 417 779 354
PK 39 50 23 1,000 454 950 431 920 417 780 354
PK 40 50 23 1,000 454 950 431 920 417 780 354
J B 4-Sep 41 50 23 1,000 454 950 431 920 417 780 354
J B 42 50 23 999 453 949 430 919 416 779 353
JB 43 50 23 1,000 454 950 431 920 417 780 354
Total tare lbs 2,151
Total tare Kg 989
Total gross lbs 42,995
Total gross Kg 19,516
Total Net lbs 40,844
Total Net Kg 18,526
Total lbs U3O8 39,533
Total Kg UaOg 17,932
Total lbs U 33,524
Total Kg U 15,206
Total Obligated 193
Calcined 0
Reaen 193
KF 0
White Mesa Mill Date 07/11 Revision DUSA-2
Transportation Accident Response Plan Page 41 of 44
Figure 4.2
ACCIDENT REPORT
10 Date Time
2 0 Person Calling Capacity
From Telephone No Who Else Notified
3 0 Accident Location
4 0 Description of the Accident
Persons Injured Name(s)
Treatment
Accident Description
5.0 Was Any Company Material Spilled from the Vehicle(s)'^
6 0 What Action Has Been Taken to Contain the Matenal'?
7 0 Please report this information to one of the following
Monday - Friday 8*00 a m to 4 30 p m MST
Harold R Roberts, Executive Vice President - Operations Denver, Colorado
Telephone No. 303-628-7798 day time, work days
Night and weekend contact Telephone No [phone], Cell Phone [phone]
Dan Hillsten, Mill Manager, White Mesa Mill, Blanding, Utah
Telephone No. 435-678-2221 day time, work days
Night and weekend contact Telephone No [phone]
41
Energy Fuels Resources (USA) Inc.
Material Safety Data Sheet
Energy Fuels Resources (USA) Inc requests that users of this EFR product study this data sheet to become
aware of the product's hazards, and promote safe handling of the product by making this information availble
to Its employees, agents and contractors If the matenal is resold. Energy Fuels Resources (USA) Inc requests
that the purchaser be furnished a copy of this data sheet and advised to provide the information herein to its
^ employees, agents and contractors
Section I Product Indentification
Product Name Yellowcake
Creation Date December 6,1993
Revision Date April 20, 2008
CAS Numbers 1344-59-8, 13721-34-1,
1314-64-3, 1309-37-1,7778-18-9, 12136-45-7,7757-82-6,
1314-62-1,7631-86-9, 1344-28-1
Chemical/AUoy Name Uramum Uranyl Oxides,
Uranium Octaoxide
Formula/Composition UjOg (65-95%), Na2U207
(2-21%, UO2SO4 (2-14%), Fe203 (0-2%), CaS04 (0-4%),
K2O (6-2 5%), Na2S04 (0-10%), V2O5 (0-1 5%), S1O2
(0-1%), AI2O3 (0-4%)
Synonyms UsOg, Uranium Concentrates
Formula/Composition UjOg (65-95%), Na2U207
(2-21%, UO2SO4 (2-14%), Fe203 (0-2%), CaS04 (0-4%),
K2O (6-2 5%), Na2S04 (0-10%), V2O5 (0-1 5%), S1O2
(0-1%), AI2O3 (0-4%) Transportation Placard Required - UN2912, Radioactive Class 7
Formula/Composition UjOg (65-95%), Na2U207
(2-21%, UO2SO4 (2-14%), Fe203 (0-2%), CaS04 (0-4%),
K2O (6-2 5%), Na2S04 (0-10%), V2O5 (0-1 5%), S1O2
(0-1%), AI2O3 (0-4%)
Section n Phvsical Data
Size 0 25 inch (0 64 cm) Solubility m Water (g/100 cc) UO2SO4
soluble, CaS04 0 21, Na2S04 4 8, V2O5 0 8, K2O V Sol,
U3O8, Na2U207, Fe203, S1O2, AI2O3 insoluble
Specific Gravity (H2O = 1) 8 3 Melting Point T ("C) U3O8 2372 (1300)
decomp, Fe203 2849 (1565), CaS04 2642 (1450), K2O
662 (350) decomp, Na2S04 1623 (884), V2O5 1274 (690),
S1O2 2930 (1610), AI2O3 3762 (2072), Na2U207, UO2SO4
not available
Odor None
Melting Point T ("C) U3O8 2372 (1300)
decomp, Fe203 2849 (1565), CaS04 2642 (1450), K2O
662 (350) decomp, Na2S04 1623 (884), V2O5 1274 (690),
S1O2 2930 (1610), AI2O3 3762 (2072), Na2U207, UO2SO4
not available
Appearance Yellow to olive-green powder
Melting Point T ("C) U3O8 2372 (1300)
decomp, Fe203 2849 (1565), CaS04 2642 (1450), K2O
662 (350) decomp, Na2S04 1623 (884), V2O5 1274 (690),
S1O2 2930 (1610), AI2O3 3762 (2072), Na2U207, UO2SO4
not available
Bulk Density 80-190 lbs/ft' (1 3-3 0 g/cm")
Melting Point T ("C) U3O8 2372 (1300)
decomp, Fe203 2849 (1565), CaS04 2642 (1450), K2O
662 (350) decomp, Na2S04 1623 (884), V2O5 1274 (690),
S1O2 2930 (1610), AI2O3 3762 (2072), Na2U207, UO2SO4
not available Molecular Weight UjOg 842, Na2U207 634, UO2SO4
336, Fe203 160, CaS04 136, K2O 94, Na2S04 142, V2O5182,
S1O2 60, AI2O3 102
Melting Point T ("C) U3O8 2372 (1300)
decomp, Fe203 2849 (1565), CaS04 2642 (1450), K2O
662 (350) decomp, Na2S04 1623 (884), V2O5 1274 (690),
S1O2 2930 (1610), AI2O3 3762 (2072), Na2U207, UO2SO4
not available Molecular Weight UjOg 842, Na2U207 634, UO2SO4
336, Fe203 160, CaS04 136, K2O 94, Na2S04 142, V2O5182,
S1O2 60, AI2O3 102
Boiling Pomt S1O2 4046 (2230), AI2O3 5396 (2980),
Others not available
Vapor Pressure Essentially ml Percent Volatile Not applicable
Evaporation Rate Not applicable
Section III Hazardous Ingredients
Material or Component (CAS #) Weight % TLV
Uranium-Uranyl Oxides, U3O8, (1344-59-8) (65-95) 0 2 mg/m^ - TWA8 (1)(3)
(Insoluble Compound) (As U)
Sodium Diuranate, Na2U207 (13721-34-1) (2-21) 0 6mg/m^-STEL(l)(3)
Uranyl Sulfate, UO2SO4 (1314-64-3) (2-14) 0 05 mg/m^ - TWA8 (1)
0 2 mg/m^ - TWA8 (3)
0 6mg/m^-STEL(3)
Iron Oxide, Fe203 (1309-37-1) (0-2) 10 mgW, fume (1)
5 mg Fe/m^ fume (3)
Calcium Sulfate, CaS04 (7778-18-9) (0-4) 10 mgW - TWA8 (total)(3)
15 mg/m^ - TWA8 (total)(3)
5 mgW - TWA8 (respirable)(l)
Potassium Oxide, K2O (12136-45-7) (0-2) No PELS listed (1)(2)(3)(4)(5)
Sodium Sulfate, Na2S04 (7757-82-6) (0-5) No PELs listed (1)(2)(3)(4)(5)
Energy Fuels Resources (USA) Inc.
Inhalation Remove victim to fresh au: Give oxygen if breathing is difficult Call a physician promptly If
breathing has stopped, perform artificial respirations
Eyes Flush eyes promptly with large quantities of water for at least fifteen minutes If irritation is
present, see a physician promptly
NOTE TO PHYSICIAN
Treat poisoning with intravenous bicarbonate to facilitate lenal excietion Piompt administi ation
of EDTA enhances removal of uranium
(*)Failure to follow the precautionary measures recommended in Sections V, VI, VII, VIII and IX may result in overexposure
Section V Fire and Explosion Data
Combustibility Essentially non-combustible Flammable Limits Not applicable
Flash Pomt (Test method) Not applicable Autoignition Temperature Not applicable
Explosion Tendency None
Extinguishing Media No fire hazard
Special Fu-e-Fightmg Procedures Avoid procedures which may create dust When fighting a fire involving this
material, wear full protective equipment including positive-pressure breathing
apparatus Mimimze spread of water-borne solids
Unusual Fire and Explosive Hazard None
Section VI Reactivity Data
Stability Stable in air and water Soluble in HNO3 with formation of uranyl nitrate Soluble in HF/H2SO4
Decomposes m UO2 at 2372°F (1300°C)
Conditions to Avoid None
Hazardous Decomposition Products None See "Stability" for possible reaction products
Materials to Avoid None
Section VII Spill. Leak, and Disposal Information
Steps to be taken if Material is Spilled or Released Restrict persons not involved with cleanup from the area of the spill
until cleanup is completed Use HEPA dust collection or temporary cover, if available, to control the level of
airborne dust Use shovel, vacuum, or mechanical means to collect spilled material Avoid maneuvering with
compressed air or any other method which generates dust Cleanup personnel should wear skin and eye
protection and avoid the inhalation of dust by the use of appropriate respiratory protection Radioactive
materials license condition must also be followed
Neutralizing Agents None
Waste Disposal Method Steps to be taken if material is spilled or released This material contains ingredients which are
included m 40 CFR 302, Table 302 4, "List of Hazardous Substances and Reportable Quantities" This material
is a "low specific activity" radioactive regulated material and must be disposed of in accordance with Nuclear
Regulatory Commission, state and local regulations
Section VIII Special Protection Information
Ventilation Provide sufficient mechanical HEPA dust collection, combined with administrative controls, if
applicable and needed to keep exposures below the permissible exposure limit
Eye Protection Dust resistant safety glasses should be woin Facilities to flush the eyes with water should be
readily available
•
Energy Fuels Resources (USA) Inc.
FOR INDUSTRLM. USE ONLY
Precautions for handling and storage "Materizil should be stored in tightly closed containers and kept dry Eating
or smoking should not be permitted in areas where dust is present Avoid contamination of clothing with this
material and wash hands thoroughly with soap or mild detergent and water before eating, smoking, or using
toilet facilities
Other Precautions
Carcinogen Listings
National Toxicology Program Annual Report (NTP) Not Listed
International Agency for Research on Cancer (lARC) Not Listed
OSHA 29 CFR Part 1910, Subpart 2 Not Listed
Energy Fuels Resources (USA) Inc behoves that the data herein are current as of the
effective date of this data sheet and that the opinions herein are those of quahfied experts
Since the product and the information herein will be used outside the control of Energy Fuels
Resources (USA) Inc , it is the user's responsibility to estabhsh conditions for safe use
of the product The data herein relate only to the product of Energy Fuels Resources (USA) Inc
and may not be applicable for products of other manufacturers
WorkCentre 7346
Transmission Report
435 678 2224 Date/Time 09/10/2012 08 ISAM
Page 1 (Last Page)
Local Name Denison Mines
Logo White Mesa Mi I I Blanding Ut
Document has been sent
Document Size 8 5X11"SEF
^RSB LOGISTIC
wwwJtUogbticcoiii
RSBLOdSnCINC. 219 Ctiduul Oesxnl Sukato<iii,5K STL 7m
Pbone. 30S-^42-8300 Toll Ftea 80(l«S7-3934 Pm 306-242-2311
ATTACHMENTl
RE Energy Fuels Resources (USA) Inc.-Lot #88
Certfficataa o/S:qmt PiEng
THESE COMMODinES 'reCHNOLOOY OR SOFIWARE WERE EXPORTED FROM THB
UNTIEI) STATES IN ACCORDANCE WTFH THE EXPORT ADMINISTRAITON
REGULATIONS DIVERSION CONTRARY TO US LAWPROHEBrrED NOSED
REQtJIRED-AES-132637752-RFn62362.
AES UN X20120906034794
SASKAIOCHSK
Total Pages Scanned 6 Total Pages Sent 6
No Doc Remote Station Start Time Duration Pages Co n t e n t s
1 1319 705 2S2-1153 9-1O 8 15AM
Note RE Resend PG Pol I ing
SA Send Ag;
MB Send to Ma i I box RB Relay Broadcast EN Engaged
BC Broadcast RS Re I ay Send AS Auto Send
MP Mu I t I Po Ming BF Box Fax Forward TM Terminated
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0/7SB LOGISTIC Driver Routing Instruction
Product
Class:
Radioactive Material. Low Specific Activity. (LSA) n.o.s.
7 i/?vr# 2912
Shipper Denison Mhies, Blandmir. UT
Consignee- Cameco Blind River. ON
Freight Bill^: K036315
Trip #: 54947
Have you hauled this product before? O Yes O No
(If NO, call Safety Director immediately @ 306-242-8300)
SPECIAL INSTRUCTIONS:
1. Acknowledge receipt of 6 instruction sheets by initialing and faxing back to (306) 65) -0600.
2. No riders/passengers allowed during this trip.
3. Entire driver routing instruction package to be rehu-ned to RSB with trip paperwork.
4 Two load bars required.
5 Tractor Backup Alarm required.
6. Drivers MUST call ahead to Boarder Crossing @ 906-632-8822 ext. 272, advising of Radioactive load
7. Escorts required for International / Mackinac Bridge see Page 4 for instructions.
Please acknowledge that each of the following duties are completed by checking the appropriate circle
ACKNOW
INITIALS
''Safety Above Air
Please Remember.
When roads are poor, get
off the road Do not take
any chances with this load'
Ai The Shipper's: Enroute
O Confirm Product Description matches B/L
O B/L is complete & in compliance
O Placards on trailer before loading
O Spare placards received from shipper
O Spill Kit Complete
O MSDS sheets received from shipper
O Load is blocked and braced
O Trailer is sealed {Dnver mttst not break seal)
Seal Is trailer sealed with bolt seal?
O Tire checks (2 hours/100 miles)
O Placard check (2 hours)
O Stop at all railroad crossings
O Authorization required to unhook from trailer
O If disabled contact Saskatoon
O Do not travel if chains are required
Lock & Security Procetiures
Maintain awareness ofthe following
O Check trailer seal for tampermg
O Trailer must be seated upon deliveiy
O Secure tractor, shut off engine
O Do not leave keys inside tractor
O Keep unit visible when unattended
Q Check 5**' wheel and other equipment
O Mamtam regular contact via satellite or cellular
O Yes O No
Bid Customs Break Seal? O Yes O No
(If YES, call Dispatch immediately)
Customs Broker: Near North
Border Crossing: Sault Ste Marie. ON
New seal U
53809
Unit Signature
Fonn #036
Updated March 2012
Page 1
Date
Guide 162
Btonduig UT - Blind River ON
0RSB LOGIsfk Driver Routing Instrucmn
Product Radioactive Material, Low Specific Actmtv (LSA), n.o.s. Class. JL C/Ar# 2972
Shipper: Denison Mines. Blandmg. UT Consignee' Cameco Blind River. ON
In an Emergency, contact 911 or local authorities, then notify RSB (306) 242-$300.
