DRC-2015-008648 - 0901a068805cf165

LLRW/U-Mill Document Scanning Form
Document Type
Incomingjj ( Outgoing)
DRC Program
LLRWl "1 GSAi I U-Mill
Internal
Facility/License # U-ftf 00 &71 I UkfC rft&A-tMlOC
Document Date hlfhy&Wfr&ft 3^ 7^> 15"
Document Title MpU/Lg 75; 4<&/$oM-T0K
Authors)
le Folder S
>n| I
:CZ3
Check Applicable Folder Selection
Application! V Correspondence! *2|
Compliance! / \ License! I
GW Permi
Check Applicable Document Class
Analytical! j Fi
Emallj [Inspection Report
OtheryT**
Letter
Monitoring Report
CP
O
O
o
Department of
Environmental Quality
Alan Matheson
Executive Director
GARY R. HERBERT
Governor
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Scott T. Anderson
Director
Spencer J. Cox
Lieutenant Governor
PRC- zo\e>-oodQ>i+<d MEMORANDUM
THROUGH:
FROM:
TO:
DATE: November 30, 2015
SUBJECT: Engineering Module 73. Inspection of Disposal of Bulk Byproduct Material November 16,
2015. Radioactive Materials License UT1900479 (License) - Energy Fuels Resources
(USA) Inc. (EFR) White Mesa Mill, Blanding, Utah
On November 15, 2015,1 traveled to the White Mesa Mill to perform an inspection of in-situ leach (ISL)
waste disposal operations on behalf of the Utah Division of Waste Management and Radiation Control
(DWMRC). This inspection responds to a 1 le.(2) Byproduct Receipt Notification from EFR, dated
October 21, 2015. EFR is allowed to dispose this byproduct material in Tailings Cell 3 only, which is
allowed by License Condition 10.5 of the EFR Radioactive Material License.
On October 21, 2015 the DWMRC received notice that EFR would receive four loads of 1 le.(2) byproduct
material, and intended to dispose of that waste in Cell 3 on October 16, 2015. Four loads were ultimately
received prior to the commencement of the burial activity.
I checked in at the White Mesa mill at 7:15 AM on October 16, 2015, and asked to see David Turk, Site
Manager for Environmental Health and Safety. Mr. Turk assigned Garrin Palmer to oversee the disposal
operation.
While waiting for Mr. Palmer to complete another task, Mr. Turk and I visited the former Roberts Pond site
where backfilling operations are nearly complete. See Photo 1 in the attached Photo Log.
We also reviewed in the field the grading of the ore pad. Heavy rain overnight left virtually no standing
water. See Photos 2 through 4 in the attached Photo Log.
At approximately 8:00 AM the crew assembled at the disposal area with the requisite equipment (a loader).
The four loads were disposed in one excavation. The field crew used the appropriate paperwork, i.e.
Revision 3.3 of Procedure PBL-10, to guide the operation.
Material disposed consisted of:
• Loose miscellaneous decommissioning debris from Cameco, Smith Ranch, in Douglas, Wyoming,
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]
urww.deq.utah.gov
Printed on 100% recycled paper
C-2015-54
Memorandum: Inspection of June 16,2016
Page 2
shipped by Greenfield Logistics, bearing Shipper Numbers 11/15-34 and 11/15-37; and,
• Loose miscellaneous decommissioning debris from Cameco, Smith Ranch, in Douglas, Wyoming,
shipped by Greenfield Logistics, bearing Shipper Numbers 11/15-38 and 11/15-39.
The bill of lading for each of these loads appears in the attachments to this report.
Mr. Palmer, with assistance from Tanner Holiday, surveyed the level at the bottom of each excavation prior
to waste placement. Using a front-end loader, the crew placed the waste in the excavations and tamped it
down. Mr. Palmer then surveyed the elevation of the top of the waste, and the crew filled the excavation to
the top with soil. As Photo 5 from the photo log shows, the solution level was within 18 to 24 inches of the
top of the cover; thus, complete compaction of the cover during the inspection was not possible.
The crew wheel-walked the cover soil to provide compaction once the fluid level in the excavation had
subsided. Mr. Palmer provided me two photos of the compaction operation. Those photos appear as the
final attachments to this report.
EFR appears compliant with Part 10.5.E.(2) of the RML with respect to the elevation of burial. It appeared
that all provisions of the approved disposal SOP were followed during placement and burial of the bulk
waste.
Finding: EFR appears to have followed applicable provisions of the RML and of the SOP for the burial
operation.
Recommendation: I recommend closing out the inspection of November 16, 2015.
Attachments: Receipt Notification dated October 21, 2015, Bill of Lading and Disposal Documentation for
each load disposed on November 16, 2015, photos of the disposal operation.
