DRC-2019-006406 - 0901a06880aa1b06

State of Utah
GARY R. HERBERT
Governor
SPENCER J. COX
Lieutenant Governor
Department of
Environmental Quality
L. Scott Baird
Interim Executive Director
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Ty L Howard
Director
-912-c-20/9-00640b
MEMORANDUM
TO: Project File C-2019-38
THROUGH: Phil Goble, Uranium Mill Section Manager NG WS (70/1
FROM: Russell J. Topham, PE
DATE: July 3, 2019
SUBJECT: 2019 Engineering Module 73, Inspection of disposal of lle.(2) decommissioning debris
from in situ leach facilities
Authority
Radioactive Materials License #UT1900479, Condition 10.5: "In accordance with the Licensee's
submittal to the NRC dated May 20, 1993, the Licensee is hereby authorized to dispose of byproduct
material generated at licensed in situ leach (ISL) facilities, subject to [...] conditions." (Conditions are
cited below as Requirements.)
R313-12-3 (quoting 10 CFR 40.4): "Byproduct Material means the tailings or wastes produced by the
extraction or concentration of uranium or thorium from any ore processed primarily for its source
material content, including discrete surface wastes resulting from uranium solution extraction
processes."1
10 CFR Part 40 Appendix A, Criterion 2: "To avoid proliferation of small waste disposal sites and
thereby reduce perpetual surveillance obligations, byproduct material from in situ extraction operations,
such as residues from solution evaporation or contaminated control processes, and wastes from small
remote above ground extraction operations must be disposed of at existing large mill tailings disposal
sites; unless, considering the nature of the wastes, such as their volume and specific activity, and the
costs and environmental impacts of transporting the wastes to a large disposal site, such offsite disposal
1 This definition amends the language given in Section 1 1 e.(2) of the Atomic Energy Act as amended in 1954 to include in
situ leach facilities on the same footing as conventional uranium mills. This is done by referencing "solution extraction" in
the definition. Text of the Atomic Energy Act as amended in 1954 can be found in NUREG-0980, Volume 1, No. 10.
DRC-20 195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
Second Quarter, 2019 ISL Decommissioning Debris Disposal Inspection Report
July 3, 2019
Page 2
is demonstrated to be impracticable or the advantages of onsite burial clearly outweigh the benefits of
reducing the perpetual surveillance obligations."
Requirements
1. Radioactive Materials License #UT1900479, Condition 10.5A: "Disposal of ISL waste is limited to
5,000 cubic yards from a single source." The Division considers a source to be a discrete facility
defined by its geographic boundaries.2
2. Radioactive Materials License #UT1900479, Condition 10.5B: "All ISL contaminated equipment
shall be dismantled, crushed, or sectioned to minimize void spaces. Barrels containing waste other
than soil or sludges shall be emptied into the disposal area and the barrels crushed. Barrels
containing soil or sludges shall be verified by the Licensee to be full prior to disposal. Barrels not
completely full shall be filled with tailings or soil prior to disposal."
3. Radioactive Materials License #UT1900479, Condition 10.5C: "All ISL waste shall be buried in
Cell No. 3 unless prior written approval is obtained from the Director for alternate burial locations."
4. Radioactive Materials License #UT1900479, Condition 10.5D: "All disposal activities shall be
documented and records thereof maintained on-site. The documentation shall include descriptions of
the ISL waste and the disposal locations, as well as all actions required by this License condition."
5. Radioactive Materials License #UT1900479, Condition 10.5E: "The Licensee shall also submit for
Director approval a revised written Standard Operating Procedure (SOP) for ISL disposal on or
before December 1, 2010. The revised SOP shall describe the documentation required for ISL
disposal, which shall include but is not limited to the following:"
(1) The material disposal area must be located on a tailings beach area of the disposal cell or on an
area of the cell that is underlain by tailings sands;
(2) The elevation of the material disposal area will not exceed the plane or grade of the elevations of
the uppermost flexible membrane liner of the tailings cell;
(3) Such ISL byproduct material will be segregated from any mill material and equipment disposed
of in the cells pursuant to License Condition 10.4, and the ISL byproduct material from each in
situ leach source will be segregated from the byproduct material from all other in situ leach
sources;
(4) Absence of void space inside barrels disposed, including physical verification before disposal;
and
(5) Detailed engineering drawings which demonstrate:
2 A "source" in this context is a geographically discrete facility. See Letter from Rusty Lundberg to Jo Ann Tischler dated
November 7, 2013 (DRC-2013-005682)
Second Quarter, 2019 ISL Decommissioning Debris Disposal Inspection Report
July 3, 2019
Page 3
a. There are at least 4 feet of tailings sands under the bottom of each disposal area; and
b. The bottom of each disposal area is located at least 12 feet from the sides or dikes of the
tailings cell.
6. Radioactive Materials License #UT1900479, Condition 10.5F: The Licensee shall notify the
Director in writing at least 7 calendar days prior to the proposed scheduled date for disposal of any
byproduct material generated at ISL facilities in the tailings cells.
An annual summary of the amounts of waste disposed of from off-site ISL generators shall be sent to
the Director on or before November 1 of each calendar year.
Observations
Russell J. Topham, PE of the Utah Division of Waste Management and Radiation Control (the
Division), observed disposal of three loads of lle.(2) byproduct material on June 11, 2019 at the White
Mesa Uranium Mill (the Mill) owned and operated by Energy Fuels Resources (the Licensee) in
response to notifications sent by the Licensee dated May 28 and June 10, 2019. The disposal operation
involved two loads of 11 e.(2) material (decommissioning debris) from Cameco's Smith Ranch property
near Douglas, Wyoming and one load from Strata Energy's Ross property near Moorcroft, Wyoming.
The June 10 notice was for a burial of three loads intended for a June 25 operation; however, one load
had arrived by the inspection date, and had enough radioactivity that the mill staff was taking additional
precautions with it for ALARA purposes. A 5 millirem (mR) perimeter was set around the loads using
barricades and rope, with radiation warning signs placed on the four faces of the resulting quadrangle.
To assist in meeting the intent of the facility's ALARA efforts, I offered, and the staff accepted, to bury
both Smith Ranch loads during the inspection rather than waiting out the two-week notice on the second
one.
This inspection focused on the Licensee's implementation of Standard Operating Procedure SOP PBL-
10, which governs disposal of lle.(2) byproduct material from in situ leach facilities. Incoming
shipments for all materials are subject to another procedure, SOP PBL-19, which was not the subject of
this inspection.
Copies of paperwork obtained from field crews show that the Licensee used revision R-3.4 of SOP PBL-
10, dated February 1, 2018 for the operations observed. A copy of this paperwork is attached to this
report. Revision R-3.4 is the most recent version of the procedure.
The Licensee maintains a map of Tailings Impoundment 3 in the Mill office that shows the dedicated
disposal location for each 1le.(2) debris generator. Examination of that map reveals that if disposal
operations are limited to the lateral extents of the dedicated disposal plots and if the vertical location of
placement of material is limited to within two feet above and below the upper surface of the tailings,