The following route must be followed. Any deviations must be reported to RSB immediately to ensure regulatory and
customer compliance.
St/Prv Route Interchange Leg Total
UT North US-191 + US-191 Ramp 105 9 105,9
UT Right Ramp Ramp 1-70 0.3 106 2
UT East 1-70 (to UT/CO State Line) 49.1 155 3
CO East 1-70 + 1-70 Exit 87 86.5 241.8
CO Keep right Exit 87 + Exit 87 US-6 0,4 242 2
CO East US-6 + US-6 CO-13 35 245 7
CO North CO-13 (to CO/WY State Line) 127.9 373.6
WY North WY-789 Creston Junction, WY 53.2 426.8
WY North WY-789 + WY-789 Ramp 01 426 9
WY Right Ramp Ramp 1-80 a2 427,1
WY East 1-80 (to WY/NE State Line) 214.6 641.7
NE East 1-80 ^ 1-80 Ramp 102 743.7
NE Keep left Ramp Ramp 1-80 1.1 744.8
NE East 1-80 +1-80 Exit 446 341.3 10861
NE Keep right Exit 446 + Exit 4461-680 0.6 1086J
NE North 1-680 (to NE/IA State Line) 12.9 1099.6
IA East 1-680 - Merman Bridge Rd + 1-680 Exit 38 3.1 1102.7
lA Keep right Exit 36 + Exit 381-29 03 1103
IA North i-29 + 1-29 Exit 71 9.4 1112.4
IA Keep right Exit 71 + Exit 711-680 0.4 1112.8
IA East 1-680 +1-680 Exit 29A 15 9 1128.7
IA Straight Exlt29A + Exit 29A1-80 0.7 1129.4
IA East 1-80 +1-80 Exit 137B 109.6 1239
IA Keep left Exit 1378 + Exit 137B 1-35 06 1239.6
IA North 1-35 (to lA/MN State Line) 131.2 1370.8
MN North 1-35 +1-35 Exit 13A 12.9 1383.7
MN Keep right Exit 13A + Exitl3A 1-90 05 1384.2
MN East 1-90 (to MN/WI State Line) 115.1 1499.3
Wl East 1-90 +1-90 Exit 45 44 9 1544.2
Wl Keep left Exit 45 + Exit 451-94 0.6 1544.8
Wl West 1-94 +1-94 Exit 143 3 1547.8
Wl Keep right Exit 143 + Exit 143 WI-21 0.3 1548.1
Wl East WI-21 Tomah, Wl 08 1548.9
Wl East WI-21 Necedah, Wi 23.8 1572,7
Wl East WI-21 + WI-21 Ramp 76 8 1649.5
Wl Left Ramp Ramp US-41 0.2 1649.7
Wl North US-41 (to WI/MI State Line) 101.8 1751.5
Ml North US-41 Daggett, Mi 25 7 1777.2
Ml North US-41 US-41 53 2 1830.4
Page 2 Guide 162
Uodat^d March 2013
Page 2
Blandinc U f-Blind River ON
90/20"d \ZL3 0iS DUSI 301 esa 90:8T 3T0S-A0-d
@RSB LOGISTH^ Driver Routing Instr^on
Product Radioactive Material. Low Specific Acttvitv (LSA). n,os. Class. J_ IW# 2912
Shipper- Denison Mines. Blandmg. UT Consignee- Cameco Blind River, ON
St/Prv Route Interchange Leg Total
Mi East US-2 + US-2 MI-117 77 3 1907,7
Ml North Mi-117 + MI-117 MI-28 14.5 1922.2
Ml East MI-28 Newberry, Ml 8.1 1930.3
Ml East MI-28 + MI-28 Ramp 48.5 1978 8
Ml Left Ramp Ramp 1-75 0.4 1979.2
Ml North 1-75 +1-75 1-75 8.3 1987.5
Ml North International Brg -1-75 (to US/CA Country Line) 1.1 1988 6
ON North ON-17 B + ON-17 B ON-17 B 1.1 1989.7
ON East ON-17 B + ON-17 B ON-17 3.6 1993.3
ON East ON-17 + ON-17 Local 83.1 2076.4
ON Left Eldorado RO Blind River, ON 0.2 2076.6
Fonn #036
Updated-March 2012
90/£0'd lZi,S PPP 0iS
Page 3
01ISIson asd
Guide 162
Blandmg UT - Bluid River ON
i0 8T 2T02-i0-d3S
Bridge Crossing Procedures
INTERNATIONAL BRIDGE
- Escorts required for loads of Class I, loads in excess of 12' wide and loads in
excess of 144,000 lbs.
- Escorts are no charge
- Toll for 5 axle unit is $20.00 U.S. or $21.15 CDM
- To arrange for escort, if required:
-Northbound - call 906-635-5255, ext 0
-Southbound - call 705-942-4345, ext 0
MACKINAC BRIDGE (IF REQUIRED)
- Escorts required for ALL Hazmat (Placarded) loads,
- Escorts are no charge.
- Travel in right lane - min. 500 ft spacing
- Use 4-way flashers
- Maximum speed is 20 mph
- ToUis$4.50U,S./axle.
- To arrange for escort, if required.
o Northbound - Use phone at South end of bridge to call Bridge Authority
(exit 339)
o Southboimd - Stop at toll booth.
- Bridge Authority can be contacted at 906-643-7600.
Please contact the Saskatoon Safety Department if you
have any questions.
90/p0'd TEl.9 PPP 0iLZ 0I1SI901 aSd <L0:8T ZT0Z-LQ-d35
CARRIER'S INSTRUCTIONS
YOUR CARGO IS CALCINED PRODUCT
THIS MATERIAL:
1) Is NOT explosive.
2) Can be approached without danger. The amount of radiation is insignificant.
3) WiU not bum.
4) Should not be swallowed or put m mouth.
5) Should not be inhaled.
IN THE EVENT OF ACCIDENT, AS SOON AS POSSIBLE: ~
1) Take prefiminary precautions (below). DispUy these instructions as necessary to local authorities
on fhe scene to obtain their hdp.
2) Evaluate tiie situation, and record all pertinent infonnation.
3) CaD collect (or have local auffaorities call for you);
Cameco (705)3S6'14$6 Cameco Security .
BLIND RIVER, ONTARIO
If possible, have emi autiiority participate in caU.
4) Make no other statements or phone calls exc^t on.in5tnicttons 'firom Cameco or RSB Logistic, Inc.
PRELIMINARY PRBCAimONS -
A. .CONTAINERS ARE NOT LEAKING, and are not seriously.damaged. Containers may or may
not have been thrown from truck. Truck may or may not have been damaged^
1) Caution people not to tamper with the containers. Use dvil authorities to help you if necessaiy.
2) It is not necessaiy to have a specific distance between people and the container or the truck, but for
ease of controllixig the situation, ask people to stay bade 10 - 15 feet
3) If closed containers are l^ng on the right of way, obtain assistance from whatever dvil authority is
available to move containers to the side ofthe right of way.
4) Ensure local audiorides that there is no danger in handHng closed containers.
B. CONTAINERS ARE LEAKING OR DAMAGED TOO SERIOUSLY TO BE MOVED. Truck
may or may not have been damaged.
1) Caution people to stay away from the material. Keep them at a distance of at least 25 feet up wind.
Extreme distance is notiiecessary. Assure local authorities that there is no danger from radiation but
that people avoid inhaling any dust from the material.
2) This vehicle contains a box or dnim of emergency equipment such as plastic sheeting, stakes, nails,
respirators, etc. this material should be used to perform the foUowing steps:
a) Avoid trackage of material.
Keep material from running into streets, gutters, sewers, etc.
Prevent the material from being scattered by the wind.
b) ' Avoid inhaling dust from the material. When covering the material, use a respirator
C. FIRE INVOLVING THE TRUCX OR IN IMMEBJATE VICINITY OF TRUCHEC.
1) Isolate the truck from people and property if possible. Use civil authorities for help.
2) . Obtain fire fighting help from local groups. . .
3) Keep fire away, from calcined product containers if po^iHe.'
4) Use precautions to avoid inhaling smoke from any fire involviiig your cargo because of possibility of
airborne particles , " "
"90/S0-d TZLS PPP QLZ OliSIQOn aSd <L0:8T ZTQZ-L0-d3S
Radioactivo iyl(p:erial$ (Low to ModeraiHf Level Radiation)
POTENTIAL HAZARDS
Health • Radietion presents minimal risk to transpoit workers, emergency response personnel and the public during
transportation »iccidcnt9. Packaging durability increases as potential Aazardf of radioacuve conient increases.
• Undamagpd packages are safe. ConteniS of damaged packages may cause higher external radiation exposure, or
both external and internal radiation exposure if contents are released.
• Low radiation hazard when material is inside container If matenal is released from pacicage or bulk contamer,
hazffsd will vary hem low to moderate
• Level of hazard will dqsend on the ^^pe and amount of ladioactivity, the kind of matenal it is m, and/or die
sur&ces it is on.
• Some material may be released &om packages dunng accidents of moderate severity but risks to people are not
gceaL
• Released radioactive materials or contambated objects usually will be visible if packaging fails
• Some exclusive use shipments of bulk and i>adcaged materials will not have "RADIOACTTVB" labels Placards,
markings and shipping papers provide identificatian.
• Some packages may have a "RADIOACTIVE" label and a second hazard labeL The second hazard is usually
greater than the radiation hazard; so follow this GUIDE as well as ^e response GUIDE for the second hazard class
label.
• Some radioactive materials cannot be detected by commonly available mstruments
• Runoif irom control of cargo fire may cause low-level pollution.
Rrc» or • Some of these matenals may bum, but most do not ignite readily.
Explosion ^ Uranium and Thorium metal cuttings may ignite spontaneously if exposed to air (see GUIDE 136),
• Nitrates are oxidizers and may ignite odier combustibles (see GUIDE 141),
PUBLIC SAFETY
4 CALL Emarganey Response Telephone Number on Shj^ping Paper first If Shippiog Paper not available or no answer,
refer to appropriate telepboDO number listed at the ead of this section.
• Priorities for reseue^ Ufe^aving, flrst aid, fire control and other hazards are higher than the priority for measuring radiation levels.
• Radiation Authority must be notified of accident condiuons. Radiation Audiority is usually responsible for decisions about
radiological consequences and closure of emergencies.
• As an immediate precautionary measure, isolate spill or leak area for at least 25 meters (75 feet) in all directions, u Stay upwind. D Keep unauthonzed personnel away.
• Detain or isolate uninjured persons or equipment suspected to be contaminated,- delay dccontanunadon and cleanup until
instructions are received from Radiation Authority.
Pfolectlve • Positive pressure self-contained breathing apparatus (SCBA) and structural firefighters' protective clothing will Clothing provide adequate protection
Evacuation Large Spill
• Consider initial downwind evacuation for at least 100 meters (330 feet)
Fire
• When a lei:ge quantity of this material is involved in a major fire, consider an initial evacuation distance of 300
meters (IOOO feet) k all dnecLions
ErvJERGENCY RESPONSE
Fire • Presence of radioactive material will not influence the fire control processes and should not influence selection of techmques.
• Move containers from fire area if you can do it without risk.
• Do not move damaged packages; move undamaged packages out of fire zone
Small fire • Dry chemical, CQ-, water spray or regular foam.
Large Fire • Water spray, fog (flooding amounts # Dike fire-control water for later disposal.
Spill or • Do not couch damaged packages or spilled matenal
l^ak ^ Cover liquid spill with sand, earth or other non-combustible absoibent material
4 Dike to collect large liquid spills.
• Cover powder spill with plastic sheet or taip to minimize spreading.
Fiist Aid • Medical problems take priority over radiological concems,
• Use first aid treatment according to the nature ofthe mjury
• Do not dela^ care and transport of a seriously mjuied person.
• Give artificial respimtioo if victim is not breathing
• Administer oxygen if breathing is difficult.
• In case of contact with substance, wipe from skin immediately; flush skin or eyes with running water for at least 20
mmutes
• Injured persons contaminated by contact with released matenal are not a serious hazard to health care personnel,
equipment or facilities.
• Ensure that medical personnel are aware of the material(s) involved and take precautions to protect themselves and
prevent spread of contamination
© Danatec Educational Services Ltd.
90/90 "d IZiLS PPP QIZ
Excerpts from the 2004Eme/genqy Response Guidebook page 667
DUSI son aSd Z.0 ST ZT0Z-L^-63S
Date 5-Sep-12
YC lot 88 WWIVl Cameco Cameco Cameco,
Element: Analysis % Penalty Spec. % Surcharge
U3O8 96 79 0 00
8 0 74 1 00 4 00 0
As 0 03 0 05 0 15 0
Zr 0 00 0 10 0 50 0
Na + K 0 62 1 00 2 00 0
0 00 0 00 0 00
V 0 01 0 10 0 50 0
Mo 0 08 0 10 0 30 0
Fe 0 02 1 00 2 00 0
YC lot 88
Converter Surcharge $ cost $0,007 lbs Uadsl
Cameco 0 00 0 0000
Total lbs Total Ka
Gross 40,844 18,527
U3O8 39,209 17,796
U 33,255 15,086
Totals 0.00
Sign Off
Dan Hiilsten
Craig Barlow
UnrestrlctenRelease
Documentation
3
O
ENERGY FUELS RESOURCES (USA) INC.
DECONTAMINATION FINAL RELEASE
I have venfied that tractor NA and/or container
Tractor Number
11 [ has been checked for any contammation and has been
Container Number
authorized for final release.
— Radiation Technician 9 J | 5 / /
RadiationUeparttnent Title Date
R \radiation\Forms\decon doc
o
o
ENERGY FUELS RESOURCES (USA) INC.
DECONTAMINATION FINAL RELEASE
I have verified that tractor NA and/or container
, Tractor Number
G^Fh ') ODIO'^.S has been checked for any contamination and has been
Container Number
authorized for final release.
iAAJiX\\ Y^>-A.^\>.Z-.^ Radiation Technician 9 - / S ~ /
Radiation Department Title Date
R \radiation\Fonns\decon doc
1 Date ^rVZzyh Container ID Cj-^^\0CyOl^
Inside Locations
rgy Fuels Resources (USA) Inc.
quipment Survey for Unrestricted Release
Surveyed By %) :>7'>K p.fK.' k
Outside Locations
Front
19
L Side
13 14
23^^
15 16
RSide
7 8
22—^
9 10 11
1 2 3 4 5 6
20
Tailgate
Location #
Total
Alpha
dpm/IOOcm'
Removable
Alpha
dpm/IOOcm*
Beta
Gamma
1 t 0.1
2
3 I3S"C>
4 7Ao
5
6
7
8
9 I3S-0
10 00
11
12
13
14
15 135-T)
16
17
18 'N
19
Total
Atpha
Instrument
SN
Cal Date
:N5IOE
1.10
dpm/iOOcm'
Location
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
Rails
Total Removable
Alpha Alpha Beta
# dpnt/iOOcm* dpm/IOOcm* Gamma
^o> 1
to 1
to I
il// m
\ k
^^
w %
Y ho ol
Truck
and Tire Survey
1 0 0 2
3 00 004
5 00 OOe
Total Alpha/
Beta-Gamma
•ocatlon 1 cpm
It Truck Ext
Function Check (5x1 mm)
Til 230 @ 33000 dpm
Bkg Average _ %.0
Dpm Average _ */ i^?^
Efficiency 12 HO^
EfTFactor 9i Q
MDA
Removable alpha • 1000 dpm/IOOcm^
^ed alpha - 5000 dpm/1 OOcm^ average
15000 dpm/IOOcm^ maximum
Instrument Data
Removable
Alpha
Model
SN lH(»7gl
Cal Date L <^u«^.lf:
Function Check(5x1 mm)
Alpha Bkg Ave I 1
Alpha eff ^J^^fj^
Alpha Factor 1^
TRAILER TIRES
7 00 0 08
9 00 OO10
11 00 OO12
Total Alpha/
Beta-Gamma
Location cpm
Total
Beta/Gamma
Model #
SN
Cal Date
Source
Reading
Bkg
10
11
cs {"^1 ~ Chassis Ext
^ OMTfltr
O'o3
3!
