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HomeMy WebLinkAboutDRC-2021-017021 - 0901a06880f89c0dState of Utah SPENCER J. COX Governor DEIDRE HENDERSON lieutenant Governor Department of Environmental Quality Kimberly D. Shelley Executive Director DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Douglas J. Hansen Director MEMORANDUM TO: Project File C-2021-32 THROUGH: Phil Goble, Uranium Mill Section Manager Phil Goble FROM: DATE: Heather Mickelson, PE, PG If~~)!., October 27, 2021 October 27, 2021 10/27/2021 SUBJECT: October 14, 2021 Inspection of The Disposal of 11 e.(2) Decommissioning Debris from In Situ Leach Facilities at the White Mesa Uranium Mill. Radioactive Material License No. UT 1900479, Amendment 10. Authority Radioactive Materials License #UT] 900479 Amendment I 0, Condition I 0.5: "In accordance with the licensee's submittal to the NRC dated May 20, 1993, the licensee is hereby authorized to dispose of l le.(2) byproduct material generated at licensed in-situ recovery (ISR) [previously known as in-situ leach (ISL)] facilities as per 10 CFR 40 Appendix A, Criterion 2 and from other uranium recovery facilities, subject to the following conditions:" (Conditions are included below in the Requirements and Compliance Determination section.) R313-12-3 (quoting JO CFR 40.4): "Byproduct Material means the tailings or wastes produced by the extraction or concentration of uranium or thorium from any ore processed primarily for its source material content, including discrete surface wastes resulting from uranium solution extraction processes." 1 IO 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 1 This definition amends the language given in Section 11 e.(2) of the Atomic Energy Act as amended in 1954 to include ISL facilities on the same footing as conventional uranium mills. This is done by referencing "solution extraction" in the definition. Text of the Atomic Energy Act as amended in 1954 can be found in NUREG-0980, Volume I, No. 10. DRC-20 195 \forth 1950 West• Salt Lake City, UT Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880 Telephone (801) 536-0200 • Fax (801) 536-0222 • T.D.D. (801) 536-4284 www.deq.utah.gov Printed on I 00% recycled paper Fourth Quarter 2021 ISL Decommissioning Debris Disposal Inspection Report October 27, 2021 Page 2 costs and environmental impacts of transporting the wastes to a large disposal site, such offsite disposal is demonstrated to be impracticable or the advantages of onsite burial clearly outweigh the benefits of reducing the perpetual surveillance obligations." Observations Heather Mickelson, PE, PG of the Utah Division of Waste Management and Radiation Control (Division), with Phil Goble, Uranium Mill Section Manager, observed the disposal of two (2) loads of l le.(2) byproduct material on October 14, 2021 at the White Mesa Uranium Mill. The mill is owned and operated by Energy Fuels Resources (Licensee). Notification of the disposal was received by the Division on October 6, 2021. Operating Procedures and Records The Standard Operating Procedure (SOP) PBL-10 dated February 1, 2018, which governs the disposal of 11 e.(2) byproduct material from ISL facilities, has not been updated with the requirements from the July 27, 2021 amended Radioactive Materials License. This amendment removed the requirement to segregate sources of l 1 e.(2) byproduct material during disposal. It was confirmed by the Licensee that an updated SOP will be submitted in December 2021, as required. Therefore, this inspection was specific to the Licensee's implementation of SOP PBL-10 without the criteria to segregate sources of l le.(2) byproduct material. The Licensee maintains hard copies of the buried 1 le.(2) material records onsite. Records are moved from the White Mesa Mill's office building to an onsite storage container within the restricted area when file space inside the office building becomes limited. These storage locations were verified and observed during this inspection. Copies of the data packets for each load disposed during this inspection are attached to this report. 11 e.(2) Byproduct Material Disposal Activities and Description Prior to October 14, 2021, the disposal pit locations were determined, located by survey, and excavated. The bottom of the excavations extended into the tailings sand. Although not required, two disposal pits were used during this burial, as additional capacity was required. The 1 le.(2) byproduct material was placed near the burial pits and processed for burial (Photos 1 and 2). Pipe was chipped or cut in half lengthwise prior to disposal to minimize void space. During the October 14, 2021 inspection, the Division observed the final disposal activities. Prior to placement, the excavation depth was surveyed (Photos 3 and 4). Once the 1 le.(2) byproduct material was in the excavation, the top of the material was surveyed (Photo 5 and 6). Clean cover was then placed over the 11 e.(2) byproduct material and then compacted to further minimize void spaces (Photo 7). The vertical extent of the burial was below the top of the tailings and above the bottom liner. Two (2) loads of 11 e.(2) byproduct material was from Crow Butte Resources, Inc in Crawford, Nebraska and URI, Inc. from Duval County, Texas. The material from this load consisted of supersacks, electrical wire, soil, and fiberglass (Photos 1 and 2). Fourth Quarter 2021 ISL Decommissioning Debris Disposal Inspection Report October 27, 2021 Page 2 costs and environmental impacts of transporting the wastes to a large disposal site, such offsite disposal is demonstrated to be impracticable or the advantages of onsite burial clearly outweigh the benefits of reducing the perpetual surveillance obligations." Observations Heather Mickelson, PE, PG of the Utah Division of Waste Management and Radiation Control (Division), with Phil Goble, Uranium Mill Section Manager, observed the disposal of two (2) loads of 1le.(2) byproduct material on October 14, 2021 at the White Mesa Uranium Mill. The mill is owned and operated by Energy Fuels Resources (Licensee). Notification of the disposal was received by the Division on October 6, 2021. Operating Procedures and Records The Standard Operating Procedure (SOP) PBL-10 dated February 1, 2018, which governs the disposal of 11e.(2) byproduct material from ISL facilities, has not been updated with the requirements from the July 27, 2021 amended Radioactive Materials License. This amendment removed the requirement to segregate sources of lle.