ENERGY 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
October 21, 2015
VIA Electronic Mail (PDF) and UPS
Mr. Scott Anderson
Director of Waste Management and Radiation Control
State of Utah Department of Environmental Quality
195 North 1950 West
PO Box 144880
Salt Lake City, UT 84114-4880
Dear Mr. Anderson,
Re: 1 le.(2) Byproduct Receipt Notification
Pursuant to Radioactive Materials License (RML) UT1900479 condition 10.5.F, Energy Fuels Resources
(USA) Inc. is hereby notifying the Division of Waste Management and Radiation Control that the White
Mesa Uranium Mill will be receiving and disposing of four loads of 1 le.(2) byproduct material by November
16, 2015.
If there are any questions regarding these shipments or the scheduling of the disposal activities feel free to
contact me at the White Mesa Mill at 435.678.4113.
Regards,
David Turk
Environmental Health & Safety Manager
Energy Fuels Resources (USA) Inc.
cc: Denver Central Files
[No.: PBL-10
| Rev. No.: R-3.3
! Date: November 13,
: 2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 11 of 13
ATTACHMENT 2
lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date:
Name of employee receiving the load: T^j-r-y $K+-JLf
Generator of the Byproduct Material : ^ r. ,^ — <;^,,^u fZ^«^- U
Shipper's Manifest or Bill of Lading number: U \
Was the State of Utah given notice to the receipt/disposal activities associated with this load'Z^Yes}>r
No
Who gave and when was the notification given?
Description of byproduct material disposal area/activities:
Has each drum been inspected to identify the presence of any void spaces? /Is/^r
Have all drums with void spaces been filled with tailings sands or soil? Ay A
Which tailings cell was the material placed in? CJL\K ~3>
Was the material placed on a tailings beach area of the cell or on an area of the cell that was underlain
by tailings sands?
Was the material segregated from any Mill material or equipment disposed of in the cell?
_ Yes :
Was the material segregated from byproduct material from other ISL sources disposed of in the celj?
YcJ
No.: PBL-10
I Rev. No.: R-3.3
Date: November 13,
|_2014 _
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 12 of 13
Manifest or BOL #: it|i<S -^4
Have the thickness and placement measurements been verified and documented for the disposal area
by the engineer, specifically:
Was the material placed in a cell approved by the executive Secretary
for ISL waste disposal? Yes
Documentation of approval L>V<»K, fr 'A -r/quo'tr? 7
Was the ISL material segregated from disposed Mill material and other
ISL material? /ts
Refer to plat(s) used to confirm. f.tli 3 j/<. I 0./
Was the maximum lift thickness above tailings less than 4 feet thick?
Was the maximum lift thickness of subsequent lifts less than 2 feet
thick?
Has 4 foot of tailings sands been maintained under each disposal
area?^
Refer to drawings used to confirm /W/ J C^r*?.
Is the bottom of each disposal area at least 12 feet from the sides or
dikes of the tailings cell? yfJ
Refer to drawings used to confirm, f.et! 3 £*r>$A /)^^,v^<
Will the elevation of the material exceed the plane or grade of the
elevation of the uppermost flexible membrane liner of the cell?
A/Q
confirmed How was
j?
this (e.g., survey or review)
Engineer's or
Environmental
Coordinator's
Initials
4t
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?
Were void spaces filled with tailings?
VLS
Was the shipment properly covered?
V'ti
No.: PBL-10
Rev. No.: R-3.3
Date: November 13,
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 13 of 13
Manifest or BOL #: u | l.C- T-{
Are additional settlement monitors required to be placed for this generator?
.A/A
If required, where were settlement markers were placed?
Js/A
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?^Ye?)pr No
STRAIGHT BILL OF LADING
ORIGINAL-NOT NEGOTIABLE
Greenfield Logistics
Shipper No. nl\r-%t
Carrier No.
Date df*-!^
(Name of Carrier) <SCAC)
on Collect on Delivery shipments, In* latter* COD muil appear before consignee's name or aa othenvna
provided in Item 430, Sec 1
To: Energy Fuels_
Street 6425 South HWY 191
City ^landing State UT Zip Code 84511
From: Shipper CAMECO RESOURCES. INC.
Street: 762 Ross Rd
Citv Douglas . State WY Zip Code 82633
24 hr. Emergency Contact Tel. No: 905-885-8745
Route: Vehicle-
Number
No. of
unite &
container
type
HM Basic Description
Proper Shipping Name, Hazard Class,
Identification Number (UN or NA), Packing Group, per 172.101,172.202,172 203
Total
Quantity
(Weight, volume, Gallons, etc.)