Comments
>
Beta - Gamma - 0 2 mr/hr @ 1cm average
1 0 mr/hr @ 1cm maximum
o
o
o
ENERGY FUELS RESOURCES (USA) INC.
DECONTAMINATION FINAL RELEASE
I have verified that tractor NA and/or container
Tractor Number
OO [I ^0 has been checked for any contamination and has been
Container Number
authorized for final release
Radiation Technician
Radiation Department Title Date
R \radiation\Forms\decon doc
1
Equ
Date 3L11IV^ Container ID <9 1 \ ^ Q
Location i
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
Total
Alpha
Inside Locations
irgy Fuels Resources (USA) Inc.
quipment Survey for Unrestricted Release
Surveyed By TusV>v. "^^VCiKla.
Outside Locations
Front
19
L Side
13 14
7 8
1 2
2a ^
15 16
22
9 10
3 4
RSide
11
5 6
20
Tailgate
Total
Alpha
dpm/IOOcm*
Removable
Alpha
dpm/IOOcm*
Beta
Gamma
r
f ^ 1
w. / /k-\ / ^ f
CS'?
28
fcoTtor^
dpm/1 OOcm*
Location i
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
Rails
27
^ Oft
Front
37 29 27
^ Oft
34
-—-36 7
31 25 V 7
31
Total
Alpha
dpm/IOOcm*
24
Removable
Alpha
dpm/IOOcm*
Beta
Gamma
1
J
A /
/
\ \ to 1 1 1 1
f % 1 \ 1
Truck
and Tire Survey
>UTSIO£
LXO
1 0 0 2
3 00 004
5 00 OOe
Total Alpha/
Beta-Gamma
•ocatton i cpm
Tmck Ext 3z:
Instrument Data
TRAILER TIRES
7 00 OOe
9 00 O0io
11 00 O0i2
Total Alpha/
Beta-Gamma
Location cpm
Instrument
SN
Cal Date
Function Check (5x1 mm)
Th 230 @ 33000 dpm
Bkg Average ^.Q
Dpm Average__tj^kg^_
Effiaency 1'^")%
Eff Factor
MDA lil
Removable alpha -1000 dpm/IOOcm'
p alpha - 5000 dpm/IOOcm'average
^ ' 15000 dpm/1 OOcm' maximum
Beta - Gamma - 0 2 mr/hr @ 1cm average
10 mr/hr @ 1cm maximum
/Removable
Alpha
Model
SN
Cal Date
Function Check(5x
Alpha Bkg Ave
Alpha eff
/\lpha Factor
1 mm)
Total
Beta/Gamma
Model*
SN
Cal Date
Source
Reading
Bkg
Y12
Cs Ml Chassis Ext
10
Mi
Comments
Weekly facility Snivoys
White Mesa Mill Weekly Alpha Survey
Date: 9-/^-/^
Technician: f^eafl Z^fA^
Alpha Survey Instruments
Fixed
IVIodel#: 3
Serial #. ]?S5gl
Calibration: 11
Efficiency: 1^.^%
Factor* 7.^
Background: 3^
MDA: jg|
Removable
Model #: 55^^
Serial #: 1153^
Calibration: lOfkl^J^
Efficiency:
Factor- 3.9
Background: Z^-?
MDA: 73. gy
Notes:
All fixed readings are in dpm/100 cm
T or t = Total or Fixed Alpha Reading in dpm/100 cm^
R or r = Removable Alpha Reading per swipe or filter (approximately 100 cm^)
RSO Reviewed:
RSO Comments: 44
Maintenance and Warehouse Areas
^\etjr
^ oof
/^/3-*
Foreman'j
Office deik
Elect
Foreman's
Warehous
e Office
Instrument
Warehouse
supply Office
pe/k
Maintenance
Operatian
Foreman s
Office
Operation
Foreman s
tjffice
•plow
fl oo»*
Survey-Alpha
Date 'i-IA-ia
3 Inst
Cal Date _A7^
SN /J?5S'7
Tech
All units m dpm/100 cm
Change/Lunch Room
IVIen's Locl<er Room
Women's Locl<er Room
Sliower
f^or^< ro«*^
Laundry
Room
Table
-floor
Survey-Alpha
Date ^'19-^13^
Inst
Table
4
Cal Date /7/?Mg
All units in dpm/100 cm^
iikJU
T^^lo
Luncli Room
Table
Scalehouse
Restroom
pi cor
Table
Survey-Alpha
Date ?'/3
Inst 3
Cal Datt
Tech
All units m dpm/100 cm
Central Control Room
Table
Table
Survey-Alpha
Date 9-/3'/<2
Inst 3
Cal Date /7/?y /3
Tech Mi
All units in dpm/100 cm Table X'^)^
b
EMPLOYEE SPOT ALPHA CONTAMINATION SURVEY
DATE 1 NAME BOOTS CLOTHES HANDS COMMENTS
9'/3'/a J
Tfre.f P««-l2y
m
T
\
j
covc^r^lf^
Alplia Instrument Information
instrument iViodei 3
Instrument SN 1^3(^1
Th23o Source SN S^i'O^
DPM 39006 CPIVi
Efficiency Efficiency Factor 7.4
ReleasePneeauns
No PBL-2
Rev No • R-3
Date July 25,2002
INTERNATIONAL URANIUM (USA) CORPORATION
STANDARD OPERATING PROCEDURES
Title Intermodal Container Acceptance, Handling & Release
Page 1 of7
LO Purpose
The follovvdng procedure applies to acceptance, handling, and release of intermodal
containers from International Uranium (USA) Corporation (lUSA) White Mesa Mill
(Mill). lUSA receives matenal for processing, in either bulk or non-bulk packagmg
This procedure addresses one form of bulk packaging - intermodal containers (IMCs)
This procedure may be amended, subject to approval by lUSA's Safety and
Enviromnental Review Panel (SERP), from time to time as appropriate to address the
individual requirements of specific feed materials, or projects
2.0 Ore Receiving
1. Check truck scale for zero balance at the beginmng of each shift
2. Inbound IMCs will be dropped off m a designated staging area near the Scale
House outside the Restncted Area
3 Inspect the inbound IMC for the items hsted on the Intermodal Container
Inspection Form (copy attached) Notify Mill management of any discrepancies
as soon as practicable The Intermodal Container Inspection Forms will be
turned in to tiie Mill office on a daily basis
4 Inspect all copies of the Bill of Lading (BOL) to ensure that the shipment is
destined for the White Mesa Mill and that all shippmg documentation is in order
(see Section 8 2) If any discrepancies are noted notify the Mill management
immediately. Do not dump the container until all paperwork discrepancies
are corrected.
5 Assign next available shipment number and White Mesa Mill load number to the
inbound IMC Record the White Mesa Mill load number, mboimd date and both
tiie truck and IMC numbers on the Scale house Weight Ticket (SWT).
6 A White Mesa tmck will be used to retneve the loaded IMCs stored m the
staging area, outside the Restricted Area, and transport them into the Restricted
Area The Mill truck will be visually inspected and scanned prior to leavmg the
Restricted Area to pick up a loaded IMC
3.0 Ore Dumping
i
1 Prior to the dumping of the IMC the tarp and tarp support structures, if applicable,
are inspected for damage and then removed
2 Connect the Bartlett tipper to the loaded IMC chassis and transport across the
truck scales.
P \Adrmn\Master SOPs\Book lO^PBL Sops\PBL-2 IMC SOP Rev3 (08 07 02) doc
No PBL-2
Rev No. R-3
Date July 25,2002
INTERNATIONAL URANIUM (USA) CORPORATION
STANDARD OPERATING PROCEDURES
Title Intermodal Contamer Acceptance, Handling & Release
Page 2 of7
3 Enter tiie loaded weight of tiie IMC on tiie IMC SWT.
4 After weighing the IMC, proceed to the tarping and untarping station. Inspect the
tarp then roll the tarp forward. Report the conditions of the tarp and bows ofthe
IMC to the Scalehouse via radio. Then proceed to the designated ore storage area
and dump the material.
5 After dumping the material, retum the IMC back to the taipmg station and replace
the tarp and the bows, unless the IMC is being decontaminated for unrestncted
release.
6 After the IMC has been retarped, transport the empty IMC back across the scales
for an empty weight
7 Record the empty weight on the appropnate IMC SWT
8 At the end of each day, tum in outbound SWT to Mill Records Manager.
9 , The Mill Records Manager will fill out a Daily Materials Receipts form to obtain
the net weight of the material in each IMC
10. After weighing the IMC, the Bartlett tipper will deposit the IMC in a designated
area, within the Restncted Area, for decontaimnation.
11 Use a front-end loader or similar equipment to push material into the designated
ore lot pile
12 Once an ore lot pile is complete, label the pile with the appropriate • ore lot
number
4.0 Decontamination and Release of IMCs
All IMCs, chassis and tires will be decontaminated after dumping prior to leaving
the White Mesa Mill Generators or transporters will notify lUSA whether a specific
IMC and chassis is to be released for restricted or unrestricted use Any IMCs that are to
be released for restricted use will be decontaminated 'according to the requirements
contained in U.S Department of Transportation (DOT) Part 49 CFR 173 441 and
173 443 (a copy of which is attached) Any IMCs that are to be released for unrestricted
use will be decontammated according to the requirements found m Table 1 of the Nuclear
Regulatory Commission's (NRC's) Policy and Gmdance Directive FC-85-23,
"Guidelines for Decontamination of Facilities and Equipment Prior to Release for
Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear
Material" issued May 1987 (a copy is attached)". IMCs requiring repair will be
decontaminated for unrestncted release, to facilitate repairs by the transporter at the
P \Admin\Master SOPs\Book 10_PBL Sops\PBL-2 IMC SOP Rev3 (08 07 02) doc
No PBL-2
Rev No.. R-3
Date. July 25,2002
INTERNATIONAL URANIUM (USA) CORPORATION
STANDARD OPERATING PROCEDURES
Title. Intermodal Container Acceptance, Handling & Release
Page 3 of 7
transporter's own site IMCs may be repaired without undergoing full decontamination if
repaired within the Restricted Area of the Mill
5.0 Decontamination and Release of IMCs for Restricted Use
1. A White Mesa Mill truck mil pick up the empty IMC, from the staging area
within the Restricted Area, and transport it to the decontamination pad.
2 Decontammate the exterior of each IMC, chassis and tires thoroughly, using a
high-pressure water wash Put the chassis into the extended position to improve
access to the rear chassis tires.
3 After the IMC is decontaminated, use the White Mesa Mill truck or other
designated on-site equivalent equipment to move the IMC along the
decontamination route. The decontamination route is a graveled roadway
specifically designed for decontaminated equipment to exit the restricted area Do
not leave the decontamination route. If it becomes necessary due to
environmental conditions or residual mud in the tires etc., proceed along the
decontamination route to the secondary wash station. Wash any visual residual
mud off of the tires, chassis or exterior surface of the container.
4 Proceed along the decontamination route to the tertiary decontamination and final
scanmng area.
5 Contact a Radiation Technician to perform a radiological contamination survey of
the IMC If the Radiation Techmcian indicates select areas on the IMC that
require further decontamination, decontammate those areas as necessary.
6 The Radiation Technician or RSO will scan the IMC, chassis, tires and White
Mesa Mill track in various locations as shown on the IMC Container Survey for
Restricted Release (attached) and document the scan readings on the Container
Survey for Restncted Release. The contamination survey will be performed using
appropnate radiological instrumentation for total activity in accordance with DOT
transportation regulations The release standards to be met for restricted release
are contained in U.S. Department of Transportation (DOT) Part 49 CFR 173 441
and 173.443 (a copy of which is attached)
7 If the IMC, chassis or tires do not meet the radiological release survey
requirements or shows visually observable contaminaton, the IMC will either be
returned to the secondary decontamination pad for further decontamination or will
be washed again at the tertiary decontamination area
8 The Radiation Techmcian or RSO will fill out the IMC survey for Restncted
Release form (copy attached) to document that the IMC has been authorized for
release for restncted use. These forms are filed in the Radiation Department The
P \Admin\Master SOPs\Book 10_PBL Sops\PBL-2 IMC SOP Rev 3 (08 07 02) doc
No PBL-2
Rev No.. R-3
Date July 25,2002
INTERNATIONAL URANIUM (USA) CORPORATION
STANDARD OPERATING PROCEDURES
Title Intermodal Contamer Acceptance, Handling & Release
Page 4 of7
Radiation Techmcian or RSO will place a white sticker on the IMC that says,
"EMPTY" and "This package conforms to the conditions and limitations specified
m 49 CFR 173 428 for radioactive material, excepted package - empty package,
9 After an IMC has been released, the IMC will be delivered by a White Mesa Mill
truck to the designated staging area for empty IMCs, outside the Restricted Area
After staging a loaded IMC in the designated area, the incoming driver will pick
up an empty IMC at the designated area Prior to leaving the staging area the
chiver will perform a visual inspection of the IMC, chassis and tires Leaving his
tmck outside of the Restncted Area, the driver will retum to the Scale House to
pick-up the documentation for the empty IMC and sign the Intermodal Container
Inspection Form
10 A Radiation Techmcian, or the RSO, will scan the designated decontamination
route and staging area(s) on a quarterly basis. The survey readings will be
recorded and kept on file in the Radiation Department
6.0 Decontamination and Release of IMCs for Unrestricted Use
1 A White Mesa Mill tmck will pick up the empty IMC, from the staging area
within the Restricted Area, and transport it to the decontaminaton pad.