neither the excavation nor the debris will endanger the integrity of the impoundment liner.
Lateral disposal pit locations are determined and located in the field by survey prior to excavation. The
bottom of the excavations is extended into the tailings sand, and the depth is surveyed prior to placement
of material into the excavation. Once the debris is placed in the excavation and compressed, the top of
debris is surveyed, after which cover soil is placed and compacted. Lateral locations were checked by
Second Quarter, 2019 ISL Decommissioning Debris Disposal Inspection Report
July 3, 2019
Page 4
the inspector onsite. Disposal data packets attached to this report show that the vertical placement is
below the peripheral top of liner and well above the liner beneath the excavation.
SOP PBL-10 requires that material must be accepted for disposal prior to departure of the transport
vehicle from the generator. This allows the Licensee to ascertain that the material characteristics meet
the requirements for classification as 1le.(2) byproduct material, and to verify that the quantity to be
shipped will not exceed the 5,000 cubic yard per source limit established in License Condition 10.5A.
Checks of running receipt totals confirmed that the volume limits had not been exceeded. The material
is checked upon receipt to verify that what was shipped is what was expected.
Once the material is accepted for shipment, the receipt and burial are scheduled and the Licensee sends a
seven-day advance notice to the Division of the date scheduled for the burial event and number of loads
anticipated for disposal. The Division received the written notices on May 30 and June 12, 2019. As
previously noted, one of the loads was intended for burial on June 25; however, to assist the mill
management in meeting its ALARA goal, that load was buried on June 11, before the Division received
the seven-day notice.
Disposal Activities Observed
Photos 1 through 4 in the attached photo log show the materials being disposed during the inspection.
The Cameco/Smith Ranch material was miscellaneous decommissioning debris, including pipes, pumps,
filters, filter socks, wire, and miscellaneous debris. The material from Strata Energy included filter pipe
and miscellaneous debris. None of the material required dismantling, sectioning or crushing. The loads
included no barrels, so License Condition 10.5B does not apply to the operations observed. Soil should
be able to fill voids in the debris mass. Once placed, the material is densified to minimize the potential
for excess differential settlement of the tailings, cover system and buried debris.
The excavations prepared to receive these materials were extended through the lighter-colored platform
fill and to the surface of the tailings. The disposal crew surveyed the elevation of the pit bottom prior to
introducing the disposed material. Results of the survey operation are included in the attachments to this
report. Lateral location of the pit was checked in the Mill office checked to verify the distance between
the edge of the pit and the Cell 3 liner.
Surveying of the depth of the pits was observed; see Photo 5 for survey of the Strata Energy pit. Results
of the survey operation demonstrate that the material was placed at proper depth to prevent liner
damage. The survey results are included in the attachments to this report.
Following placement of the debris in the excavation, the crew used the loader bucket to compact the
debris into place. Then, the crew surveyed the elevation of the top of the debris. Photo 8 shows the
survey operation to determine the elevation at the top of the disposed material in the Smith Ranch
excavations. The survey data is included as an attachment to this report. The survey data shows, and a
check against the drawing at the Mill office confirmed, that the top of the disposed material in the pit
was below the plane of the top of the flexible membrane liner, as required.
The crew placed soil meeting the specification for platform fill into the excavation to cover the newly
emplaced debris. Photos 9 through 11 show the crew placing cover soil in the excavations and wheel
walking to densify that material. The capping soil was placed in lifts of about 12" thickness and wheel-
Second Quarter, 2019 ISL Decommissioning Debris Disposal Inspection Report
July 3, 2019
Page 5
walked to densify. The cover soil serves both to retain the debris in the pit away from environmental
forces, and as part of the platform fill/secondary Radon barrier.
A Note on Safety Culture and ALARA
This disposal operation gave a good opportunity to note efforts the Energy Fuels staff takes to keep
workers safe and to meet ALARA goals. The readings of radioactivity taken upon receipt of the
materials and later at the location of placement adjacent to the receiving pits did not reveal levels of
radioactivity sufficient to exceed regulatory thresholds and require additional measures to be taken.
Nevertheless, the staff noted that the Smith Ranch materials contained substantially more radioactivity
than background; 15 and 22 mR/hr, respectively. The crew established a perimeter around the Smith
Ranch work using barricades and rope, with radiation warning signs suspended from the rope.
Remaining outside the perimeter ensured that the received dose would not exceed 5 mR/hr.
The perimeter remained in place until the active disposal operation commenced. At that point, only the
equipment operator and surveyor were allowed within the perimeter. Inspectors for both the Division
and the Licensee observed from an upwind position over 200 feet away. To prevent inhalation of any
dust carrying radioactivity, the loader operator was in a respirator.
To me, this level of precaution, along with other measures taken and noted in other inspections,
demonstrates a commitment on the part of Energy Fuels to the safety and healty of its employees, and by
extension, the public.
Conclusions and Recommendations
The Licensee appears fully compliant with applicable laws, standards, requirements and License
Conditions with respect to disposal of 1le.(2) byproduct material generated as decommissioning debris
from in situ leach uranium recovery facilities.
The Licensee appears committed to doing significantly more than the minimum required to foster
workplace safety and to minimize worker and public exposure to radiation.
No new recommendations were identified during this inspection.
Photo 1: Two loads of 11 e.(2) decommissioning debris from Cameco - Smith
Ranch. Note the boundary set to prevent exposure above 5 mR/hour for
ALARA oses. Photo taken June 11, 2019.
Photo 3: Two loads of 1le.(2) decommissioning debris from Cameco - Smith
Ranch. The white rope in the foreground is part of the 5mR perimeter
established to support ALARA. Photo taken June 11, 2019.
Photo 2: Two loads of 11e.(2) decommissioning debris from Cameco - Smith
Ranch. Note the boundary set to prevent exposure above 5 mR/hour for
ALARA purposes. Photo taken June 11, 2019.
Photo 4: One load of 11e.(2) decommissioning debris from Strata Energy.
Photo taken June 11, 2019.
Photo 5: Surveying the bottom of the excavation prior to burying the Strata Photo 6: Placing Strata Energy material in the excavation. Photo taken June 11,
Energy material. Photo taken June 11, 2019. 2019.
Photo 7: Placing Cameco — Smith Ranch material in the excavation. Operator
is wearing respirator, and inspector was 300 ft. upwind to prevent inhaling
contaminated dust. Photo taken June 11, 2019.
Photo 8: Surveying the top of the 1le.(2) material mass prior to burying the
Cameco - Smith Ranch material. Photo taken June 11, 2019.
Photo 9: Placing cover soil over Strata Energy material. Photo taken June 11,
2019..
Photo 10: Placing cover soil over Cameco-Smith Ranch material. Photo taken
June 11, 2019.