Weight
(Subject to
Correction)
RATE Charges
(For Carrier
Use Only)
1 Roll
off
XX UN2913, RADIOACTIVE MATERIAL, SURFACE CONTAMINATED OBJECT
(SCO-D.CLASS7
3U.4ya*
27.8m'
RADIONUCLIDE: RESIDUAL NATURAL URANIUM & ASSOCIATED DAUGHTER
PRODUCTS
PHYSICAL FORM: SOLID
CHEMICAL FORM: NATURAL URANIUM OXIDE UO4-2H,0
TOTAL ACTIVITY: 3.7E7 Bq (0.001CI)
TRANSPORT INDEX: N/A AS PER 49CFR172.203(d)(5)
PLACARDS: RADIOACTIVE 7
EXCLUSIVE USE SHIPMENT: THIS VEHICLE IS ASSIGNED FOR EXCLUSIVE
USE OF CAMECO RESOURCES, INC. UNDER PROVISIONS OF 49 CFR 173.427
INCLUDING EXEMPTING FROM MARKING AND LABELING REQUIREMENTS
DO NOT LOAD OTHER FREIGHT IN THIS VEHICLE, TRANSFER EN ROUTE
PLACARDS TENDERED: YES: X NO • REMIT CO D. TO:
ADDRESS
Nortel) Where the raft ts rjepenaant on value shippers are required to state epectrcafly on
writing me agreed or declared Vitus ol the property. IS roeowe The agreed or declared
value of the property Is hereby specKcsly stated by Ins shipper to be not
exceeding . oer
(Z) Where me epprrcebfe tariff provtslone specify t HmnatfcMi of Ihe center's tiabarty absent e
releese or a value declaration oy the snipper end me shipper does not release Ihe carrier's
l>*t*ty oi declare e value, the carrier's leblMy shsu be United lo the Menl provided Dy such
provisions See NMFLIwm 172
(3) Commodities requiring special or additional care or attention In handling or stowing must
pe so merited and packaged as to ensure safe transportation See Section 2(e) of Kern 360,
8*18 ol Lading. Freight BHI3. and Stetements ol Charges and Section 1(a) of the Conlrect
lerrris end conditions roi a tut of such articles
I hereby declare that ihe contents of this
consignment are My and accurately described above by the proper shipping name end are
classified, packaged, marked, and
labeted/feuicere'. and are In an respects in
proper condition for transport according la
applicable InternaeonBl and national
governmental regulations
ON 9*JML/ OF SHIPPER
Sutpja Seaen 7 «rrrw IttheaNnmerieWte
Tht tmm thes ret meto eehery ml in
el hreht ana el «tur Mri crieeet
tsrgntfureeCMtJgntt)
COO FEE
PffcPAlO
COLLECT I
TOTAL
CHARGES •
FREIGHT CHARGES
FHEJOifT WIS PAID Ct*ek*mit**im
«M>e*ef*«*fM**V 4>TtlOM
l*^e.e**«eMd MM
DECEIVED. subject <o the ciasaflcalkms and isnffs in effect on die daft of issue of tnii BUI of Lading, the property described itwe In apparent good order excepi es noted (contents end condition of contents of packages unknown), marked, consigned, end
destined u indicated above wtiteii Mid canter (the word carrier being understood Itvoughout this contract as meaning any person or corporation In possession of INs property under the contract) agree* to carry to ft* usual place of dettvary at uW destination.
tt on <uroute, otnerwee to deliver to another earner on the route to said destination It H mutually agreed es lo each carrier of el or eny of, said property over or erty portion of Hid route to destination end as to each party at any Interacted In all or any
***d property. that every serve* to be performed hereunder shell be subject to a the bill of lading term end cjondrttone (n the gmenMng ctessifteeUoft on the date of the ehlpmant
Shipper hereby certifies irtat rte Is rarrtttar wto ail the lading ierms and wndiions in the governing desslflcaLlon and the said terms and condltone an hereby agreed to by the shipper and accepted for Nrnseif ems his assigns.
SHIPPER: CAMECO RESOURCES, INC.
PER
CARRIER
PER
Rev 3-Apr 02, 2015
Page I of 1
J:\4) Radiation Protection Program WYO-RPP-01 (Volume IV-Hcalth Physics)\WYO -RPP-01 (Forms)\WYO -RPP-01.07I Bill of Lading-By-Product-
SCO.doc I^L/
ll/lS--3M
Q.O Y
Smith Ranch
Controled Elevation used (Cell 3)
Area
5612.27
Elevation Transit Shot
Initial shot for trench
Top of trench 5606.96
Bottom of trench 5599.26
Initial shot used for material
Top of material in trench 5606.32
5.65
10.96
18.66
5.65
11.6
Top of cell 3 Liner 5608.5
Feet below liner 2.18
I No.: PBL-10
! Rev. No.:R-3.3
Date: November 13,
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 11 e.(2) Byproduct Disposal
Page 11 of 13
ATTACHMENT 2
lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date: ),/•>/, C
Name of employee receiving the load: 1)^1. J TL^k.
Generator of the Byproduct Material: Cc^*.co - S^-j-lL. ILV-• ^
Shipper's Manifest or Bill of Lading number: h J z-r - 3 ~?
Was the State of Utah given notice to the receipt/disposal activities associated with this load?
No
Who gave and when was the notification given?
cW; iohjiiC
or
Description of byproduct material disposal area/activities:
Has each drum been inspected to identify the presence of any void spaces?
Have all drums with void spaces been filled with tailings sands or soil? [OV
Which tailings cell was the material placed in? 6cU 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?
•y*< :
Was the material segregated from byproduct material from other ISL sources disposed of in the cell?