2 Open the tailgate and decontaminate each IMC usmg a high-pressure water wash
Make sure to thoroughly wash the inside and outside of each IMC, the chassis and
tures
3. After the IMC is decontaminated, use the White Mesa Mill truck or other
designated on-site equivalent equipment to move tiie IMC along the
decontamination route. The decontamination route is a graveled roadway
specifically designed for decontaminated equipment to exit the restricted area Do
not leave the decontamination route If it becomes necessary due to
envuronmental conditions or residual mud m the thes etc, proceed along the
decontammation route to the secondary wash station Wash any visual residual
mud off of the tires, chassis or exterior surface of the contamer. Otherwise,
proceed along the decontamination route to the tertiary decontamination and final
scanning area
4 Contact a member of the Radiation Department staff to conduct the appropriate
radiological survey of the IMC, chassis, tures and White Mesa Mill tmck, as
delineated in Section 2 6 of the White Mesa Mill Radiation Protection Manual
The release standards to be met for unrestricted release are contained in Table 1 of
the Nuclear Regulatory Commission's (NRC's) Policy and (juidance Directive
FC-85-23, "Guidelines for Decontamination of Facilities and Eqmpment Prior to
P \Admin\Master SOPsVBook 10_PBL Sops\PBL-2 IMC SOP Rev3 (08 07 02) doc
(
No PBL-2
Rev No. R-3
Date: July 25,2002
INTERNATIONAL URANIUM (USA) CORPORATION
STANDARD OPERATING PROCEDURES
Title Intermodal Container Acceptance, Handling & Release
Page 5 of 7
Release for Unrestricted Use or Termination of Licenses for Byproduct, Source,
or Special Nuclear Material" issued May 1987 (Copy attached).
5 The Radiation Technician will perform a radiological contamination survey of the
IMC If the Radiation Technician indicates select areas on the IMC that require
further decontamination, decontaminate those areas as necessary.
6. If the IMC, chassis or tires do not meet the radiological release survey
requirements and/or has visually observable contamination, the IMC will either be
returned to the secondary decontamination pad for further decontamination or will
be washed again at the tertiary decontamination area.
7 If the IMC, chassis and tires meet the radiological release survey and visual
inspection requirements, the Radiation Technician will place a red sticker on the
/ IMC tiiat says, "THIS CONTAINER HAS BEEN FULLY
DECONTAMINATED AND SURVEYED FOR "UNRESTRICTED USE" BY:
(FILL IN NAME OF RADIATION TECHNICIAN)" The RSO or Radiation
Technician that perfonned the release survey will then sign the red sticker and
date h In addition, the RSO or Radiation Techmcian will fill out a
Decontamination Final Release Form (a copy of which is attached) to document
that the IMC has been cleared for unrestricted release. The form includes a
schematic diagram of the IMC with points to be scaimed and locations on the
schematic to fill in survey values for each IMC. The Decontamination Release
Form will be turned in to the Mill Administration Office daily for filing and
distnbution
8 After an IMC has been released, the IMC will be delivered by the White Mesa
Mill truck to the designated staging area for empty IMCs, outside the Restricted
Area After staging a loaded IMC in the designated area, the incoming dnver will
pick up an empty IMC at the designated area Prior to leaving the staging area,
the driver will do a visual mspection of the IMC, chassis and tires Leaving his
tmck outside of the Restricted Area, the driver will retum to the Scale House to
pick-up the documentation for the empty IMC and sign the Intemiodal Container
Inspection Form
7.0 Hazard Identification and Safety
7 1 Required Persormel Protective Equipment (PPE)
In all areas of the Mill covered by this procedure, hard hats, safety glasses and
steel-toed shoes are reqmred as a minimum. These must be worn in all areas of
the Mill witii the exception of the Administration Building
P \Admin\Master SOPsNBook 10_PBL Sops\PBL-2 IMC SOP Rev3 (08 07 02) doc
No PBL-2
Rev No.. R-3
Date July 25,2002
INTERNATIONAL URANIUM (USA) CORPORATION
STANDARD OPERATING PROCEDURES
Title Intermodal Container Acceptance, Handling & Release
Page 6 of7
7 2 Industrial Hazards and Safety
1 Use caution when chassis are backing onto the Ore Pad
2. Ensure that all persormel within 50 feet of the area where the IMC is hooked up to
the Bartlett tipper are aware that dumping is about to commence.
3. Bartiett tipper operators must use caution during the dumping process. Move at
least 25 feet away from the rear of the IMC during the imUal dumping operation.
4 Do not place any part of your body inside the IMC when the chassis is being
tipped and the tailgate is open. The IMC could be lowered or accidentally fall at
any time, which would cause the tailgate to close rapidly and result in injury.
Only work under the tailgate after it has been properly blocked open.
5 Be aware of high-pressure wash water.
6 When the crane is in operation, make sure all persormel, except the persons in
charge of the tag lines, are 50 feet away from the IMC bemg moved The persons
m charge of the tag lines should never be underneath the IMC that is being
moved
7. Be aware of slippery conditions on the ore pad during periods of inclement
weather
8 Be aware of the potential for ice bmld-up on and around the decontamination pad
during penods of cold weather.
9. Use caution when entering or exiting eqmpment Be sure to use the ladders and
hand rails Do not jump off of the equipment.
10 Always use a ladder when entering and/or exiting the interior of an IMC
8.0 Paperwork Tracking
1 Each IMC will have a umque sequential project number assigned to it at the
generating facility This number will be entered onto the Bill of Lading (BOL)
and attached to the IMC prior to shipment from the generation site
2 Upon arrival at the White Mesa Mill, the tmck driver will tum m all of his/her
paperwork to the Scale House operator who will verify tiiat the BOL number,
IMC number and project number assigned to.the shipment match on all copies of
the BOL The Scale House operator will also verify that tiie actual IMC number
matches tiie BOL IMC Number If there are any discrepancies in any of the
numbers notify Mill management immediately. Only origmal paperwork will
P \Admin\Master SOPs\Book 10_PBL Sops\PBL-2 IMC SOP Rev3 (08 07 02) doc
r
INTERNATIONAL URANIUM (USA) CORPORATION
STANDARD OPERATING PROCEDURES
Title Intermodal Contamer Acceptance, Handling & Release
No. PBL-2
Rev No R-3
Date July 25,2002
Page 7 of7
be accepted. If the original paperwork does not come vsdth the IMC, notify Mill
management immediately. The Scale House operator will sign the BOL,
acknowledging receipt of the material at the Mill, if all of the paperwork is m
order Depending on contractual and/or sampling requirements, final acceptance
or rejection of certain altemate feed materials may be contingent on analytical
results.
Each IMC will be transported across the scale at the Mill pnor to and after being
unloaded The appropnate information will be entered into the project database
All copies of the SWTs and BOLs will be forwarded to the Mill Records Manager
on a daily basis or other frequency specified by Mill Management, from time to
time
The Mill Records Manager will compile and reconcile the BOL's and SWTs for
distribution. The accounting department will forward a summary of all receipts to
the International Uranium corporate office and the generator of the matenal at
least twice monthly, or at other frequencies as determmed for the specific project
P \Admin\Master SOPs\Book lO^PBL Sops\PBL-2 IMC SOP Rev3 (08 07 02) doc
INTERNATIONAL URANIUM
WHITE MESA MILL
INTERMODAL CONTAINER INSPECTION FORM
Number
Container Number
Chassis Number
1 Correct Paperwork
2 Decontaminated
3 Tarps
4 Tarp Tie Downs
5 Tarp Support Bows
6
Bow Attachment
Brackets
7 Lifting Lugs
8 Structural Damage
9 Latch Mechanisms
10 Tires
11 Mudflaps
Additional Comments
Date
lUC
Driver&Trk Num.
incoming Outgoing
INTERNATIONAL URANIUM (USA) CORPORATION
DECONTAMINATION FINAL RELEASE
I have venfied that tractor NA and/or container
Tractor Number
has been checked for any contammation and has been
Contamer Number
authorized for final release
Radiation Technician
Radiation Department Title Date
C \windows\TEMP\decon SOP doc
International Uranium (USA) Corporation
Intermodal Container Survey for Restricted Release
Oate Container ID
Ashland or Linde
Surveyed By
Outside Locations
Lccatlon#
24
25
26
27
28
29
30
31
32
33
34
35
36
37
Rails
Instrument Data
Total Alpha/
Beta/Gamma
Model #
SN
Cal Date
Source
Efficiency
Total Alpha/
Beta-Gamma
cpm
lUSA Truck
and Tire Survey
0 0
0 0 00
00 00
Tota! Alpha/
Beta-Gamma
^9caHpn| cpm
1
2
3
4
5
6
Truck Ext
IMC CHASSIS TIRES
00 00
00 00
00 00
Total Alpha/
Beta-Gamma
Location # cpm
7
8
9
10
11
12
Chassis Ext
ASH2(b)
Date:
Location #
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
international Uranium (USA) Corporation
Intermodal Container Survey for Unrestricted Release
Container ID
Inside Locations Ashland or Linde
Front
19
L Side
13 14
V 23
15 16
RSide
17 18
7 8
22
9 10
21
11 12
1 2 3 4 5 6
20
Tailgate
Total
Alpha
dpm/IOOcm*
Removable
Alpha
dpm/IOOcm*
Surveyed By.
Outside Locations
dpm/1 OOcm*
Location #
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
Rails
Total Removable
Alpha Alpha
dpm/IOOcm* dpm/IOOcm*
f «ny location exceeds 1000 dpm/100 cm2 total alpha a swear/wipe survey for removable alphe must be performed
}wever additional removabia apB» swipes although not required may be performed
Instrument Data
Total
Alpha
Instrument ESP-1 / AC-3
SN 02299 / 1
02286 / 2
Cal Date
I ' Function Check (5x1 mm)
r/> 230 ©30300 dpm
Bkg Average
Dpm Average
Removable
Alpha
Model
SN
Cal Date
Function Check(5x1 min)
Alpha Bkg Ave
Alpha eff*
Alpha Factor
Total
Beta/Oamma
Model #
SN
Cal Date
Source
Efflclency
lUSA Truck
and Tire Survey
1 0 02
3 00 004
5 00 OOe
Total Alpha/
Beta-Gamma
-pcatloin ( cpm
1
Truck Ext
IMC CHASSIS TIRES
7 00 O08
9 00 O0io
11 00 O0i2
Total Alpha/
Beta-Gamma
Location I cpm
10
11
12
Chassis Ext
ASH2(a)
UocummtKetnevai nnp.//inveDgBieaccessgpogov/cgfouv^. wiiii^c-^y«er/\n.i'^i/j«dcv^iiun-^itti tra-ic
[Code of Federal Regulations]
[Title 49, Volume 2, Parts 100 to 185]
[Revised as of October 1, 1999]
From the U.S. Goverimient Printing Office via GPO Access
[CISE: 49CEm73.441] ^ ^
^ [Page 582-583]
TITLE 49~TRANSPORTATION
CHAPTER I—RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION, DEPARTMENT OF
TRANSPORTATION ^
PART 173—SHIPPERS—GENERAL REQUIREMENTS FOR SHIPMENTS AND PACKAGINGS—Table of Cont
Subpart I—Class 7 (Radioactive] Materials
Sec. 173.441 Radiation level limitations.
(a) Except as provided in paragraph (b) of this section, each
package of Class 7 (radioactive) materials offered for transportation
must be designed and prepared for shipmerit, so that under conditions
normally incident to transportation, the radiation level does not exceed
2 mSv/hour (200 mrem/hour) at any point on the external surface of the
package, and the transport index does not exceed 10.
[[Page 583]]
(b) A package which exceeds the radiation level limits specified in ^
paragraph (a) of this section must be'transported by exclusive use
shipment, and the radiation levels for such shipment may not exceed the
following during transportation:
(1) 2 mSv/h (200 mrem/h} on the external surface of the package
unless the following conditions are met, in which case the limit is 10
mSv/h (1000 mrem/h):
(1) The shipment is made in a closed transport vehicle;
(ii) The package is secured within the vehicle so that its position
remains fixed during transportation; and
(iii) There are no loading or unloading operations between the
beginning and end of the transportation;
(2) 2 mSv/h (200 mrem/h) at any point on the outer surfaces of the
- vehicle, including the top and underside of the vehicle; or m the case
of a flat-bed style vehicle, at any point on the vertical planes
projected from the outer edges of the vehicle, on the upper surface of
the load or enclosure if used, and on the lower extemal surface of the
vehicle;
(3) 0.1 mSv/h (10 mrem/h) at any point 2 meters (6.6 feet) from the
outer lateral surfaces of the vehicle (excluding the top and underside
of the vehicle); or in the case of a flat-bed style vehicle, at any
point 2 meters (6.6 feet) from the vertical planes projected by the
outer edges of the vehicle (excluding the top and underside of the ,
vehicle); and
(4) 0.02 mSv/h (2mrem/h) in any normally occupied space, except that
this provision does not apply to carriers if they operate under the
provisions of a State or federally regulated radiation protection ^
program and if personnel under their control who are in such an occupied
space wear radiation dosimetry devices.
(c) For shipments made under the provisions of paragraph (b) of this
section, the offeror shall provide specific written instructions for
maintenance of the exclusive use shipment controls to the carrier. The
' instructions must be included with the shipping paper infonnation. The
instructions must be sufficient so that, when followed, they will cause
the carrier to avoid actions that will unnecessarily delay delivery or
unnecessarily result in increased radiation levels or radiation
exposures to transport workers or members of the general public.
WAIS Document Retneval httpy/frwebgate access gpo gov/cgi-bin/a. imrLE«49&PAR'I^173&SECTION«441&TYPE«^
(d) Packages exceeding the radiation level or transport index
prescribed in paragraph (a) of this section may not be transported by
aircraft.
[Amdt. 173-244, 60 FR 50307, Sept. 28, 1995, as amended at 63 FR 48568, '
Sept. 10, 1998]
WAIS Dooument Retneval http //fnvebgate access gpo.gov/cgt-bin/g. i?TITLE'=49&PART°173&SECTZON'>443&TYPE-lH
[Code of Federal Regulations]
[Title 49, Volume 2, Parts 100 to 185]
[Revised as of October 1, 1999]
From the U.S. Government Printing Office via GPO Access
[CITE: 49CFR173.443]
[Page 583-584]
TITLE 49—TRANSPORTATION
CHAPTER I—RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION, DEPARTMENT OF
TRANSPORTATION
PART 173—SHIPPERS—GENERAL REQUIREMENTS FOR SHIPMENTS AND PACKAGINGS—Table of Cont
Subpart I—Class 7 (Radioactive) Materials
Sec. 173.443 Contamination control.
(a) The level of non-fixed (removable) radioactive contamination on
the external surfaces of each package offered for transport must be kept
as low as reasonably achievable. The level of non-fixed radioactive
contamination may not exceed the limits set forth in table 11 and must
be determined by either:
(1) Wiping an area of 300 square centimeters of the surface
concerned with an absorbent material, using moderate pressure, and
measuring the activity on the wiping material. Sufficient measurements
must be taken in the most appropriate locations to yield a
representative assessment of the non-fixed contamination levels. The
amount of radioactivity measured on any single wiping material, when
averaged over the surface wiped, may not exceed the limits set forth in
table 11 at any time during transport; or
(2) Using other methods of assessment of equal or greater
efficiency, in which case the efficiency of the method used must be
taken into account and
[[Page 584]]
the non-fixed contamination on the external surfaces of the package may
not exceed ten times the limits set forth in table 11, as follows:
Table 11—Non-Fixed External Radioactive Contaraination-Wipe Limits
Maximum permissible limits
Contaminant
Bq/cm<SUP>2</SUP> uCi/cm<SUP>2</SUP>
Beta and gamma emitters and low toxicity 0.4 10<SUP>-5</SUP> 22
alpha emitters
All other alpha emitting radionuclides.. 0.04 10<SUP>-6</SUP> 2.2
(b) Except as provided in paragraph (d) of this section, in the case
of packages transported as exclusive use shipments by rail or public
highway only, the removable (non-fixed) radioactive contamination on any
package at any time during transport may not exceed ten times the levels
prescribed in paragraph (a) of this section. The levels at the beginning
of transport may not exceed the levels prescribed in paragraph (a) of
this section.