Photo 11: Wheel-walking to densify the cover soil at the Cameco — Smith
Ranch burial site. Photo taken June 11, 2019.

eFENERGY FUELS
Energy Fuels Resources (USA) Inc.
6425 South Highway 191, PO Box 809
Blanding, UT. US, 84511
435 678 2221, fax [phone]
www.energyfuels.com
1) RC-26 I, - 005o 9

Div 0 Waste Monovalent
and Radiation Control
MAY 3 0 2019
May 28, 2019
VIA Electronic Mail (PDF) and UPS
Mr. Ty Howard
State of Utah Department of Environmental Quality
195 North 1950 West
PO Box 144880
Salt Lake City, UT 84114-4880
Dear Mr. Howard,
Re: 11e.(2) Byproduct Receipt Notification
Pursuant to Radioactive Materials License (RML) UT1900479 condition 10.5.F, Energy Fuels Resources
(USA) Inc. is hereby notifying the Division of Waste Management and Radiation Control that the White
Mesa Uranium Mill will be receiving and disposing of two loads by June 11 th, 2019.
If there are any questions regarding these shipments or the scheduling of the disposal activities feel free to
contact me at the White Mesa Mill at 435.678.4114.
Regards,
Garrin Palmer
cc: Denver Central Files
No.: PBL-10 ENERGY FUELS RESOURCES (USA) NC.
Rev. No.: R-3.4 STANDARD OPERATING PROCEDURES Page 11 of 13 Date: February 1, Title: 1 le.(2) 13yproduct Disposal
2018
ATTACHMENT 2
11e.12) BYPRODUCT 111ATERIAL DISPOSAL DOCUMENTATION FORM
Date:
Name of employee receiving the load: J-jLL-r".-f
Generator of the Byproduct Material: S Fr-v.+ t"... y
Shipper's Manifest or Bill of Lading number. -0 ga f Ac,o4,1,
Was the State of Utah given 'notice tothe receipt/disposal activities associated with this load?
No
Who gave and when was the notification given?
Descliption of byproduct material disposal area/activities:
C fe,s.„ AAAA_ 52,Ak.r-414 4-1--#6.f S 4)14-40+1Er-r
Has each drum been inspected to identify the presence of any void spaces? eVA
Have all drums with void apaces been fllíed With tailings sands or soil?
Which tailings cell was the material placed in? t -3