L
No.: PBL-10
Rev. No.: R-3.3
Date: November 13,
2014
Manifest or BOL #:
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 12 of 13
Have the thickness and placement measurements been verified and documented for the disposal area
by the engineer, specifically:
Was the material placed in a cell approved by the executive Secretary
for ISL waste disposal? Y*s
Documentation of approval L'i-t^'tf-ut /iee*/7<? /Wi 7
Was the ISL material segregated from disposed Mill material and other
ISL material? Ye£
Refer to plat(s) used to confirm. j z cO,yig><u f dr**?
Was the maximum lift thickness above tailings less than 4 feet thick?
Was the maximum lift thickness of subsequent lifts less than 2 feet
thick?
Has 4 foot of tailings sands been maintained under each disposal
area? Y*S
Refer to drawings used to confirm c'e// 3 don^.
Is the bottom of each disposal area at least 12 feet from the sides or
dikes of the tailings cell? Ye<,
Refer to drawings used to confirm. (_,,n 3 tfraus. ijs
Will the elevation of the material exceed the plane or grade of the
elevation of the uppermost flexible membrane liner of the cell?
..Ac
How was this confirmed (e.g., survey or review)
Engineer's or !
Environmental
Coordinator's
Initials
3_
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?
t,tV,__
Were void spaces filled with tailings?
_ . Ytx
Was the shipment properly covered?
... - _
No.: PBL-10
Rev. No.: R-3.3
Date: November 13,
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 13 of 13
Manifest or BOL #: uflT ^ 3=
Are additional settlement monitors required to be placed for this generator?
A^A
If required, where were settlement markers were placed?
,/V/Ar
Radiological receipt survey measurements:
Breathing Zone:
1. Was a Breathing Zone Sample collected? Yes orc^LcP
2. If yes, what were the results of the sampling?
Was a photograph taken during the unloading activities?(T§s>or No
STRAIGHT BILL OF LADING
ORIGINAL-NOT NEGOTIABLE
Greenfield Logistics
Shipper No.tl/lS-1/
Carrier No.
Date 1\/S(<S
(Name of Carrier) (SCAC)
on Collect on Delivery shipments, the letters COO mult appear before consignee's name or as otherwise
provided in Item 430. Sec 1
To: Energy Fuels_
Street 6425 South Hvw 191
City Blamding < State UT Zip Code 84513_
From: Shipper CAMECO RESOURCES. INC.
Street: 762 Ross Rd
City Douglas . State Wy Zip Code 82633
24 hr. Emergency Contact Tel. No: 905-885-8745
Route : Vehicle: ? Number J
No of units &
container type
HM Basic Description
Proper Shipping Name, Hazard Class,
Identification Number (UN or NA), Packing Group, per 172.101,172.202,172.203
Total Quantity
(Weight, Volume,
Gallons, etc.)
Weight
(Subject to
Correction)
RATE Charges
(For Carrier
Use Only)
1 Roll off XX RQUN2912, RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY
(LSA-1), CLASS 7
RADIONUCLIDE: RESIDUAL NATURAL URANIUM & ASSOCIATED
DAUGHTER PRODUCTS
15.3m'
PHYSICAL FORM: SOLID
CHEMICAL FORM: NATURAL URANIUM OXIDE UO4-2H,0
TOTAL ACTIVITY: 2.22E10 Bq (0.6CI)
TRANSPORT INDEX: N/A AS PER 49CFR172.203(d)(5)
PLACARDS: RADIOACTIVE 7
EXCLUSIVE USE SHIPMENT: THIS VEHICLE IS ASSIGNED FOR
EXCLUSIVE USE OF CAMECO RESOURCES, INC. UNDER
PROVISIONS OF 49 CFR 173.427 INCLUDING EXEMPTING FROM
MARKING AND LABELING REQUIREMENTS
DO NOT LOAD OTHER FREIGHT IN THIS VEHICLE, TRANSFER EN
ROUTE
PLACARDS TENDERED: NOD REMIT C.O.D. TO:
ADDRESS
Notft-P) Where the rate h dependant on value, snippers are required to state specifically on
wtKlrtg lh« agreed or declared value of the property, as Wow* The agreed or declared
value of the properly 4 hereby tpecaieaVy stated by Ihe shipper to be nol
aaeaedmg per .
(2) Where (he appHcabie lartfT provision* specify a imnation ot the canter's Ubtttty absent a
release or a value dedintiwi by the shipper and the shipper does not release the carrier*!
UapMy or declare a value, the carrier's aablMy shin be Rmned to Ihe extent provided by such
provisions. Sea NMFL lem 172.
\l) CommodRlw requtrtng special or addtttontl care <w attention to handling or stowing must
be *o marked and packaged as to ensure safe transportation See Section 2(e) of Hem 380,
Mrt of Lading. Freight QMs, and Statements of Charges and Section i{a) of the Contract
terms and conditions lor a list of such articles
I hereby declare that the contents of this
cgnsignmerx are fuly and accurately described
above by Ihe proper shipping name and are
classified, packaged, marked, end
lebeied/Zplscerd, and are In el respects in
proper condition lor transport according lo appecable International and national
governmental regulations.