(c) Except as provided in paragraph (d) of this section, each
transport vehicle used for transporting Class 7 (radioactive) materials
as an exclusive use shipment that utilizes the provisions of paragraph
(b) of this section must be surveyed with appropriate radiation
detection instruments after each use. A vehicle may not be returned to
service until the radiation dose rate at each accessible surface is
iVAIS Document Retrieval httpy/rrwebgatcaccess gpo.gov/cgi-bin/g. .nBn.E-49&PART"I73&SECTION'M43&TVPE-TE:
0.005 roSv per hour (0.5 mrem per hour) or less, and there is no
significant removable (non-fixed) radioactive surface contamination as
specified in paragraph (a) of this section.
(d) Paragraphs (b) and (c) of this section do not apply to any i
closed transport vehicle used solely for the transportation by highway
or rail of Class 7 (radioactive) material packages with contamination
levels that do not exceed 10 times the levels prescribed in paragraph
(a) of this section if—
(1) A survey of the interior surfaces of the empty vehicle shows
that the radiation dose rate at any point does not exceed 0.1 mSv per
hour (10 mrem per hour) at the surface or 0.02 mSv per hour (2 mrem per
hour) at 1 meter (3.3 feet) from the surface;
(2) Each vehicle is stenciled with the words ^^For Radioactive
Materials Use Only" in letters at least 76 millimeters (3 inches) high
in a conspicuous place on both sides of the exterior of the vehicle; and
(3) Each vehicle is kept closed except for loading or unloading.
[Amdt. 173-244, 60 FR 50307, Sept. 28, 1995, as amended by Amdt. 173-
244, 61 FR 20753, May 8, 1996]
06/14/2000 II-nAI
GIIIOFL'NES FOR DECOKWINATrPN OF FACILITIES ANO EQUlPHm
PRIOR TO RELEA:E FOR UNRESTRICTED USF
CP TERMINATION OF LICENSES FOR BYPRODUCT, SOURCF,
OR SPECIAL NUCLEAR MATERIAL
c^j, U.S. Nuclear Regulatory Conwlssion
Division of Fuel Cycle, Medical, Academic,
and Conwerclal Use Safety ' Wasfilngton, DC 20555
May 1987
t
J '
Thp instructions in this cu'de, in conjunction wUh Tjble I, specfv t^p
rad^nnuclides and radiation exposure rotp Hmits which should be 'i^ed In
dPcontaF'*ndtion and survey of sfr'aces or prenises and pcuipment pnor to
abandonment or release Vr unrestr'.rted use. The limits m TeMe 1 do not
apply to premises, equipment, or scrap containing induced radioactivity for
which the radiological considerations pertinent to their use may be
different. The release of such facilities or items from regulatory ccntrol is
cmsidered on a case-by-case.
1.
4.
The licensee shi»ll malte a reasonable effort to eliminate resic^ual
contamination.
Radioactivity on pqulpnent or surfaces shall not be covered by paint,
plating, or other covering material unless tontamination levels, as
determined by a survey and documented, are below the limits specified in
Table 1 prior to the application of the covering. A reasonable effort
must be made to minimize the contamination prior to use of any covering, ^
The radioactivity on the interior surfaces of pipes, drain lines, or
ductwork shall be determined hy making measurements at all traps, and
other appropriate access points, provided that contamination at these
locations Is likely to be representative of contamination on the inteno
0^ the pipes, drain lines, or ductwork. Surfaces nf premises, eou
or scrap which are likely to be contaminated but are of such size. 1.
construction, or location as to make the surface inaccessible for purposes
of measurement shall be presumed to be contaminated in excess of the limits
Upon request, the Conmlsslon may authorize a licensee to relinquish
possession or control of premises, equipment, or scrap having surfaces
contaminated with materials in excess of the limits specified. This may
include, but would not be limited to, special circumstances such as razinq
of buildings, transfer to premises tn another organization cnntinuing work
with radioactive materials, or conversation of facilities to a long-term
storage nr standby status. Such requests must:
a. Provide detailed, specific information describing the premises,
equipment or scrap, radioactive contaminants, and the nature, extent,
and degree of residual surface contamination.
b. Provide a detailed health and safety analysis which reflects that the
residual amounts of materials on surface areas, toqether with other
considerations such as prospective use of the premises, eoulpnent,
or scrap, are unlikely to result In an unreasonable risk to the
health and safety of the public.
5. Pnor to release of premises ^or unrcftricted use, the licensne shall
make a comprehensive radiatmr survey which establisbes that rortamination "
within the limits specified m Table 1. A copv the survey reoort shall he
fHec* Kith the nivt<;ion Fuel Cycle, Medical, Academic, and Conrerclal l.'se
Safety. U. S. NurVar Regulatorv Commission, Washinaton, OC 20555. and also
the Administrator of the NRC Recional Office having jwrisdiction. The report-
should be filed at least 30 days prior to the planned date of abandonment.
The survey report shall:
a. Ic'cntify the premises.
b. Show that reasonable effort has been made to eliminate residual
contamination.
c. Describe the scope of the survey and general procedures followed.
d. State the findlnas of the survey in units specified in the
instruction.
Followlpo review of the report, the *IK will consider visiting the
facilities to confirm the survey.
TABIC I
ACaPTABLE SURrACE CONTAHIHATIOII LtVELS
NUCllOCS* AVERAGE^ C f MAXtNUnt» <l f REMOVABLE** « f
U-nat. U-23S. U-236. and
associated decay products
Transuranics. Ra-226. Ra^ZZS.
Th.230. Th.226. Pa-231.
Ac.22;. M25. 1-129
Th.nat, Th-232, Sr-90.
Ra*223« R)-224. U-232. 1-126.
1-131. 1-133
Ceta-^an:^ cnitlers (nuclides
wUh decay rodes other than
alphj emission or spontaneous
fission) except Sr-90 and
others noted above. •
5.000 dpm tt/tOO cn^
100 dp^/100 (M?
1000 dp«/100 an2
5000 dpn BT/100 cm^
15.000 dp« o/lOO on^
300 dpa/100 Ca2
3000 dpq/100 cn2
15.000 dpn BT/100 at?
1.000 dps o/lOO CB^
20 dpn/lOO c«2
200 dpo/lOO cn^
1000 dpm BY/1 00 cm^
•Where surface contamination by both alpha- and beta-gaona-cnltting nuclides exists, the limits established for >inK. .-^ tl,^ nuclides Should apply independently. eswonshed for alpha, and beta-gamna-eniltlng
*»As used in this table. dp« (disintegrations per minute) means the rate of emission by radioactive material as Ai^tmt^eut u ...
counts per minute observed by an appropriate detector for background, efficiency, and geometric factori associated^ilh tS instJ^nLuon
c.'loasurenents of average contaminant should not be averaged over more than 1 square meter. For obiects of «...-r>^. , . should be derived for each such object. ^ [ surface area, the average
^The maxifflun contamination level applies to an area of not more than 100 cm^.
«Thc amount of removable radioactive material per 100 cm^ of surface area should be detenalned by wiplnq that ar»a with A^y, tt\*m^
AhsoruMt raper. applying moderate pressure, and assessing the anount of radioactive material on the wipe with an aoDro»pl*Ii 1^^*™°! r
kn^.n efficiency. When removable contamination on objects of less surface area Is detemfoed. the pertinent levJlJ ShoSldh! **
proportionally and the entire surface should be wiped. *^ * reduced
'the average and maxirauo radiation levels associated with surface contamtnation resulting from beta-gamna emitters should not •^r- A 0.2 mrad/hr at 1 cm and 1.0 mrad/hr at 1 cm. respectively, measured through not more than 7 minigrams per square centimeter of
total absorber.
' • '
INTERNATIONAL URANIUM (USA) CORPORATION
DECONTAMINATION FINAL RELEASE
I have venfied that tractor NA and/or container
Tractor Number
, has been checked for any contamination and has been
Contamer Number
authonzed for final release
Radiation Technician
Radiaton Department Title Date
C \windows\TEMP\decon SOP doc
No PBL-9
Rev No R-0
Date Oct 4,2002
INTERNATIONAL URANIUM (USA) CORPORATION
STANDARD OPERATING PROCEDURES
Title End Dump Trailer Acceptance, Handling & Release
Page 1 of 6
1.0 Purpose
The following procedure applies to acceptance, handhng, and release of end dump trailers
at the White Mesa Mill (the "Mill") International Uranium (USA) Corporation
("lUSA") receives material for processing, in either bulk or non-bulk packagmg. This
procedure addresses one form of bulk packaging - end dump trailers. This procedure
may be amended, subject to approval by lUSA's Safety and Environmental Review Panel
(SERP), firom time to time as appropnate to address the individual requirements of
specific feed materials, or projects.
2.0 Ore Receiving
1. Check truck scale for zero balance at the begiiming of each shift.
2 Wlien each truck driver enters the Restricted Area for the first time, the Scale
house operator wall provide hazard training for the driver. The driver will be
provided with the Safety Trainmg Form (copy attached) All drivers will be
required to read the Safety Trammg Form and sign and date the Safety Training
Form indicating that they understand and agree to follow lUSA's safety rules and
procedures while on company property The Scale house operator will sign the
Safety Training Form as the instructor for lUSA. Completed Safety Training
Forms will be turned m to the Safety Department for fiiture reference
3 Inspect all copies of the Bill of Lading (BOL) to ensure that the shipment is
destined for the Mill and that all shipping documentation is in order (see Section
8.2) If any discrepancies are noted notify the Mill management
immediately. Do not empty the end dump trailer until all paperwork
discrepancies are corrected.
4 Assign next available shipment number and Mill load number to the inbound
shipment Record the Mill load number, inbound date and both the truck and end
dump trailer numbers on the Scale house Weight Ticket (SWT)
5. Enter the loaded weight of the end dump truck and trailer on the SWT.
3.0 Ore Unloading
1 After weighing the truck and trailer, direct the driver to the specified ore storage
pad area where the matenal will be unloaded. Pnor to unloading the tarp is
inspected for damage and then removed, if necessary The driver is then directed
to unload the material, ensuring all persormel are clear of the trailer and the
immediate area.
2 After unloading the material replace the tarp, unless the trailer is being
decontaminated for unrestncted release
P \Admin\Master SOPs\Book 10_PBL Sops\PBL-9\PBL-9 End Dump SOP Rev 0 (10 04 02) doc
No PBL-9
Rev No R-0
Date Oct 4,2002
INTERNATIONAL URANIUM (USA) CORPORATION
STANDARD OPERATING PROCEDURES
Title End Dump Trailer Acceptance, Handling & Release
Page 2 of 6
3. After the tarp has been replaced on the trailer, direct the dnver back to the scales
for an empty weight
4 Record the empty weight on the appropriate SWT
5 Use a front-end loader or similar equipment to push matenal into the designated
ore lot pile.
4.0 Decontamination and Release of End Dump Trailers and Trucks
All end dump trailers and trucks will be decontaminated after unloading prior to
leaving the Mill Generators or transporters will notify lUSA whether a specific trailer is
to be released for restncted or unrestricted use. Any trailers that are to be released for
restricted use will be decontaminated according to the requirements contained in U S
Department of Transportation (DOT) Part 49 CFR 173 441(b) and 173 443 (copies
attached). Any trailers that are to be released for unrestricted use will be decontaminated
according to the requirements found in Table 1 of the Nuclear Regulatory Commission's
(NRC's) Pohcy and Guidance Directive FC-85-23, "Guidelines for Decontamination of
Facilities and Equipment Prior to Release for Unrestricted Use or Termination of
Licenses for Byproduct, Source, or Special Nuclear Material" issued May 1987 (copy
attached) Trailers requiring repair wdll be decontaminated for unrestricted release, to
facilitate repairs by the transporter at the transporter's own site Trailers may be repaired
without undergoing full decontamination if repaired within the Restricted Area of the
Mill.
5.0 Decontamination and Release of Equipment for Restricted Use
1 After the tarp has been replaced on the trailer and the empty weight obtained, the
dnver will be directed to the decontamination pad.
2 Decontaminate the exterior of each trailer, truck and tires thoroughly, using a
high-pressure water wash.
3 After the truck and trailer are decontaminated, the driver will be directed to the
gate, along the decontamination route The decontamination route is a graveled
roadway specifically designed for decontaminated equipment to exit the
Restricted Area If it becomes necessary due to environmental conditions or
residual mud m the tires etc., direct the driver to proceed along the
decontammation route to the secondary wash station. Wash any visual residual
mud off ofthe tkes, or extenor surface of the truck and trailer. Otherwise, direct
the driver to proceed along the decontamination route to the tertiary
decontamination and final scanning area
P \Admin\Master SOPs\Book 10_PBL Sops\PBL-9\PBL-9 End Dump SOP Rev 0 (10 04 02) doc
No PBL-9
Rev No R-0
Date Oct 4,2002
INTERNATIONAL URANIUM (USA) CORPORATION
STANDARD OPERATING PROCEDURES
Title End Dump Trailer Acceptance, Handling & Release
Page 3 of6
6.0
1
Contact a Radiation Technician to perform a radiological contamination survey
for restricted release of the truck and trailer If the Radiation Technician indicates
areas on the truck or trailer that require fiirthei decontamination, decontaminate
those areas as necessary ^
The Radiation Technician or RSO will scan the trailer, truck, and tires m various
locations as shown on the Eqmpment Survey for Restricted Release (copy
attached) and document the scan readings on the Equipment Survey for Restricted
Release. The contamination survey will be perfomied using appropriate
radiological instrumentation for total activity in accordance with DOT
transportation regulations. The release standards to be met for restricted release
are contained m U S Department of Transportation (DOT) Part 49 CFR
173 441(b) and 173 443 (copies attached).
If the trailer, truck or tires do not meet the radiological release survey
requirements or shows visually observable contamination, the truck and trailer
will either be returned to the secondary decontamination pad for fiirther
decontamination or will be washed again at the tertiary decontamination area
The Radiation Technician or RSO will fill out the Equipment Survey for
Restricted Release form (copy attached) to document that the truck and trailer has
been authonzed for release for restricted use. These forms are filed in the
Radiation Department. The Radiation Techmcian or RSO will place a white
sticker on the trailer that says, "EMPTY" and "This package conforms to the
conditions and limitations specified in 49 CFR 173 428 for radioactive material,
excepted package - empty package, UN2910"
After a truck and trailer have been released, the driver will perform a visual
inspection of the truck, trailer and tires
Leaving his truck outside of the Restricted Area, the driver will retum to the Scale
House to pick up the documentation for the empty trailer
Decontamination and Release of Equipment for Unrestricted Use
After the empty weight of the trailer has been obtained, the driver will be directed
to the decontamination pad. The tarp will not be replaced on the trailer or, if
necessary, the tarp shall be removed.