Was the material placed on a tailings beach area of the cell or on an area of the cell that was underlain
by tailings sands?
fitio.-4--ifi.r4a.
Was the material segregated livin any Mill material or equipment disposed of in the cell?
Was the material segregated from byproduct material from other ISL sources disposed of in the cell? Yrs
• No.: PBL-10
R.ev. No.: R-3.4
Date: February 1, 2018
ENERGY FUELS RESOURCES (USA) INC. STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal Page 12 of 13

Manifest or BOL #: - 3 2- i3yp pootv
Have the thickness and placement measurements been verified and documented for the disposal area
by the engineer, specifically:
Engimer's or
• Environmental
Coordinator's
• Initials
Was the material placed in a cell approved by the executive Secretary
for ISL waste disposal? fte .tor Documentation of approval 21.40.0. # uriteeyy_i_.*..... r
Was the ISL material segregated from disposed Mill material and other
ISL material? /'',5
Refer to plat(s)used to confinn. e...// 3 /k. 2 0,40•04/ 4004
Was the maximum lift thickness above tailings less than 4 feet
thick?
-
Was the maximum lift thickness of subsequent lifts less than 2 feet
thick? 4* Has 4 foot of tailings sands been maintained under each disposal
area9 . t V o
Refer to drawings used to confimi ce // .7 GIs/ t00.--•-tis' ,•
Is the bottom of each disposal area at least 12 feet from the sides or
dikes of the tailings cell? Yes
Refer to drawin used to confinn (e1ð3 f A 0.1...".•
Will the elevation of the material exceed the plane or grade of the
• elevation of the uppermost flexible membrane liner of the cell?
A4
ilow was this confirmed (e.g., survey or review)
How was the area compacted? Was each lift compacted by heavy equipment (such as a Cat D-6) at
least 4 times prior to placement of subsequent lifts?
P^S r.A.04,41 AAA. o—LOLCr Oc4- 4 Li 1
Were void spaces filled with tailings?
_Ye-4
Was the shipment properly covered?
Ye-5 t (ir eA- 6e) 4"C•
No.: PBL-10 Rev. No.: R-3.4 Date: February 1,
2018
ENERGY FUELS RESOURCES (USA) NC. STANDARD OPERATING PROCEDURES
Title: 1le.(2) Byproduct Disposal Page 13 of 13
Manifest or BOL #: i 4-0 3 Z- try it 0,c., vi‘P e
Are additional settlement monitors required to be placed for this generator?
If required, where were the settlement markers placed?
Radiological receipt survey measurements:
Breathing Zone:
1. Was a Breathing Zone Sample collected? Yes
2. If yes, what were the results of the sampling?
Was a photograph taken during the unloading activities r No
Generator of Byproduct material:
Contraled Elevation used (Cell 3)
Area
Strata Energy
Elevation
5612.6
Transit Shot
Initial shot for trench 4.88
Top of trench 5607.98 9.5
Bottom of -trench 5602.72 14.76
Initial shot used for material 4.88
Top of material in trench 5607.08 10.4
Top of cell 3 Liner 5608.5
Feet below liner 1.42
5‘-k rr'
q- c) 32_ Oyp-12 Av et--
Energy Fuels ReAources (USA) Corp.
White Mesa Mill Transaction No. 6425 S. Highway 191 54349 Blanding UT 84511
Date Time Scale
In: 05/30/2019 15:58 1
Out: 05/30/2019 16:39 1
Vehicle ID: 1001
Trailer ID:
Account ID: STRATA ENE STRATA ENERGY
Order ID:
Owner ID:
Material ID: 11(e)2 Mat 11(e)2 Material Receipt
Destin, ID: BLANDING
Gross: 51740 lb (M)
Tare: 41440 lb
Net: 10300 lb
Comments: CONTAINER NO NUMBER
Operator: 4 Ch rge by Weiglat
Signature:
(1. Ci = 3.7E10 Bq) Radionuclides Present: Natural Uran'um, Ra-226, Th-230, Pb-210
Physical Form: Surface contamination on processing wastes
Chemical Form: U04, RaCO3, ThSO4
Package: roll-off container which meets the requirements of 49 CFR 173.410
Volume of Material: 30 YclA3
Total Activity: 9.66E+07 Bq (2.61E-3 Ci)
To:
Facility: White Mesa Mill
License #: UT 190047 Amendment #8
Address: 6425 S. HWY 191, Blanding, Utah, 84511
Contact Person: Terry Slade
Phone #: [phone] x113
From:
Facility: Strata Energy, Inc. Ross Project
License #: SUA-1601
Address: 2929 New Haven Rd., Oshoto, WY, 82721
Contact Person: John Durand
Phone: [phone]
HazMat Company ID: 174549
Proper Shipping Name: UN 2912, Radioactive material, low specific activity (LSA-I) non fissile or fissile excepted , 7
Radionuclides Present
Radionuclide
U (nat)
Ra-226
Th-230
Pb-210
Po-210
Quantity (Bq)
1.19E+07
4.89E+07
3.38E+07
1.81E+06
1.64E+05
Exclusive Use Shipment
BILL-OF-LADING & LICENCE MATERIAL SHIPPING FORM
Shipment #: 19-032 Byproduct
Carrier Name: Greenfield Logistics LLC
Carrier HazMat Registration #: 0620175520222
"I hereby declare that the contents of this consignment are fully and accurately described above by the proper shipping name,
and are classified, packaged, marked and labeled/placarded, and are in all respects in proper condition for transport
according to applicable intemational and national governmental regulations."
Shipper's Signature: Date:

24 Hr Emergency Response Number: 435-669-9858 re c.f,f_jratirscovci

I
No.: PEL-10
Rev. No.: R-3.4
Date: February 1,
2018
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: lle.(2) Byproduct Disposal Page II of 13
ATTACHMENT 2
11e.(2)1HPRODUCT MATERIAL DISPOSAL DOCUMEN'TATION FORM
Date: 6:(LIIICL
Name of employee receiving the load: pc- 'AS
Generator of the Byproduct Material: S',44,z OA, 12 AA. t S
Shipper's Manifest or Bill of Lading number: 2014 —SZ l - 00 1
Was the State of Utah given noticeto the receipt/disposal activities associated with this load?
No
Who gave and when was the notification given?
it047
Description of byproduct material disposal area/activities:
r I c4— Ç.+-
Has each drum been inspected to identify the presence of any void spaces? AM -
Have all drums with void spais been fllled With tailingi sands or soil? rnA
Which tailings cell was the material placed in? Cc 1 t 3
Was the material placed on a tailings beach area of the cell or on an area of the cell .that was underlain
by tailings sands?
Was the material Segregated from any Mill material or equipment disposed of in the cell?
Was the material segregated from byproduct material from other ISL sources disposed of in the cell?
No.: PBL-10
Rev. No.: R-3.4
Date: February 1,
2018
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Tide: 1 1 e.(2) Byproduct Disposal
Page 12 of 13

Manifest or BOL #: •zo a I -60 (
Have the thickness and placement measurements I;een verified and documented for the disposal area
by the engineer, specifically:
Engineer's or
Environmental
Coordinator' s
Initials
Was the material placed in a cell appioved by the executive Secretary
for ISL waste disposal? re/ Documentation of approval L,1.4.,,t itte Rrito 4,71 Am-, fir
Was the ISL material segregated from disposed Mil1 material and other
ISL material? rr,f
Refer to /gags) used to confirm. twi ..1 Ats. E A jo/ Are
Was the maximum lift thickness above tailings less than 4 feet
thick?
Was the maximum lift thickness of subsequent lifts less than 2 feet
thick?
Has 4 foot of I-filings sands been maintained under each disposal . area? re5 Refer ti drawings used to confirm 4.il 3 Ad, 0 ago.,
Is the bottom of each disposal area at least 12 feet from the sides or
dikes of the tailings cell? Y. 1
.Refer to drawings used to confirm. . ii ii. ..-.0$.
Will the elevation of the material exceed the plane or grade of the
elevation of the uppermost flexible membrane liner of the cell?
eas• How was this confirmed (e.g., survey or ) 5
How was the area compacted? Was each lift compacted by heavy equipment (such as a Cat D-6) at
least 4 times prior to placement Of subsequent lifts?
c. t" I t 4-Z44-Gs
Were void spaces filled with tailings?
Was the shipment properly covered?

No.: PBL-10
Rev. No.: R-3.4
Date: February 1,
2018
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal

Page 13 of 13

Manifest or BOL #: Z.t.) bot
Are additional settlement monitors required to be placed for this generator?
If required, where were the settlement markers placed?
AA
Radiolo 'cal receipt survey measurements: 3 PA R i&-r- c es-S eS 'Fr; c.ck