«a#r»r* lai tn iwaignu *timd muni
HWtrvfnwrttitoei m tit CWfcyiaf. H
MaMea. HIPPER
(7 SJgiwurC tVda«M0Wr~
COO FEE
PREPAID
COU6CT i
TOTAL
CHARGES
FREIGHT CHARGES
FR.EJQHT MlfpAtD CtW M> H dwifM
tmotwiMneae: *rt »• o»
RECEIV60, subject to the dasssficalkms and tariff! in effect on the date of issue of the* BHi ol Lading, the property described above in apparent good order, except at noted (oonients end condition of contents of package* unknown), marked consigned
and destined as Indicated above which said carrier (the word carrier being understood (ftm«]f»tri this eortlraot as meaning any person or oorporailon In possession of Ihts property under the contract) agrees lo carry to its usual place of delivery at said
destination, if on *s route, otherwise to deliver to another carrier on the route to said destination H Is mutually agreed as to each earner of al or any of, said property over at or any portion of said route to destination and as to each party at any time
Interested in eN or any said property, thai every service to be performed hereunder shall be subject to al Ihe oil of lading terms and conditions in t* governing classification on the date of (ho shipment
Shipper hereby cercMet that he is femSar wttrt ail (he lading terms and condrllons In the governing classification and the said farms and conditions are hereby agreed to by the shipper end accepted for himself and hb assigns
SHIPPER: CAMECO RESOURCES, INC CARRIER:
PER.
DATE^
PER LL DATE 'da A
Rev 3-Apr 02, 2015
Page 1 of I
J-.U) Radiation Protection Program\WYO-RPP-01 (Volume IV-Health Physics)\WYO -RPP-01 (Forms)\WYO-RPP-01.070 Bill of Lading-By-Product-
LSA.doc
Smith Ranch
Controled Elevation used (Cell 3) 5612.27
Area Elevation Transit Shot
Initial shot for trench
Top of trench 5606.96
Bottom of trench 5599.26
Initial shot used for material
TOP of material in trench 5606.32
5.65
10.96
18.66
5.65
11.6
Top of cell 3 Liner 5608.5
Feet below liner 2.18
; No.: PBL-10
! Rev, No.: R-3.3
Date: November 13,
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: lle.(2) Byproduct Disposal
Page 11 of 13
ATTACHMENT 2
lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date: )i/,„/?„,<-
Name of employee receiving the load: ""[V"1^ ~TZryL_
Generator of the Byproduct Material: Ce-i^tt e - Sd^i f^/-
Shipper's Manifest or Bill of Lading number: ///<r- ?^
Was the State of Utah given notice to the receipt/disposal activities associated with this load?( Yes or
No
Who gave and when was the notification given?
Description of byproduct material disposal area/activities:
Has each drum been inspected to identify the presence of any void spaces? N^V
Have all drums with void spaces been filled with tailings sands or soil?
Which tailings cell was the material placed in? Lcii 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?
YVj
Was the material segregated from byproduct material from other ISL sources disposed of in the cell?
Yes _. . _
No.: PBL-10
Rev. No.: R-3.3
Date: November 13,
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: I le.(2) Byproduct Disposal
Page 12 of 13
Manifest or BOL #: Mt-r 3ff
Have the thickness and placement measurements been verified and documented for the disposal area
by the engineer, specifically:
Was the material placed in a cell approved by the executive Secretary
for ISL waste disposal? Yd
Documentation of approval _L
Was the ISL material segregated from disposed Mill material and other
ISL material? Yti
Refer to plat(s) used to confirm. f_*/> ,? //c z £?<£/>evii
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 foot of tailings sands been maintained under each disposal Has
area?
Refer to drawings used to confirm t'< il 3 c'c-i<f /7/t,^,vy,
Is the bottom of each disposal area at least 12 feet from the sides or
dikes of the tailings cell? fej
Refer to drawings used to confirm. ^V// 3 Ct-^. £3n>~;
I Will the elevation of the material exceed the plane or grade of the
elevation of the uppermost flexible membrane liner of the cell?
How was this was
s
confirmed (e.g., survey or review)
Engineer's or
Environmental
Coordinator's
Initials
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?
Were void spaces filled with tailings?
.._ ......
Was the shipment properly covered?
... >«-.5r it-t. Akut'
No.: PBL-10
Rev. No.: R-3.3
Date: November 13,
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Manifest or BOL #: _u/<r- 3 $
Are additional settlement monitors required to be placed for this generator?
Mh
Page 13 of 13
If required, where were settlement markers were placed?
MA
Radiological receipt survey measurements:
?.o ^^.(L^ px/7 - a £>
Breathing Zone:
1. Was a Breathing Zone Sample collected? Yes or(Ng
2. If yes, what were the results of the sampling?
Was a photograph taken during the unloading activities? (tfe^br No
STRAIGHT BILL OF LADING
ORIGINAL-NOT NEGOTIABLE
Greenfield Logistics
Shipper No. h 9
Carrier No.