Open the trailer tailgate, elevate the trailer ensunng that there are no overhead
hazards and decontaminate the trailer using a high-pressure water wash Make
sure to thoroughly wash the inside and outside of the trailer. The tmck and tires
shall also be washed.
P \Admin\Master SOPs\Book 10_PBL Sops\PBL-9\PBL-9 End Dump SOP Rev 0 (10 04 02) doc
No PBL-9
Rev. No. R-0
Date Oct 4,2002
INTERNATIONAL URANIUM (USA) CORPORATION
STANDARD OPERATING PROCEDURES
Title' End Dump Trailer Acceptance, Handlmg & Release
Page 4 of 6
After the truck and trailer are decontaminated, the driver is directed to follow the
decontamination route The decontamination route is a graveled roadway
specifically designed for decontaminated equipment to exit the Restncted Area
If It becomes necessary due to environmental conditions or residual mud in the
tires etc, the driver is instructed to proceed along the decontamination route to the
secondary wash station Wash any visual residual mud off of the tires, or exterior
surface of the container Otherwise, the dnver is instructed to proceed along the
decontammation loute to the tertiary decontamination and final scanning area.
Contact a member of the Radiation Department staff to conduct the appropnate
radiological survey for unrestricted release of the tmck, trailer and tires The
release standards to be met for unrestricted release are contained in Table 1 ofthe
Nuclear Regulatory Commission's (NRC's) Policy and Guidance Directive FC-
85-23, "Guidelines for Decontamination of Facilities and Equipment Prior to
Release for Unrestricted Use or Termination of Licenses for Byproduct, Source,
or Special Nuclear Material" issued May 1987 (copy attached). The RSO will
prepare a memorandum detailing the applicable standard on Table 1 for each
project The RSO will also provide die training of the Radiation Technicians
required
The Radiation Technician will perform a radiological contammation survey of the
truck and trailer. If the Radiation Technician indicates areas that require fiirther
decontamination, decontammate those areas as necessary
If the tmck, trailer and tires meet the radiological release survey and visual
inspection requirements, the Radiation Technician will place a red sticker on the
trailer that says, "THIS CONTAINER HAS BEEN FULLY
DECONTAMINATED AND SURVEYED FOR "UNRESTRICTED USE" BY-
(FILL IN NAME OF RADIATION TECHNICIAN)" The RSO or Radiation
Technician that performed the release survey will then sign the red sticker and
date It. In addition, the RSO or Radiation Techmcian will fill out a
Decontamination Final Release Form (copy attached) to document that the tmck
and trailer have been cleared for unrestricted release. The Decontamination
Release Form will be turned in to the Mill Admimstration Office daily for filmg
and distribution
After a tmck and trailer have been released, the driver will do a visual inspection
of the tmck and trailer.
Leaving his truck outside of the Restricted Area, the driver will retum to the Scale
House to pick up the documentation for the empty trailer
P \Admin\Master SOPs\Book 10_PBL Sops\PBL-9\PBL-9 End Dump SOP Rev 0 (10 04 02) doc
No PBL-9
Rev No R-0
Date: Oct 4,2002
INTERNATIONAL URANIUM (USA) CORPORATION
STANDARD OPERATING PROCEDURES
Title End Dump Trailer Acceptance, Handling & Release
Page 5 of 6
7.0 Hazard Identification and Safety
7 1 Required Personal Protective Equipment (P?E)
In all areas of the Mill covered by this procedure, hard hats, safety glasses and
steel-toed shoes are required at a minimum. These must be worn in all areas of
the Mill with the exception of the Administration Building
7.2 Industrial Hazards and Safety
1 Use caution when the trailers are backing onto the Ore Pad
2 Ensure that all persormel within 50 feet of the area where the end dump trailer are
aware that unloading is about to commence. Move at least 25 feet away from the
rear of the tiailer during the initial unloading operation
3 Dnvers must use caution dunng the imloading process and be aware of any
overhead hazards ^
4 Do not place any part of your body mside the trailer when the trailer is being
tipped and the tailgate is open Only work around the tailgate after it has been
properly blocked open
5 Be aware of high-pressure wash water
6. Be aware of slippery conditions on the ore pad during periods of inclement
weather \
1 Be aware of the potential for ice build-up on and around the decontamination pad
- during periods of cold weather.
8 Use caution when entering or exiting equipment Be sure to use the ladders and
hand rails Do not jump off of the equipment.
9 Always use a ladder when entenng and/or exiting the interior of an end dump
trailer.
8.0 Paperwork Tracking
1. Each trailer will have a umque sequential project number assigned to it at the
generating facility This number will be entered onto the Bill of Lading (BOL)
and attached to the trailer prior to shipment from the generation site
P \Admin\Master SOPs\Book 10__PBL Sops\PBL-9\PBL-9 End Dump SOP Rev 0 (10 04 02) doc
INTERNATIONAL URANIUM (USA) CORPORATION
STANDARD OPERATING PROCEDURES
Title End Dump Trailer Acceptance, Handling & Release
No PBL-9
Rev. No R-0
Date Oct 4,2002
Page 6 of 6
Upon amval at the Mill, the tmck driver wall turn in all of his/her paperwork to
the Scale House operator who will verify that the BOL number, trailer number
and project number assigned to the shipment match on all copies of the BOL, The
Scale House operator wall also verify that the actual trailer number matches the
BOL Trailer Number If there are any discrepancies in any of the numbers
notify Mill management immediately. Only original paperwork will be
accepted If the original paperwork does not come with the trailer, notify Mill
management immediately. The Scale House operator will sign the BOL,
acknowledging receipt of tiie matenal at the Mill, if all of the paperwork is in
order Depending on contractual and/or sampling requirements, final acceptance
or rejection of certain altemate feed maten^s may be contingent on analytical
results
Each trailer wall be transported across the scale at the Mill prior to and after bemg
unloaded The appropriate information will be entered into the project database
All copies of the SWTs and BOLs will be forwarded to the Mill Records Manager
on a daily basis or other frequency specified by Mill Management, from time to
time
The Mill Records Manager will compile and reconcile tiie BOL's and SWTs for
distribution
P \Admin\Master SOPs\Book 10_PBL Sops\PBL-9\PBL-9 End Dump SOP Rev 0 (10 04 02) doc
SAFETY TRAINING FOR ALTERNATE FEED
DELIVERY PERSONNEL
Welcome to International Uranium (USA) Corporation's, White Mesa Mill In order to assure
your safety while on our property, we would like to acquaint you with the safety mles and
procedures, which you wall be required to follow while on our property.
1.0 General Safety
1 Approved hard hats and safety glasses are reqmred at all times except when inside the
cab of your truck
2 This is a smoke free facility No smoking is allowed on the property Eating anything,
drinking, chewing candy, gum or tobacco is also not allowed in .the Mill restricted area
due to radiation hazards
3 All mobile equipment will not exceed a speed limit of 5 miles per hour
4 Be aware of the possibility of a tmck turning over while dumping Ensure that the tmck
IS on level ground and biakes are set prior to dumping
5 Check for potential overhead hazards pnor to dumping
6 If matenal is hung up in the trailer bed, it is not permissible to work in the bed while it is
m the dump position If it is necessary to get m the bed of the trailer to free a hang up,
the bed must be lowered
7 Be aware of slippery conditions on the ore pad during penods of inclement weather
8 Be aware of the potential for ice build-up on and around the decontamination pad during
periods of cold weather
9 Use caution when entering or exiting equipment *
2.0 Radiation Safety
1 All drivers are required to scan for alpha radiation prior to leaving the Mill restncted
area
2. All eqmpment, i e trucks and trailers, will be scaimed for radiation prior to leaving the
Mill's restricted area
Driver (Pnnted) - Scale House Operator
Driver (Signature) Date
P \Admin\Master SOPs\Book 10_PBL Sops\PBL-9\PBL-9 End Dump SOP Att A (10 04 02) doc
, WAi!> Liocument Hemevai nnp.//irweogateaccess.gpogov/cgi*oin/g..winuc-nyoemivi-^i/JACACUinjiH-mlo&i irc-
[Code of Federal Regulations]
(Title 49, Volume 2, Parts 100 to 185]
[Revised as of October 1, 1999]
From the U.S. Goverrunent Printing Office via GPO Access
[CITE: 49CFR173.441]
[Page 582-583]
TITLE 49—TRANSPORTATION
{ '
CHAPTER I—RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION, DEPARTMENT OF i
TRANSPORTATION, ^
PART 173—SHIPPERS—GENERAL REQUIREMENTS POR SHIPMENTS AND PACKAGINGS—Table of Cont
Subpart I—Class 7 (Radioactive) Materials
Sec. 173.441 Radiation level limitations. \
(a) Except as provided in paragraph (b) of this section, each
package of Class. 7 (radioactive) materials offered for transportation
must be designed and prepared for shipment, so that under conditions
normally incident to transportation, the radiation level does not exceed
2 mSv/hour (200 mrem/hour) at any point on the external surface of the
package, and the tralnsport index does not exceed 10.
[[Page 583]]
(b) A package which exceeds the radiation level limits specified in
paragraph (a) of this section must be transported by exclusive use
shipment, and the radiation levels for such shipment may not exceed the
following during transportation:
(1) 2 roSv/h (200 mrem/h) on the external ,surface of the package
unless the following conditions are met, in which case the limit is 10
mSv/h (1000 mrem/h):' '
(1) The shipment is made in a closed transport vehicle;
(ii) The package is secured within the vehicle so that its position
remains fixed-during transportation; and \
(iii) There are no loading or unloading operations between the
beginning and end of the transportation;
(2) 2 mSv/h (200 mrem/h) at any point on the outer surfaces of the
vehicle, including the top and underside of the vehicle; or in the case
of a flat-ted style vehicle, at any point on the vertical planes
projected from the outer edges of the vehicle, on the upper surface of
the load or enclosure if used, and on the lower external surface of the
vehicle; ^
(3) 0.1 mSv/h (10 rarem/h) at any point 2 meters (6.6 feet) from the
outer lateral surfaces of the vehicle (excluding.the top and underside
of the vehicle); or in the case of a flat-bed style vehicle, at any
point 2 meters (6.6 feet) from the vertical planes projected by the
outer edges of the vehicle (excluding the top and underside of the
vehicle); and
(4) 0.02 mSv/h (2mrem/h) in any normally occupied space, except that
this provision does not apply to carriers if they operate under the
provision^ of a State or federally regulated radiation protection
program and if personnel under their control who are in such an occupied
space wear radiation dosimetry devices.
(c) For shipments made under the provisions of^ paragraph (b) of this
section, the offeror shall provide specific written instructions for
maintenance of the exclusive use shipment controls to the carrier. The
instructions must be included with the shipping paper information. The
instructions must be sufficient so that, when followed, they, will cause
the carrier to avoid actions that will unnecessarily delay delivery or
unnecessarily result in increased radiation levels or radiation
exposures to transport workers or members of the general public.
WAIS Document Retrieval ^ httpi/Zfrwebgatcaccess gpo gov/cgi.bm/g...irnTLE"49&PART»173&SECTION»441&TYPE=TI
(d) Packages exceeding the radiation level or transport index
' prescribed in paragraph (a) of this section may not be transported by
aircraft.
(Amdt. 173-244, 60 FR 50307, Sept. 28, 1995, as amended at 63 FR 48568,
Sept. 10, 1998]
WAIS Document Retneval http//frwebgare.access gpo.gov/cgl-bm/g t?TlTLE"^9&PART^173&SECTION«»«443&TYPE'»Tl
[Code of Federal Regulations]
[Title 49, Volume 2, Parts 100 to 185]
[Revised as of October 1, 1999]
Prom the U.S. Government Printing Office via GPO Access
[CITE: 49CFR173.443]
[Page 583-584]
TITLE 49—TRANSPORTATION
CHAPTER I—RESEARCH AND SPECIAL PROGRAMS ADMINISTRATION, DEPARTMENT OP
TRANSPORTATION
PART 173—SHIPPERS—GENERAL REQUIREMENTS FOR SHIPMENTS AND PACKAGINGS—Table of Cont
Subpart I—Class 7 (Radioactive) Materials
Sec. 173.443 Contamination control.
(a) The level of non-fixed (removable) radioactive contamination on
the external surfaces of each package offered for transport must be kept
as low as reasonably achievable. The level of non-fixed radioactive
contamination may not exceed the limits set forth m table 11 and must
be determined by either:
(1) Wiping an area of 300 square centimeters of the surface
concerned with an absorbent material, using moderate pressure, and
measuring the activity on the wiping material. Sufficient measurements
must be taken in the most appropriate locations to yield a
representative assessment of the non-fixed contamination levels. The
amount of radioactivity measured on any single wiping material, when
averaged over the surface wiped, may not exceed the limits set forth in
table 11 at any time during transport; or
(2) Using other methods of assessment of equal or greater
efficiency, m which case the efficiency of thfe method used must be
taken into account and
[[Page 584]]
the non-fixed contamination on the external surfaces of the package may
not exceed ten times the limits set forth in table 11, as follows:
Table 11—Non-Fixed External Radioactive Contamination-Wipe Limits
Maximum permissible limits
Contaminant
Bq/cm<SUP>2</SUP> uCi/cm<SUP>2</SUP>
Beta and gamma emitters and low toxicity 0.4 10<SUP>-5</SUP> 22
alpha emitters
All other alpha emitting radionuclides.. 0.04 10<SUp>-6</SUP> 2.2
(b) Except as provided m paragraph (d) of this section, in the case
of packages transported as exclusive use shipments by rail or public
highway only, the removable (non-fixed) radioactive contamination on any
package at any time during transport may not exceed ten times the levels
prescribed in paragraph (a) of this section. The levels at the beginning
of transport may not exceed the levels prescribed in paragraph (a) of
this section.
(c) Except as provided in paragraph (d) of this section, each
transport vehicle used for transporting Class 7 (radioactive) materials
as an exclusive use shipment that utili2es the provisions of paragraph
(b) of this section must be surveyed with appropriate radiation
detection instruments after each use. A vehicle may not be returned to
service until the radiation dose rate at each accessible surface is
WAIS Document Retrieval http'/Zfrwebgate access gpo.gov/cgi-bm/g i7nTLE"M9&PART"173&SECnON"443&TYPE'=Tl
0.005 mSv per hour (0.5 mrem per hour) or less, and there is no
significant removable (non-fixed) radioactive surface contamination as
specified in paragraph (a) of this section.