13 AI LI.
Breathing Zone:
1. Was a Breathing Zone Sample collected? (13oWf i
2. If yes, what were the results of the sampling
4NA-6- c..-Lbk,
Was a photograph taken during the unloading activities?
STRAIGHT BILL OF-LADING
ORIGINAL—NOT NEGOTIABLE
\GRtENDIELD LOGISTICS
Shipper No. 2019-SR1-001
Cairier No. N/A
Date 6/3/2019
(NAME OF CARRIER) (SCAC)
Time 130
au Dc5vay must sppc.ibcrorc cniiueesnauc Clit as odicrwe provided in item 430. Sec. I, .
To: Consignee Energy Fuels
- Street 6425 South HWY 191
City: Blanding State: UT Zip Code: 84511
From: Shipper Cameco Resources
Street: 762 Ross Road
City: Douglas State: WY Zip Code: 82633
4 hr Emergency Contact Tel. No: 1 [phone]
Mr. John Zaldam Contractual Agreement with Quantum Murray IZeluzle: Route: See map umber N/A
No.of units & coma= type HiM Basic Description
Paws Sideolike Nista limit OisRisetElestioi Wiiiiketil otWA), 'Waft irstee oer mot taxa, 112.213 %
Total Quantity vam 4,..,
Weight Nisbet i., Rate Charges
Wht Calder Up: 010
I Roll Off X UN2912, RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY (LSA-1),
NON FISSILE, CLASS 7 18.9ma (24.7yd,
RADIUE: NATIAL
226
PHYSICAL FORM: SOLID
CHEMICAL FORM: UNAT WITH DAUGHTERS
TOTAL ACTIVITY: 11.25E8 Bq (0.004 Ci)
EXCLUSIVE USE SHIPMENT: THIS VEHICLE IS ASSIGNED FOR
EXCLUSIVE USE OF CAMECO RESOURCES, INC. UNDER PROVISIONS
OF 49 CFR173.427 INCLUDING EXEMPTING FROM MARKING AND
LABELING REQUIREMENTS .
DO NOT LOAD OTHER FREIGHT IN S VEHICLE, TRANSFER EN
ROUTE, OR BREAK SEAL
PLACARDS TENDERED: YES: X NO: Rom C.O.D. TC): AntatEss twA
Note-(1) Vilrowbs Ws is dowikett shispestare MOW swots
COD An'i $ WA NW. ME: WA to ape:Wally ea wain *saved fx declared wine crib. raw% is Rao= She r wad o diehard was& Of do pearatc isientrweedloily Wed by the Aimee le te met exceeding pa •
buoy &doe dot the woods edit cwidgentsw we lidly sod egawsdIdeseedrol *we the Www *pees =mesa an eisollisiL Petheatd. oohed awl WheloWeawsk holi h, al ImPlArin Myer catlike kr tram Fat amid* a appliiile inlemitemai end *
PREPND o COLLECT o
0,1 When the applicable onlfpowieiew ipecilY a desissiotardo oink& lieility SWenswool aselstisos .
about a zebus era who dedssoket by the %Wpm sad We shipper does set Mame ths crakes Ibilley or dirdsse . Wee. the artieee liability she be haired 10 the mdist pevikd Ilw nth plavisfam $14 Mgt haw 172.
a Ow. 6 'Wooed isle be *Waal is the coes*le • wag* sougall as the reariper. tie =Wow sew stoweest
',WM Culmall WA
GI) Cassnoilise retriting *del of addliisoal are sr sloths. is bendliso es flexing suet be me aisloularl retard to to wore trit trompesstito. See
Sectieft 30. Nth W LARS. PM Rilk Moth= esiRelesesrniedthoges
ON WAAL? OF SHIPPER AO the Made' The owlet WA let rake Sway Wild ehipoest "Wheel meet OW.' set al eiho• 'FREIGHT OIARERIS
awl Rafts la) of acCorna Maw asð coaltkas fa a Ha amok add= - P WAS Warp WA
FREIGHT PREPAID
comp what Clock lox ildurges SISMILlafillingld botai tisk o are IQ let celkoleth
=BM ohissse Se doolesIte• aw,... iw,b..rww 4,1‘111WWiws. dwWWW.... I Wee sersoes arises =lion!. twraii oresstiew woo o nisi tenteetsel elheshess etwwwl hwloh ostiewiaisl desied etieftestseheo elieh isil miff We seel mewls* ......m......gi..........4.0.,............4.1 park..ftbi. papraro.yeAsands1)•swes Neon in its owl Ow of Mks, at aildrilastbs. ifftissaelo.oWermewhlivoi warder osier. ihnormaisaileakaiim k is wolielayllpoidaMort ssitionfersey oitssid am army afvoiloads la irlis•Mosrasfilmok meimmmoiri ig a .70644141.1.11% AO ...2.04..., k ania aham wan.; isa••••••bad•aban• twin* pia pitaysiaar P,th....ih....I.A4b..eb*si•a ...11". . 6.64. Mho Wm.& ...wigs els•Oikairmi ir.bi...n.abli.4. *imam* mile or la k Wirt via A ilk Imliitiftwarld amigo*. i. di. e....11Th.q....fairame lawaysso•hobia.441....4...0.1
SHIPPER: CAMECO RESOURCES CARRIER: GREENFIELD LOGISTICS ,
PER PER / -
DATE 6 2C DATE

RSQ:
Operations:
Elution No.