Date, i \<i /, r
(Name of Camer) (SCAC)
on Collect on Delivery shqxnenu. Ihe letters COO must appear before consignee's name or as otherwise
provided in Item 430, Sec 1.
To: Energy Fuels
Street 6425 South HWY 191
Citv Standing State UT Zip Code 84511
From: Shipper CAMECO RESOURCES. INC.
Street: 762 Ross Rd
Citv Douglas . State WY Zip Code 82633
24 hr. Emergency Contact Tel. No: 905-886-8745
Route: Vehicle:
Number
No of
units &
container
type
HM Basic Description
Proper Shipping Name, Hazard Class,
Identification Number (UN or NA), Packing Group, per 172.101,172.202,172.203
Total
Quantity
(Weight, volume,
Gallons, etc.)
24./yoJ
18.9m*
Weight
(Subject to Correction)
RATE Charges
(For Carner
Use Only)
1 Roll
off
XX RQUN2913, RADIOACTIVE MATERIAL, SURFACE CONTAMINATED OBJECT
(SCO-1), CLASS 7
RADIONUCLIDE: RESIDUAL NATURAL URANIUM & ASSOCIATED DAUGHTER
PRODUCTS
PHYSICAL FORM: SOLID
CHEMICAL FORM: NATURAL URANIUM OXIDE UO.-2H,0
TOTAL ACTIVITY: 2.74E10Bq (0.741Ci)
TRANSPORT INDEX: N/A AS PER 49CFR172.203(d)(5)
PLACARDS: RADIOACTIVE 7
EXCLUSIVE USE SHIPMENT: THIS VEHICLE IS ASSIGNED FOR EXCLUSIVE
USE OF CAMECO RESOURCES, INC. UNDER PROVISIONS OF 49 CFR 173.427
INCLUDING EXEMPTING FROM MARKING AND LABELING REQUIREMENTS
DO NOT LOAD OTHER FREIGHT IN THIS VEHICLE, TRANSFER EN ROUTE
PLACARDS TENDERED: YES : X NO • REMIT COD TO:
ADDRESS
Note-O) Where the rste is dependent on vtlue, shippers ere required to slete tpecrflcatty on
writing the agreed or deefsred vetaa of Ihe property, as fosdv/e The agreed or declared
value of the property is hereby specWcely staled by the shipper fa be not
exceeding . per
(2) Where fhe eppecable tariff provisions specify a arretaiian of Ihe carrier's MbKny atvent a release or i value defloration by the shipper and the shipper does not release the carrier's
liability or dtciere a value, the earner's HablMy shall be HmMed lo the extant provided by aucfi
provisions. See NMFl Hem 172.
(3) Cornmodsies requiring special or additional care or attention In handling or stowing must
be so marked and packaged as to ensure safe transportation See Section 2(e) of Hem 300,
SBis of Lading, Freight Bins, and Statements of Cherges and Section t (a) ol the Contract
(arms and conditions for a Hst of such articles
I hereby declare that the contents of this
consignment are fuly and accurately described
above by the proper shipping name and are
cJaasHled, packaged, marked, and
tebeledZ/placard. and a*e m el respects m
proper condibdn for transport according to
applicable irtematonsi and national
governmental regulations.
ON BJEIULF OF SHIPPER,-
COO FEE
PREPAID
COLLECT $
TOTAL
CHARGES
FREIGHT CHARGES
RECEIVED, subject to the classifications and tariffs in orrect on lha dais ol issus or this BH ol Lading, the property described above in apparent good order, except ss noted (contents and condition ol contents or Dockages unknown), merked. consigned, and
destined a* indicated above wtwh said earner (Uia word earner being understood throughout litis contract as meaning any person or corporation in possession at lies properly under lha contract) agrees lo cany to its usual place ol delivery at said destination.
H on Its roule. otherwne to deliver lo another earner on lha route lo said destination. It Is mutually agreed aa to each carrier ol a" or any of, saw property over aK or any portion of said route 10 destination and as to each party at any tons Interested In all or any
seid property, (net every service to be performed hereunder shall be sucrect to all the on of iedlng terms and conditions In Ihe governing classification on the dais of the shipmanl
Shipper hereby certifies lhat ha is tamWar with as the lading terms and conditions in ins governing classlficauoft and the said leims and conditions ere hereby earned to by the shipper and accepted for himself and nil assigns
SHIPPER: CAMECO RESOURCES, INC. CARRIER: U
PER PER
L2 DATE ML DATE
Rev 3-Apr 02,2015 ^te''^ ^ ^ll/^f w\v\*f
Page 1 of I D^JT^1^-
J:\4) Radiation Protection Program\WYO-RPP-0l (Volume IV-Health Physics)\WYO -RPP-01 (Forms)\WYO -RPP-01.071 Bill of Lading-By-Product-
SCO.doc
Smith Ranch
Cbntroled Elevation used (Cell 3)
Area
5612.27
Elevation Transit Shot
Initial shot for trench
Top of trench 5606.96
Bottom of trench 5599.26
Initial shot used for material
TOP of material in trench 5606.32
5.65
10.96
18.66
5.65
11.6
II |l5-3fT
Top of cell 3 Liner 5608.5
Feet below liner 2.18
[No.: PBL-10
| Rev. No.: R-3.3
; Date: November 13,
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 11 c.(2) Byproduct Disposal
Page 11 of 13
ATTACHMENT 2
Ue.m BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date: 'i/ii/.r
Name of employee receiving the load: T^m^ SLcU
Generator of the Byproduct Material: ^iwco -St^,-l-L. L^~^
Shipper's Manifest or Bill of Lading number: ^tl( tT-ll
Was the State of Utah given notice to the receipt/disposal activities associated with this load? <^es)or
No
Who gave and when was the notification given?