(d) Paragraphs (b) and (c) of this section do not apply to any
closed transport vehicle used solely for the transportation by highway
or rail of Class 7 (radioactive) material packages with contamination
levels that do not exceed 10 times the levels prescribed in paragraph
(a) of this section if—
(1) A survey of the interior surfaces of the empty vehicle shows
that the radiation dose rate at any point does not exceed 0.1 mSv per
hour (10 mrem per hour) at the surface or 0.02 mSv per hour (2 mrem per
hour) at 1 meter (3.3 feet) from the surface;
(2) Each vehicle is stenciled with the words '*For Radioactive
Materials Use Only*' in letters at least 76 millimeters (3 inches) high
in a conspicuous place on both sides of the exterior of the vehicle; and
(3) Each vehicle is kept closed except for loading or unloading.
[Amdt. 173-244, 60 FR 50307, Sept. 28, 1995, as amended by Amdt. 173-
244, 61 FR 20753, May 8, 1996]
GUIDELINES FOR DECONTAMINATION OF FAdLITIBS AND EQUIPMENT
PRIOR TO RELEASE FOR UNRESTRICrTED USB
OR TERMINATION OF UCENSES FOR BYPRODUCT, SOURCE,
OR SPECIAL NUCLEAR MATERIAL
U.S. Nuclear Regulatory Commission
Division of Fuel Cycle, Medical, Academic,
and Commercial Use Safety
Washington, DC 20555
April 1993
The instructions in this guide, in conjunction with Table 1, spedfy the
radionuclides and radiation exposure rate limits which sboidd be used in
decontamination and survey of surfeces or premises and equipmrat prior to
abandonment or release for uniestiicted use. The limits in Tfblt 1 do not
apply to premises, equipment, or scrap containing induced radioactivity for
which the radiological considerations pertinent to their use may be
different. The release of such facilities or items from regulatory control is
considered on a cas&-by-case basis.
1. The licensee shall make a reasonable effort to eliminate residual
contamination.
2. Radioactivity on equipment or surfaces shall not be coveted by paint,
plating, or otiier covering material unless contamination levels, as
determined by a survey and documented, aie bdow the limits specified in
Table 1 prior to the application of die covering. A reasonable effort
must be made to minimize the contamination prior to use of any covering.
3. The radioactivity on die interior sur£u;es of pipes, dram lines, or
ductwork shall be determined by making measurements at all tn^s, and
other appropriate access points, provided that contamination at these
locations is likely to be rqnesentative of contamination on the interior
of die pipes, drain lines, or ductwork. Surfeces of premises, equipment,
or scrap which are likely to be contaminated but are of such size,
constmction, or location as to make the surfiEice inaccessible for purposes
of measurement shall be presumed to be contaminated in excess of die limits.
4. Upon request, Uie Commission may autiioiize a licensee to relinquish
possession or control of premises, equipment, or scrap having surfaces
contaminated with materials in excess of the limits specified. This may
include, but would not be limited to, special circumstances such as razmg
of buildmgs, transfer of premises to another oxganization continuing work
with radioactive materials, or conversion of facilities to a long-term
storage or standby status. Such requests must:
a. Provide detailed, specific information describing the premises,
equipment or scrap, radioactive contaminants, and the nature, extent
and degree of residual'sur&ce contamination.
b. Provide a detailed health and safety analysis which reflects that the
residual amoimts of materials on surface areas, together with other
considerations such as prospective use of the premises, equipment,
or scrap, are unlikely to result in an unreasonable risk to the healtii
and safety of the public.
5. Prior to release of premises for unrestricted use, the licoisee shall
make a comprehensive radiation survey which establishes that contamination is
witiiin die limits specified in Table 1. A copy of die survey report shall be
filed witii tiie Division of Fuel Cycle Safety and Safeguards, U.S. Nuclear
Regulatory Commission, Washington, D.C. 20555, and also the Administrator
of the NRC Regional Office haviog jurisdiction, llie reports should be filed at
least 30 days prior to Uie planned date of abandonment. The survey report shall:
a. Identify the premises.
b. Show Uiat reasonable effort has be^ made to eliminate residual
contamuiation.
c. Describe Uie scope of the survey and general procedures followed.
d. State Uie findings of the survey in units specified in the
instmctions.
Following review of tiie report, the NRC will consider visiting Uie
facilities to confirm the survey.
•to
TABLE 1
ACCEPTABLE SURFACE CONTAMINATION LEVELS
NUCUDES* AVERAGE?" MAXIMUM^*' REMOVABLE^*'
U-nat, U-235, U-238, and
associated decay products
Transuranics, Ra-226, Ra-228,
Th-230, ni-228, Pa-231, Ac-227,
M25,1-129
Hi-nat, Th-232, Sr-90, Ra-223,
Ra-224. U-232,1-126,1-131,
1-133
Beta-gamma enutters (nuclides
with decay modes other than
alpha enn^on or spontaneous
fission) ejicept Sr-90 and
ofbisrs noted above
5,000 dpm a/lOO cm'
100 dpna/100 cm*
1,000 dpm/100 can*
5,000 dpm /?yi00 cn^
15,0CK) dpm ce/lOO cn^
300 dpm/lOO cm*
3,000 dpm/lOO cn^
15,000 dpm fiyflOO cm*
1,000 dpm a/100 cm*
20 dpm/lOO cm*
200 dpm/lOO cm*
1,000 dpm J87/IOO cnr*
Where suiface contamination by both alalia- and beta-ganmia-emitting nnchdes exists, the limits established for alpha- and beta-gamna-emitting
nuclides ^ould i^l^ ind^pendenUy.
As used in diis table, d^ (disint^rations per nnnute) means the rate of emission by radioactive material as determined by correcting the counts per
minute observed by an appropriate detector for background, efficiency, and geometric factors assodated \^th fhe instrummtation.
Measurements of average contaminant should not be averaged over more than 1 square meto* For objects of less surface area, flie average should be
derived finr eadi such object.
The maximum contandnation level i^lies to an area of not more than 100 cm*.
The amount of xemovable radioactive matensi per 100 cm* of surfece area should be determined by wiping that area with dry filter or soft absorbent
papNt applying moderate pressure, and assessing the amount of radioactive material on the vnpt with an appropriate instrnmoit of known effvAeocy.
When removable contamination on objects of less surfoce area is determmed, the pertinent levels should be reduced proportionally and fbe> oatibre
surface should be wiped.
The avoage and maximum radiation levels associated with surfiice contammation resnltmg from beta-gamma emitters should not exceed 0 2 mrad/hr at
1 cm and 1 0 mrad/hr at 1 cm, respectively, measured tfarongfa not more than 7 milligrams per square cratimeter of total absorber.
IBiBI
International Uranium (USA) Corporation
Equipment Survey for Restricted Release
Date Contamer ID: Surveyed By
Outside Locations
Location #
24
25
26
27
28
29
30
31
32
33
34
35
36
37
Ralls
instrument Data
Total Alpha/
Beta/Oantma
Model #
SN
Cal Date
Source
Efficiency
Total Alpha/
Beta-Oamma
cpm
Truck
and Tire Survey
0 0
00 00
00 00
Total Alpha/
Bata-Camma
Location # cpm
1
2
3
4
5
6
Truclc Ext
TRAILER TIRES
7
9
11
00 00
00 00
00 00
Total Alpha/
Beta-Oamma
Location # cpm
10
12
7
8
9
10
11
12
Chassis Ext
PBL-9 (10 04 02) END DUMP(b) xls
International Uranium (USA) Corporation
Equipment Survey for Unrestricted Release
Date Container ID.
Inside Locations
Locatioii #
1
2
3
4
5
6
7
B
9
10
11
12
13
14
15
16
17
18
19
Front
19
L Side
13 14
23
15 16
R Side
17 18
7 8
22
9 10
21
11 12
1 2 3 4 5 6
20
Tailgate
Total
Alpha
dpm/IOOcm'
Removable
Alpha
dpm/IOOcm*
Surveyed By
Outside Locations
dpm/IOOcm*
Location #
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
Rails
Total
Alpha
dpm/1 OOcm*
Removable
Alpha
dpm/IOOcm*
iny locelion exceeds 1000 dpm/100 cm2 total elpto, a swearAvipe survey (or removabte elptia must be perfonned
/ever, eddUonat removable apths t\Nfpes aKIwuglt not required may be performed
Instrument Data
Total
Alpha
Instrument E5P-1 / AC-3
SN 02299 / 1
02286 / 2
Cal Date
Function Check(5x1 mm)
Th 230 @ 30300 dpm
BKg Average
Dpm Average
Removaltle
Alpha
Model
SN
Cal Date
Function Check (5x1 mm)
Alpha Bkg Ave
Alpha eff
Alpha Faclor
Tota/
Beta/Qamma
Model it
SN [
Cal Date
Source
Efficiency
Truck
and Tire Survey
1 0 02
3 00 004
5 00 OOe
Total Alpha/
Beta-Gamma
•ocatlon cpm
Truck Ext
TRAILER TIRES
7 GO OOs
9 00 O0io
11 00 O0i2
Total Alpha/
Beta-Gamma
Locatipn cpm
10
11
12
Chassis Ext
PBL-9 (10 04 02) END DUMP(a) xls
(•
#
INTERNATIONAL URANIUM (USA) CORPORATION
DECONTAMINATION FINAL RELEASE
I have verified that tractor NA and/or container
Tractor Number
has been checked for any contamination and has been
Contamer Number
authonzed for final release
Radiation Technician
Radiaton Department Title Date
C \wmdows\TEMP\decon SOP doc
Type A Packaging
Cenillcatlon
SKOLNIK
xhibit 11 2A - Type A Test Report
Revision 03
Revision Date 17 July 2009
TESTING PERFORMED BY SKOLNIK INDUSTRIES. INC
CQ5506 TESTING LAB - AKA "SDCC"
4900 S Kilboum Avenue Chicago, Illinois 60632 10-090
TYPE A TEST REPORT
DRAWING NUMBER CQ5506 Rev /\2 MATERIAL Carbon Steel
UN RATING SOLIDS 1A2/X435/S UN RATING LIQUIDS 1/\2/Y1 5/150
DRUM TYPE Open Head THICKNESS 0 0433"-0 0480" (18 GA)
RING 12 GA (RBH2212) CAPACITY 55 Gallon
NUT/BOLT TYPE 5/8"-11 UNCx4" INSIDE DIAMETER 22 5"
GASKET "D" - EPDM (GE5500) OVERALL HEIGHT 34 75"
CLOSING INSTRUCTIONS PQ 080 Rev C ROLLING HOOPS 3
FITTINGS 2" & 3/4" Rieke CHIME TYPE Round Chime
NUCLEAR VENT None SEAM CONSTRUCTION Lap Weld
TESTING IS PERFORMED USING SURROGATE CONTENTS
SOLIDS (SMALL PARTICLE SIZE) Sodium Bicarbonate. Sand, Flour, Fluorescein Dye
SOLIDS (HEAVY BULKY MATERIAL) Lead Blocks. Steel Plate, Inner Steel Drum
GROSS MASS OF TESTED DRUM 960 lbs
EACH DRUM SHALL BE INSPECTED FOR CONFORMANCE TO 49CFR § 173 462 AND SOP 11 2 SECTION 4 0
DOES EACH DRUM CONFORM TO THE REQUIRED PRE-TESTING INSPECTION'? Yes
This report ensures that Skolnik Industries, Inc has successfully performed the Type A Packaging Tests as descnbed in 49 CFR § 173 465 using
sunrogate contents and that all requirements of 49 CFR § 173 462 were met pnor to testing This packaging is capable of withstanding, without
aipture or leakage, the vibration standard in 49 CFR § 178 608 (49 CFR § 173 410(f)) This packaging has been tested according to 49 CFR §
178 605 to support compliance with 49 CFR § 173 412(f), results are listed within this report
Skolnik Industnes, Inc does not, and cannot, certify this packaging as a DOT 7A Type A Package, it is the responsibility of the packager / shipper
to certify that the package meets all of the applicable requirements
Customer must be aware of subsequent Type A requirements including, but not limited to the following
49 CFR §172 310 Class 7 (radioactive) matenals
49 CFR §178 2 Applicability and responsibility
49 CFR §178 350 Specification 7A, general packaging, Type A
Additional information on this subject can be found within DOT clanfication letter Ref No 05-0074 and DOE Office of Transportation Regulatory
and Legislative Development Highlights Issue Number EM/OT-001 dated November 2005
PERFORMED BY
APPROVED BY
STGNATURE
Moises Basilio/Quality Assurance Tech
PRINTED NAME / TITLE
Matt Dick/Manager of Quality Assurance
PRINTED NAME / TITLE
SKolnik Industnes Inc
4900 S Kilboum Avenue
Chicago, IL 60632-4593 USA
773 735 0700 Page 1 of 8
SKOLNIK
Oruma of Stcd
xhibit 11 2A - Type A Test Report
Revision 03
Revision Date 17 July 2009
PART NUMBER
CQ5506
TESTING PERFORMED BY SKOLNIK INDUSTRIES, INC
TESTING LAB - AKA "SDCC"
4900 S Kilboum Avenue Chicago, Illinois 60632
TYPE A TEST REPORT
ID NUMBER
10-090
TYPE A PACKAGING TESTS 49CFR § 173.465
DATE 7/7/2010 TIME 7 45 AM TEST SEQUENCE # 1
SPRAY
DURATION 1 Hour
SOAK
DURATION 2 Hours
RESULT No Loss of Contents
s
BC Q
TEST RESULT PHOTOGRAPHS
I- ^
LZ IO
o.
Ui (09
ec €C
UJ u.