•

Rev 5 - October 19, 2017
Page 1 of 1
WYO-RPP-FORM-031 Bill of Lading.xisx

Controled Elevation used (Cell 3)
Area
Smith Ranch
5612.6
Elevation Transit Shot
Initial shot for trench 4.88
Top of trench 5608.38 9.1
Bottom of trench 5603.1 14.38
Initial shot used for material 4.88
Top of material in trench 5607.68 9.8
Top of cell 3 Liner 5608.5
Feet below liner 0.82
SO L --4-
2o 1 6'1 - SRI-(501
Gross: 51540 lb (M)
Tare: 43940 lb
Net: 7600 lb
Energy Fuels Resources (USA) Corp.
White Mesa Mill Transaction No.
6425 S. Highway 191 54352 Blanding UT 84511
Date Time Scale
In: 06/04/2019 07:25 I
0ut: 06/04/2019 08:08 1
Vehicle ID: 1001
Trailer ID:
Account ID: 11(e)2 WYO SMITH RANCH
Order ID:
Owner ID:
Material ID: 11(e)2 Mat 11(e)2 Material Receipt
Destin. ID: BLANDI,NG
A •
Comments: TRL#GFLU001139
Operator: 4 Charge by Weight -00( -0/ 00/
Signature:
ENERGY FUELS
and Radiation Control
JUN 1 2 2019
Energy Fuels Resources (USA) Inc.
6425 South Highway 191, PO Box 809
Blanding, UT. US, 84511
435 678 2221, fax [phone]
www.energyfuels.com
1 K-20(9-005589
June 10, 2019
VIA Electronic Mail (PDF) and UPS
Mr. Ty Howard
State of Utah Department of Environmental Quality
195 North 1950 West
PO Box 144880
Salt Lake City, UT 84114-4880
Dear Mr. Howard,
Re: 11e.(2) Byproduct Receipt Notification
Pursuant to Radioactive Materials License (RML) UT1900479 condition 10.5.F, Energy Fuels Resources
(USA) Inc. is hereby notifying the Division of Waste Management and Radiation Control that the White
Mesa Uranium Mill will be receiving and disposing of three loads by June 25th, 2019.
If there are any questions regarding these shipments or the scheduling of the disposal activities feel free to
contact me at the White Mesa Mill at 435.678.4114.
Regards,
Garrin Palmer
cc: Denver Central Files
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3.4 STANDARD OPERATING PROCEDURES Page 11 of 13 Date: February 1, Title: 11 e.(2) Byproduct Disposal 2018
ATTACHMENT 2
11e42) ByPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date: g/711'1
Name of employee receiving the load: 3";sfi.A. Pe. r k vti
Generator of the Byproduct Material: 5 Z. 4- ia - c
Shipper's Manifest or Bill of Lading number: S o t - SATZ -Co ti
Was the State of Utah given notice to the receipt/disposal activities associated with this load?(/ or
No
Who gave and when was the notification given?
(4.)-11/4
Description of byproduct material disposal area/activities:
S
Has each drum been inspected to identify the presence of any void spaces? it/A-
Have all drums with void spaces been filled with tailings sands or soil? A4A
Which tailings cell was the material placed in?

Was the material.placed on a tailings beach area of the cell or on an area of the cell that was underlain
by tailings sanciV ,
4- 44.4_ sow.A.ta
Was the material segregated from any Mill material or equipment disposed of in the cell? r 5.
Was the material segregated from byproduct material from other ISL 'sources disposed of in the cell?
No.: PBL-10
Rev. No.: R-3.4
Date: Febniary 1,
2018
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 11e.(2) Byproduct Disposal Page 12 of 13

Manifest or BOL #: ZOI Z
Have the thickness and placement' measurements been verified and documented for the disposal area
by the engineer, specifically:
Engineer's or
Environmental
Coordinator's
Initials
Was the material placed in a cell approved by the executive Secretary
for ISL waste disposal? %es
Documentation of approval vvr1.444,„,t # kritravvrr _Is. t
-
Was the ISL material segregated flow disposed Mill material and other
ISL material? y,ea-
Refer to la s used to confirm. i / t /it Was the maximum lift thickness above tailings less than 4 feet
thick? y
Was the maximum lift thickness of subsequent lifts less than 2 feet
thick? lif --Of Has 4 foot of tailings sands been maintained under each disposal
area? .
Refer to drawings used to confirm /.., / 3
Is the bottom of each disposal area at least 1 2 feet from 1e sides or•
dikes of the tailings cell? Y;s
Aefer to drawings used to confirm, e...11 3 4.0.47: #94..........."
Will the elevation of the material exceed the plane or irade of the
elevation of the uppermost flexible membrane liner of the cell?
.4

How was this confirmed (e.g., survey or review)

L..04or 4ie
How was the area compacted? Was each lift compacted by heavy equipment (such as a Cat D-6) at
least 4 times prior to placement of subsequent lifts?
4 AA. +
Were void spaces filled with tailings?
Was the shipment properly covered?
Ye see._ 1,
Radiological receipt survey measurements:
r- c, rL j
1. Was a Breathing Zone Sample collected?
2. If yes, what were the results of the sampling?
Se.++AlLe
Breathing Zone:

No.: PBL-10
Rev. No.: R-3.4
Date: February 1,
2018
ENERGY FUELS RESOURCES (USA) INC.
STA/s1DARD OPERATING PROCEDURES
Title: 11042) Byproduct Disposal
Page 13 of 13

Manifest or BOL #: 201 4 - .9,4-T2 --Oa
Are additional settlement monitors required to be placed for this generator?
If required, where were the settlement markers placed?
Was a photograph taken during the unloading activities. or No
Controled Elevation used (Cell 3)
Area
Smith Ranch
5612.6
Elevation Transit Shot
Initial shot for trench 4.88
Top of trench 5608.38 9.1
Bottom of trench 5603.1 14.38
Initial shot used for material 4.88
Top of material in trench 5607.68 9.8
Top of cell 3 Liner 5608.5
Feet below liner 0.82
2019 - - .5.472-00ci