Description of byproduct material disposal area/activities:
<-W pl^ ^-JL f U-f-g;
Has each drum been inspected to identify the presence of any void spaces? HSk
Have all drums with void spaces been filled with tailings sands or soil? HtK
Which tailings cell was the material placed in? C-cil. 2 — —— —
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?
it*.
Was the material segregated from byproduct material from other ISL sources disposed of in the cell?
. . .
No.: PBL-10
Rev. No.: R-3.3
Date: November 13,
2014
Manifest or BOL #:
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 12 of 13
Have the thickness and placement measurements been verified and documented for the disposal area
by the engineer, specifically:
Was the material placed in a cell approved by the executive Secretary
for ISL waste disposal? _J^r
Documentation of approval Arte-sc fturtgoomq 4** ~f
Was the ISL material segregated from disposed Mill material and other
ISL material? fc<
Refer to plat(s) used to confirm. 3 i/e -z Dt-fptxin/ Ann
Was the maximum lift thickness above tailings less than 4 feet thick?
Was the maximum lift thickness of subsequent lifts less than 2 feet
thick?
Has 4 foot of tailings sands been maintained under each disposal
area? Yes
Refer to drawings used to confirm Ccf/ ^ 3 Cef^tt. frays >r-gj
Is the,bottom of each disposal area at least 12 feet from tfTe sides or
dikes of the tailings cell? fej
Refer to drawings used to confirm, Ce/> 3 fcnjA tOra^ih
Will the elevation of the material exceed the plane or grade of the
elevation of the uppermost flexible membrane liner of the cell?
AA>_
this
Engineer's or
Environmental
Coordinator's
Initials
How was confirmed (e.g., survey or review)
How was the area compacted? Was each lift compacted by heavy equipment (such as a Cat D-6) at
least 4 times prior to placement of subsequent lifts?
I a.Mr-
Were void spaces filled with tailings?
Was the shipment properly covered?
Jo^Jcc ishc^a.
\ No.: PBL-10
! Rev No.: R-3.3
j Date: November 13,
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES Page 13 of 13
Title: I le.(2) B>product Disposal
1 2014
Manifest or BOL #: n(iy
Are additional settlement monitors required to be placed for this generator?
If required, where were settlement markers were placed?
Radiological receipt survey measurements:
l<o *~;<*~ll,- ?Xp- y.g-
Breathing Zone:
1. Was a Breathing Zone Sample collected? Yes yf$<5~~\
2. If yes, what were the results of the sampling? ~
AJAL
A/A
Was a photograph taken during the unloading activities?(Tesjor No
STRAIGHT BILL OF LADING
ORIGINAL-NOT NEGOTIABLE
Greenfield Logistics
Shipper No.
Carrier No.
Date U /'>/*r
(Name of Carrier) (SCAC)
on Collect on Oativery shipments, the letters COO mu»t appaar betora contignaa'a nama or at otherwise
provided In Itam 430, Sac 1
To: Energy Fuels_
Street 6425 South HWY 191
City Blandino. State I Zip Code 94511
From: Shipper CAMECO RESOURCES. INC.
Street: 762 Ross Rd
City Douolas . State WY Zip Code 82633
24 hr. Emergency Contact Tel. No: 905-885-8745
Route: Vehicle:
Number
No. of
units &
container
type
HM Basic Description
Proper Shipping Name, Hazard Class, Identification Number (UN or NA), Packing Group, per 172 101,172.202,172.203
Total
Quantity
(Weight, volume,
Gallons, etc.)