Drum #1 was closed to a torque of 60 ft-lbs and a
nng gap of 0 426 inches
Contents of Drunns #1 and #2 used for testing
Heavy Bulky Matenal Lead Blocks, Steel Plate,
Compacted Inner Drum
Contents of Drums #1 and #2 used for testing
Small Particle Size Sodium Bicarbonate, Sand
Flour, Fluorescein Dye
Drum #1 was sprayed with water for one hour to
simulate exposure to rainfall at a rate of at least 2"
per hour
Drum #1 was allowed to set for a penod of 2 hours so
that the water has soaked into the maximum extent No
loss of contents was observed due to the water spray test
of49CFR§ 173 465(b)
Skolnik Industries Inc
4900 S Kilboum Avenue
Chicago IL 60832-4593 USA
773 735 0700 Page 2 of 8
SKOLNIK
Drums of Steel
Exhibit 11 2A - Type A Test Report
Revision 03
Revision Date 17 July 2009
mMmmmm^m
CQ5506
TESTING PERFORMED BY SKOLNIK INDUSTRIES, INC
TESTING LAB-AKA "SDCC"
4900 S Kilboum Avenue Chicago, Illinois 60632
TYPE A TEST REPORT
10-090
TEST SEQUENCE #
RESULT CQ5506 is not capable of preventing loss of content dunng 49CFR 173 465(c)(2) and (c)(1)
MAXIMUM TOP
CRUSH PATTERN
MAXIMUM BOTTOM
CRUSH PATTERN
CQ5506 IS not capable of preventing loss of content
dunng the senes of testing as discnbed in 49CFR
173 465(c)(2) and 49CFR 173 465(c)(1) This test
was perfomed on 7/7/2010 resulting in loss of
contents Additional information is available upon
request
Skolnik Industnes, Inc
4900 8 Kilboum Avenue
Chicago, IL 60632-4593 USA
773 735 0700 Page 3 of 8
SKOLNIK
Drums of Scool
hibit 11.2A - Type A Test Report
Revision 03
Revision Date 17 July 2009
PART NUMBER
CQ5506
TESTING PERFORMED BY SKOLNIK INDUSTRIES, INC
TESTING LAB - AKA "SDCC"
4900 S Kilboum Avenue Chicago, Illinois 60632
TYPE A TEST REPORT
ID NUMBER
10-090
TYPE A PACKAGING TESTS 49CFR § 173.465
DATE 7/7/2010 TIME 11 10 AM TEST SEQUENCE # 3
DROP
HEIGHT 4 feet
RESULT No Loss of Contents
RU
I
M
#
:
M/0<IMUM TOP
CRUSH PATTERN 16 00" x 5 50"
MAXIMUM BOTTOM
' CRUSH PATTERN N/A
O
TEST RESULT PHOTOGRAPHS
(0 u
0. "*
" (09 UJ UJ £
^ o
Drum #1 was dropped from a height of 4 feet onto Drum #1 was dropped to cause the maximum amount of
the drum/nng/bolt assembly damage to the safety features being tested
' * \ — • •
Visible damage was observed due to the 4 foot drop No loss of content was observed due to this senes of
onto the assembly of Drum #1, crush pattem of tests that were performed on Drum #1
16 00" X 5 50"
Skolnik Industries Inc
4900 S Kilboum Avenue
Chicago, IL 60632-4593 USA
773 735 0700 Page 4 of 8
SKOLNIK
Drums of Stoo4
xhibit 11.2A - Type A Test Report
Revision 03
Revision Date 17 July 2009
PART NUMBER
CQ5506
TESTING PERFORMED BY SKOLNIK INDUSTRIES, INC
/ TESTING LAB - AKA "SDCC"
4900 S Kilboum Avenue Chicago, Illinois 60632
TYPE A TEST REPORT
ID NUMBER
10-090
TYPE A PACKAGING TESTS 49CFR § 173.465
DATE 7/7/2010 TIME 12 45 PM TEST SEQUENCE # 1
CM SPRAY
DURATION 1 hour
SOAK
DURATION 2 hours
RU
M
RESULT No Loss of Content
O
TEST RESULT PHOTOGRAPHS
a. ^
(0 (09
CC €C
1$
Drum #2 was closed to a torque of 60 ft-lbs and a Drum #2 was allowed to set for a penod of 2 hours so
nng gap of 0 451 inches Drum #2 was sprayed with that the water has soaked into the maximum extent No
water for one hour to simulate exposure to rainfall at loss of contents was observed due to the water spray test
a rate of at least 2" per hour of 49CFR § 173 465(b)
Skolnik Industnes inc
4900 S Kilboum Avenue
Chicago, IL 60632-4593 USA
773 735 0700 Page 5 of 8
SKOLNIK
Drums of Seed
Exhibit 11 2A - Type A Test Report
Revision 03
Revision Date 17 July 2009
PART NUMBER
CQ5506
TESTING PERFORMED BY SKOLNIK INDUSTRIES, INC
TESTING LAB - AKA "SDCC"
4900 S Kilboum Avenue Chicago, Illinois 60632
TYPE A TEST REPORT
ID NUMBER
10-090
TYPE A PACKAGING TESTS 49CFR § 173.465
CN
s
O
DATE 7/8/2010
COMPRESSIVE
LOAD
CALCULATION
5 X GROSS
MASS =
TIME
4796 lbs
6 30 AM TEST SEQUENCE #
13(kPa)x
TT(0 D /2)'^2 = 933 lbs
USE THE GREATER OF THE CALCULATED LOADS
TEST
DURATION 24 hours with a load of at least 4796 lbs
OD = OUTSIDE DIAMETER
RESULT No Loss of Contents
TEST RESULT PHOTOGRAPHS
m IO IU <s
S *ot
< u. H- O CO 0>
A compressive load of at least 4796 lbs was applied The overall height of Drum #2 pnor to performing the
uniformly to two opposite sides of Drum #2 for at stack test was 34 75"
least 24 hours
The overall height of Drum #2 after the 24 hour No loss of content occunred dunng the stack test The
penod of the stack test was 34 75", no defomriation O D was approximated at 25" for the compressive load
of Drum #2 occurred calculation
Skolnik Industries Inc
4900 S Niboum Avenue
Chicago IL 60632-4593 USA
773 735 0700 Page 6 of 8
SKOLNIK
Oroms of Stcol
Exhibit 11.2A - Type A Test Report
Revision 03
Revision Date 17 July 2009
PART NUMBER
CQ5506
TESTING PERFORMED BY SKOLNIK INDUSTRIES, INC
TESTING LAB - AKA "SDCC
4900 S Kilboum Avenue Chicago, Illinois 60632
TYPE A TEST REPORT
ID NUMBER
10-090
TYPE A PACKAGING TESTS 49CFR § 173.465
s
CC
a
DATE 7/7/2010
PENETRATION
BAR DIAMETER 1 252"
VERIFICATION
TIME 11 00 AM TEST SEQUENCE # 2_
MASS 16 53 lbs
49CFR § 173 465(e)(1) 1 25(in) 49CFR § 173 465(e)(1) 13 2(lbs)
DROP
HEIGHT 3 3 feet from the lowest point of the penetration bar to the point of impact
RESULT No Loss of Contents
TEST RESULT PHOTOGRAPHS
ill
z o p
cc
li.
o P Drum #1 was placed onto a ndged, flat, honzontal
surface The penetration bar was dropped from a
height of 3 3 feet
This drop was performed at two locations on Drum #1
Drop 1 on the cover created a dent that was 1 750" in
diameter and 0 324" deep
Drum #1 was then placed onto its side for drop 2
that was performed on the body of the drum The
penetration bar was dropped from a height of 3 3
feet
This drop created a dent that was 4 25" in diameter and
0 142" deep No loss of content occurred due to this
series of tests
Skolnik industnes Inc
4900 S Kiiboum Avenue
Chicago IL 60632-4593 USA
773 735 0700 Page 7 of 8
SKOLNIK
Drums of Stoo)
Exhibit 11 2A - Type A Test Report
Revision 03
Revision Oate 17 July 2009
PART NUMBER
CQ5506
TESTING PERFORMED BY SKOLNIK INDUSTRIES. INC
TESTING LAB - AKA "SDCC"
4900 S Kilboum Avenue Chicago, Illinois 60632
TYPE A TEST REPORT
ID NUMBER
10-090
TYPE A PACKAGING TESTS 49CFR § 173.465
IO
I
CO
«
S
3 tc o
DATE 6/28/2010 TIME 10 00 AM TEST SEQUENCE #
TEST PRESSURE 150 kPa
DURATION 5 minutes once the test pressure is achieved
RESULT No Loss of Contents
TEST RESULT PHOTOGRAPHS
Drums #3, #4. and #5 were closed to a torque of 60 No loss of contents was observed dunng this sequence
ft-lbs and a nng gap of 0 230", 0 309", and 0 330" of testing
Hydrostatic testing was performed in accordance
With 49CFR 178 605 to support compliance with
49CFR 173 412(f) The drums were filled with water
to a test pressure of 150 kPa for a duration of 5
minutes
DESCRIPTION ID/SERIAL NUMBER DUE DATE
1-
6" Caliper 6398978 May-2011
Ui
IU
1- K
alf Z
Pressure Gauge DPG-1 May-2011
^ 111
OS Torque Wrench 33498 May-2011
ME
A
S
U
R
EQ
U
I
Torque Wrench 990 May-2011
ME
A
S
U
R
EQ
U
I
Measunng Tape 12 ft N/A
Scale 140154 May-2011
Skolnik Industries Inc
4900 S Kilboum Avenue
Chicago IL 60632-4593 USA
773 735 0700 Page 8 of 8
other Supporting Pocnmontatlon
Page 1 of 2
Boyd Imai - Fwd: ChangelBf Titles and Contact Infor Ation for Energy Fuels
Resources (USA) Inc.
From: Ryan Johnson
To: Imai, Boyd
Date: 9/17/2012 9:55 AM
Subject: Fwd: Changes of Titles and Contact Information for Energy Fuels Resources (USA) Inc.
Ryan Johnson, P.G.
Environmental Scientist/Health Physicist
Utah Division of Radiation Control .
»> Phillip Goble 8/15/2012 12:48 PM »>
Thought you'd be interested.
>» David Frydenlund <[e-mail]> 8/15/2012 12:32 PM »>
Phil,
Further to our call yesterday morning, this is to confirm that Denison Mines (USA) Corp changed its name to Energy Fuels
Resources (USA) Inc effective July 25,2012 The name has changed, but the entity remains the same
Also, some changes have been made in the titles of certain personnel The following table sets out the current titles and contact
information forthe key personnel that DRC corresponds with on a regular basis regarding White Mesa Mill matters
Name Current Title Comments Email Address Direct Telephone
Number
Stephen P Antony President and Chief
Executive Officer
santonv(5)ener6vfuels com [phone]
Harold R Roberts Executive Vice President
and Chief Operating
Officer
hroberts@energvfuels com [phone]
David C Frydenlund Senior Vice President,
Regulatory Affairs and
General Counsel
dfrvdenlund(5)energvfuels com [phone]
Jo Anns Tischler Director, Compliance itischlerpenerevfuels com [phone]
KathermeA Weinel Quality Assurance
Manager
(No Change to
Title)
kweinel@ener6vfuels com [phone]
Daniel L Hillsten Mill Manager (No Change to
Titie)
dhillsten^energvfuels com [phone]
David E Turk Manager, Environmental,
Health and Safety
dturk@energvfuels com [phone]
Ronnie B Nieves Mill Radiation Safety
Officer
rnieves@energvfuels com [phone]
Jaime J Massey Environmental
Compliance Assistant
(No Change to
Title)
imassev@energvfuels com (303) 389- 4167
file://C:\Documents and Settings\Blmai\Local Settings\Temp\XPGrp... 9/17/2012
Page 2 of 2
Effective August 20, 2012, Energy Fuels Resources (USA) Inc will be moving its offices to the following address
Energy Fuels Resources (USA) Inc
225 Union Blvd , Suite 600
Lakewood, CO 80228
The mam phone number will continue to be [phone]
The fax number will continue to be [phone]
Please let me know if you have any questions, or require any further information
Dave
David Frydenlund
Vice President, Regulatory Affairs, Counsel and Corp Secretary
Energy Fuels Resources (USA) Inc.
t 303-389-4130 |f 303-389-4125
1050 17th Street, Suite 950
Denver, CO, US, 80265
http //www energyfuels com
This e-mail is intended for the exclusive use the of person(s) mentioned as the recipient(s) This message and any attached files
with it are confidential and may contain privileged or propnetary information If you are not the intended rec!pient(s) please delete
this message and notify the sender You may not use, distribute print or copy this message if you are not the intended recipient(s)
file://C:\Documents and Settings\Blmai\Local Settings\temp\XPGrp... 9/17/2012
"This package conforms to the
conditions and limitations specified in
49 CFR 173 428 for radioactive
materials excepted package-empty
package, UN2908 "
"This package conforms to the
conditions and limitations specified in
49 CFR 173 428 for radioactive
materials excepted package-empty
package, UN2908"
"This package conforms to the
conditions and limitations specified in
49 CFR 173 428 for radioactive
materials excepted package-empty
package, UN2908 "
"This package conforms to the
conditions and limitations specified in
49 CFR 173 428 for radioactive
materials excepted package-empty
package, UN2908 "
'This package conforms to the
conditions and limitations specified in
49 CFR 173 428 for radioactive
materials excepted package-empty
package, UN2908 "
"This package conforms to the
conditions and limitations specified in
49 CFR 173 428 for radioactive
materials excepted package-empty
package, UN2908 "
'This package conforms to the
conditions and limitations specified m
49 CFR 173 428 for radioactive
matenals excepted package-empty
package, UN2908 "
"This package conforms to the
conditions and limitations specified in
49 CFR 173 428 for radioactive
matenals excepted package-empty
package, UN2908 "
'This package conforms to the
conditions and limitations specified in
49 CFR 173 428 for radioactive
materials excepted package-empty
package, UN2908 "
"This package conforms to the
conditions and limitations specified in
49 CFR 173 428 for radioactive
matenals excepted package-empty
package, UN2908 "
"This package conforms to the
conditions and limitations specified in
49 CFR 173 428 for radioactive
materials excepted package-empty
package, UN2908 "
"This package conforms to the
conditions and limitations specified in
49 CFR 173 428 for radioactive
materials excepted package-empty
package, UN2908 "
"This package conforms to the
conditions and limitations specified in
49 CFR 173 428 for radioactive
materials excepted package-empty
package, UN2908 "
"This package conforms to the
conditions and limitations specified m
49 CFR 173 428 for radioactive
materials excepted package-empty
package, UN2908 "
"This package conforms to the
conditions and limitations specified m
49 CFR 173 428 for radioactive
materials excepted package-empty
package, UN2908 "
"This package conforms to the
conditions and limitations specified in
49 CFR 173 428 for radioactive
matenals excepted package-empty
package, UN2908 "
"This package conforms to the
conditions and limitations specified in
49 CFR 173 428 for radioactive
materials excepted package-empty
package, UN2908 "
"This package conforms to the
conditions and limitations specified m
49 CFR 173 428 for radioactive
matenals excepted package-empty
package, UN2908"
"This package conforms to the
conditions and limitations specified in
49 CFR 173 428 for radioactive
materials excepted package-empty
package, UN2908 "
"This package conforms to the
conditions and limitations specified in
49 CFR 173 428 for radioactive
materials excepted package-empty
package, UN2908"
"This package conforms to the
conditions and limitations specified in
49 CFR 173 428 for radioactive
matenals excepted package-empty
package, UN2908 "
'This package conforms to the
conditions and limitations specified m
49 CFR 173 428 for radioactive
materials excepted package-empty
package, UN2908 "
"This package conforms to the
conditions and limitations specified in
49 CFR 173 428 for radioactive
materials excepted package-empty
package, UN2908 "
"This package conforms to the
conditions and limitations specified in
49 CFR 173 428 for radioactive
materials excepted package-empty
package, UN2908 "
"This package conforms to the
conditions and limitations specified m
49 CFR 173 428 for radioactive
matenals excepted package-empty
package, UN2908"
'This package conforms to the
conditions and limitations specified in
49 CFR 173 428 for radioactive
materials excepted package-empty
package, UN2908 "
"This package conforms to the
conditions and limitations specified in
49 CFR 173 428 for radioactive
materials excepted package-empty
package, UN2908 "
"This package conforms to the
conditions and limitations specified in
49 CFR 173 428 for radioactive
materials excepted package-empty
package, UN2908 "
"This package conforms to the
conditions and limitations specified in
49 CFR 173 428 for radioactive
materials excepted package-empty
package, UN2908"
"This package conforms to the
conditions and limitations specified in
49 CFR 173 428 for radioactive
materials excepted package-empty
package, UN2908"