STRAIGHT BILL OF-LADING
ORIGINAL—NOT NEGOTIABLE
OltEENFIELD LOGISTICS

Shipper No. 2019-SAT2-004
_
Canier No. N/A

(NAME OF CARRIER) — (SCAC)
CH ipni =IC CII SS
provided in inn 430, Sea. I. .
To: Consignee Ener Fuels gy
Street 6425 South HWY 191 .
City: Blanding State: UT Zip Code: 84511
Front: Shipper Cameco Resources
Street: 762 Ross Road
City: Douglas State: WY Zip Code: 82633
24 hr Emergency Contact Tel. No: 1 (905) 8854745
Mr. John Zaidan; Contractual Agreement wšth Qwanhan Murray
Route: See map Whole:
Number N/A
No.of Nits &
conteinar Npe
' LIM Basic Description
Paper nippily) Nook Hood CloOkollicallca 1 , a NA), Paddiaro, pa 172.101, Iwo. M.303 1,
Total Quantity (WW101, Worm Wm, 219.)
Weight mod*
Came*
Rate charges
(Por Collor 1200110)
1 Roll Off UN2912, RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY (ISA-1),
NON FISSILE, CLASS 7 18.9rtf (24.7yd")
E: NATURAL RIUM- 226 •
PHYSICAL FORM: SOLID
CHEMICAL FORM: UNAT WITH DAUGHTERS
TOTAL ACTIVITY: -1.25E8 Bq (0.004 CI)
EXCLUSIVE USE SHIPMENT: THIS VEHICLE IS ASSIGNED FOR
EXCLUSIVE USE OF CAMECO RESOURCES, INC. UNDER PROVISIONS
OF 49 CFR173.427 INCLUDING EXEMPTING FROM MARKING AND
LABELING REQUIREMENTS
DO NOT LOAD OTHER FREIGHT IN THIS VEHICLE, TRANSFER EN
ROUTE, OR BREAK SEAL . .„
PLACARDS TENDERED: YES: X NO: REMIT C.O.D. TO:
ADDRESS N/A
Nate.0) Whoa Dr wo Ddepoodest as wise. iblwasare nadeed Waft Walk* 06 010001161010o1 orobahad wan of tho ma% a iblloom Tbo wad addend Woe tido peoperNie bee* *milk* alaleil by De Wpm vibe notoweidne on
' "uw1"'""w ".".°°"1""nlialccqaW1.0.106 &HY 602 womb* ireolDol Woo IN theeniernenene one sae se versiect prima nenneone iredvienwain ead ma in all rapeas ke poporooaDdon Do loaapce1 amain wapperable Inionsaioal ma
COD 0 WA COZ.
FEE: WA PRETAID a cower RI
finvielinelv nierenvieessen& liaiodo;d1loaalet1 MIN, nliWil 00"40,0101101116110111. • atom a Wan rtro moire daboalico tobcdippa ad OD duppadea aa Mao to aeo110070(arWabouno aoi Wawa Oat* Miami se the cassia= AL oboe 2W coda% 11thiliiyor *due sone, Meciala611thayilan be WOW UM atom proviii0 by nab wham SHINN. ban 172. ON BMW OF SHIPPER „stall wialIN secoow ao lbemœloor. Outossaaor ilpo Oa WNW% Oaten= °Wm* NJA A3) Coearoallasopirlos special or aliktood am se Westin 16 boodliap a atoolovolo be so ordialsol to alb arapprailoo Oa DoWludas owe tbe arta 10•11 not ado dewy 6004 1000GHT CHARGES
Swim 2(e) alien 360. DIN pilaw& Prolabid1W, ail 3161o010W damp Amor Wilma mato of Del* pal •11 paa PREIGHTPIEDANI 4116 00211611 OW 0f00 Coma me extoadilisstr s mit aro& atikko. 1041001110 t WOW obaga. WA owptilloo Clock boo Warps/ 0110/0000Madais) -bozo Opbt o in a begolloma
maim..w..,.,b,„...0,0,..„,a inbei,...ribi.nnaudi. .066,6„,,,,, ob„ d. pprork..6.i.b.„. I, wpm pa wax as••••••••••0•••••••••••••••••••••ivoorossereomesmo•mo.omiewd. redvievi oineunnovvies anioniveinmed mirky* WOMNINII Intilleoottlit •o•Ind =swim ray plow troweeplios I* pro•Wom alai pommy arderilm lookoolpror foam rib orial plow ardemogy el WA dmindow. Ws ils rook etluna• op &raw le•Mborani.m *ma* iet mil dririst le inemboalympori mogul. anisrafie or rty 4 aid 1.1.110 I....*.rmYPwa.g.il..""aaa""4.""t.f."Y".Y,."IM."""kawa.Y.idr.swIKOYsmy enio• l• b• Woo* MA 1.1•10•1 di a• mere.% warmed t• v••••vso won. i.e.r...a.••••••a•ri... e••••••to.oeme. •\ ridoerimerenilvee Iv elearuilb el evens immod.vvrivol•no theikole•ml es im.od emus wig ••••Idorm•imie vned motif* Ow ovi vvierernmervvi *m.o.
,
SHIPPER: CAMECO RESOURCES , CARRIER: GREENFIELD LOGISTICS ,
PER PER /
DATE t 4,ii I Ci DATE e, - 67 — /Pr—
•

RSO:
Operations:
Elution No.

Rev 5 - October 19 2017
Page 1 of 1
WYO-RPP-FORM-031 8111of La chng.xlsx

Comments: GFLU2160
Operator: 4 Charge by Weight
Signature:
Oolq SA--n-z-oloc(
Energy Fuels Resources (USA) Corp.
White Mesa Mill Transaction No. 6425 S. Highway 191 54356
Blanding UT 84511
Date Time Scale
In: 06/07/2019 12:11 1
Out: 06/07/2019 12:49 1
Vehicle ID: 1001
Trailer ID:
Account ID: 11(e)2 WYO SMITH RANCH / HIGHLAND
Order ID:
Owner ID:
Material ID: 11(e)2 Mat 11(e)2 Material Receipt
De4tin. ID: BLANDING ,
Gross:
Tare:
Net:
52500 lb (M)
43500 lb
9000 lb