Weight
(Subject to Correction)
RATE Charges
(For Carrier
Use Only)
1 Roll
off
XX RQUN2913, RADIOACTIVE MATERIAL, SURFACE CONTAMINATED OBJECT
(SCO-1), CLASS 7
18.9m1
RADIONUCLIDE: RESIDUAL NATURAL URANIUM & ASSOCIATED DAUGHTER
PRODUCTS
PHYSICAL FORM: SOLID
CHEMICAL FORM: NATURAL URANIUM OXIDE UO4-2H20
TOTAL ACTIVITY: 2.74E10Bq (0.741 CI)
TRANSPORT INDEX: N/A AS PER 49CFR172.203(d)(5)
PLACARDS: RADIOACTIVE 7
EXCLUSIVE USE SHIPMENT: THIS VEHICLE IS ASSIGNED FOR EXCLUSIVE
USE OF CAMECO RESOURCES, INC. UNDER PROVISIONS OF 49 CFR 173.427
INCLUDING EXEMPTING FROM MARKING AND LABELING REQUIREMENTS
DO NOT LOAD OTHER FREIGHT IN THIS VEHICLE, TRANSFER EN ROUTE
PLACARDS TENDERED: YES : X NO Li REMIT C.O.D. TO AODRESS
Nole-O) Where the rale is dependent en value, shippers are required to stele specfflcasy on
writing the agreed or declared value of the propertir. as follows The agreed or declared
vakie ol lira property is hereby ipeeMcaay elated by lha shipper lo be nol
exceeding . asr
(2) Wham ihe applicable tariff provisions specify a hmitsllon of Ihe carrier's Habinty absent e
release or a value declaration by lha aitipper end the snipper doss not rsleaes Ihe canter's
lisbSKy or declare e vetua. lha carrier's llabJaty shall be limited lo Ihe orient provided by such
provisions Set HMFL Item I n
(31 Commodities requiring speclel or additional care or attention In handling or slowing must
be so merited and packaged as 10 ensure safe transportation see Section 2(a) of nam 3M ants of Lading. Freight SMs. and Statements ol Charges and Section 1(a) of tha Contract
terms and conditions for a llel of such erbdea
1 hereby declare that lha contents ol ties
consignment are fuSy and accurately described
above by lha proper shipping nama and are
deluded, packaged, marked, and
labaled/rctecaid. and are In ell respects In
proper condition tor transport according to
applicable international and notional
governmental regulations
eeMrto u »* eMUONM •thM noma m a* canatsw.
OF SHIP
rtmeue*h*rf ,1 eei
****** dWrgM
•NprMrthejfev isnMcensfaw
I eewvemi
(SenrfOTrfCmleMr)
C CD FEE
PREPAIO '
COLLECT I
TOTAL
CHARGES
FREIGHT CHARGES
FMIGHT PMPAiO Chart tat i «tws*a •uaelvnetbttM most itntdwcM ulii
RECEIVED, subject 10 the cleitstcations and tariffs in effect on the oeta or issue of trw B* ol Lading, lha property described above in apparent good order, except as noted (contents and condition of conleme of packages unknown), merited consigned, and
destined as Indicated above which said earner (the word carrier being understood thioughout this contract as meaning eny person or corporation in possession ol ties property under Ihe cornrea) egrets to carry to its usual place of delivery at said detonation,
if on Us route, aherwtso lodeinerio another camtr an lh« routs to said destinsllon It is mutuety agreed aalo each carrier ol an or any of. ssid property over al or any portion of said routs to destination and aslo each party al any lime Interested in alt or any said properly, thai every service lo bs performed hereunder shell bs subject to all lha bri of lading terms and conditions In Ihe governing ctasslficaUon on Iht date or the shipment
8htppor hereby certiSes that fit Is (ameer with al tha lading terms and conations in the governing classification and the said leima and Conations ere hereby agreed to by Ihe shipper and accepted for himself snd his essigns
SHIPPER: CAMECO RESOURCES, INC. CARRIER; A A
PER
z , y 7
PER
DATE ' . / y' DATE
Rev 3 - Apr 02, 20 iT^ R<Jt6AO^ E f Py. XLNVVA-J
Page I of 1 O
J:\4) Radiation Protection Program\WYO-RPP-01 (Volume lV-Health Physics)\WYO -RPP-01 (Forms)\WYO -RPP-01.071 Bill of Lading-By-Product-
SCO.doc fCu
t'nergy Fuels Resources (USA) Corp..
White Mesa Hi 11
6 4 85 S„ Highway 1.9:1
EUanding UT 84511
Transaction No.
51843
Vehicle ID::
Trailer IDs
Account IDs
Order IDs
Owner IDs
Material IDs
Destin. ID:
Date Time;
Ins 11/12/8015 07s54
Out:: 11/18/2015 08:17
T3
11(e)8 WYC) SMITH RANCH
11(e) £ Mat 11 (&) £ Mater :i.a 1 Rece i pt
ULANDING
Gross s
Tare?:
Net a
67380 lb
44060 lb
£3860 lb
Scale
1
1
CM)
Comments: (3FI..U R/0 »1:1.60
Operator:: 4
Si gnatures
Charr.|e by Weight
51843
T3
I I (e) P. WYO
II (e)£ Mat
11/18/8015 07s54
11/1E/8015 08:17
Net Chq: 0
67380 lb
44060 lb
83860 lb
Tot Chgn
(M)
pro
Smith Ranch
Controled Elevation used (Cell 3) 5612.27
Area Elevation Transit Shot
Initial shot for trench
Top of trench 5606.96
Bottom of trench 5599.26
Initial shot used for material
Top of material in trench 5606.32
5.65
10.96
18.66
5.65
11.6
Top of cell 3 Liner 5608.5
Feet below liner 2.18