(2) byproduct material during disposal. It was confirmed by the Licensee that an updated SOP will be submitted in December 2021, as required. Therefore, this inspection was specific to the Licensee's implementation of SOP PBL-10 without the criteria to segregate sources of 1le.(2) byproduct material. The Licensee maintains hard copies of the buried 1le.(2) material records onsite. Records are moved from the White Mesa Mill's office building to an onsite storage container within the restricted area when file space inside the office building becomes limited. These storage locations were verified and observed during this inspection. Copies of the data packets for each load disposed during this inspection are attached to this report. 11e.(2) Byproduct Material Disposal Activities and Description Prior to October 14, 2021, the disposal pit locations were determined, located by survey, and excavated. The bottom of the excavations extended into the tailings sand. Although not required, two disposal pits were used during this burial, as additional capacity was required. The 11e.(2) byproduct material was placed near the burial pits and processed for burial (Photos 1 and 2). Pipe was chipped or cut in half lengthwise prior to disposal to minimize void space. During the October 14, 2021 inspection, the Division observed the final disposal activities. Prior to placement, the excavation depth was surveyed (Photos 3 and 4). Once the 11e.(2) byproduct material was in the excavation, the top of the material was surveyed (Photo 5 and 6). Clean cover was then placed over the lle.(2) byproduct material and then compacted to further minimize void spaces (Photo 7). The vertical extent of the burial was below the top of the tailings and above the bottom liner. Two (2) loads of 1le.(2) byproduct material was from Crow Butte Resources, Inc in Crawford, Nebraska and URI, Inc. from Duval County, Texas. The material from this load consisted of supersacks, electrical wire, soil, and fiberglass (Photos 1 and 2). Fourth Quarter 2021 ISL Decommissioning Debris Disposal Inspection Report October 27, 2021 Page 3 Close Out Meeting A close out meeting to discuss observations during the inspection included Heather Mickelson, Phil Goble, Terry Slade, Garrin Palmer (Radiation Safety Officer), and Tanner Holiday. Requirements and Compliance Determination Radioactive Materials License #UT1900479, Condition 10.5B: "All ISR contaminated equipment shall be dismantled, crushed, or sectioned to minimize void spaces. Barrels containing waste other than soil or sludges shall be emptied into the disposal area and the barrels crushed. Barrels containing soil or sludges shall be verified by the Licensee to be full prior to disposal. Barrels not completely full shall be filled with tailings or soil prior to disposal. " The activities observed and information gathered during this inspection supports a conclusion that the Licensee is complying with this license condition. Pipe was chipped or cut lengthwise prior to placement in the Cell 3. Cut pipe was made of fiberglass that easily crushed when compacted. Radioactive Materials License #UT1900479, Condition 10.5C: "All ISR byproduct material shall be buried in Impoundment No. 3 unless prior written approval is obtained from the Director for alternate burial locations." The activities observed and information gathered during this inspection supports a conclusion that the Licensee is complying with this license condition. All 11e.(2) byproduct material was buried in Tailings Cell No. 3. Radioactive Materials License #UT1900479, Condition 10.5D: "All disposal activities shall be documented and records thereof maintained on-site. The documentation shall include all items required by this License." The activities observed and information gathered during this inspection supports a conclusion that the Licensee is complying with this license condition. The Licensee maintains records of the 11 e.(2) byproduct material disposed of onsite. These records document the nature of each load of material received, where it is buried, and how it was handled, including all measures taken to comply with all of License Condition 10.5. Radioactive Materials License #UT1900479, Condition 10.5E: "Disposal Requirements for lle.(2) byproduct material: the licensee shall perform byproduct material disposal activities in accordance with the current Standard Operating Procedure (SOP) for 11e.(2) byproduct material disposal. Said plan includes the following minimum provisions: (1) The material disposal area must be located on a tailings beach area of the conventional impoundment or on an area of the impoundment 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 conventional impoundment; (3) (Reserved) (4) Absence of void space inside barrels disposed, including physical verification before disposal; and (5) Detailed engineering drawings which demonstrate: a. There are at least 4 feet of tailings sands under the bottom of each disposal area; and Fourth Quarter 2021 ISL Decommissioning Debris Disposal Inspection Report October 27, 2021 Page 4 b. The bottom of each disposal area is located at least 12 feet from the sides or dikes of the impoundment." The activities observed and information gathered during this inspection supports the conclusion that the Licensee is complying with this license condition. The Licensee met the requirement to submit the procedure with the initial version of SOP PBL-10, and now uses Revision R-3.4, dated February 1, 2018. Revision R-3.4 addresses all of the items specified in License Condition 10.5. The original version and every subsequent revision of this procedure were submitted to the Division for review and approval prior to implementation. Further, the Licensee is complying with the SOP, such as, minimizing void space, and placing the waste in the tailing sands with at least four feet of sands below it and at least 12 feet from the side or dike of the cell. Radioactive Materials License #UT1900479, Condition 10.5F: "The Licensee shall notify the Director in writing at least 7 calendar days prior to the proposed scheduled date for disposal of any 11e.(2) byproduct material in the conventional impoundments. An annual summary of the amounts of 11e.(2) byproduct material disposed of from off-site generators shall be included in the Annual Technical Evaluation Report required in License Condition 12.2." The activities observed and information gathered during this inspection supports the conclusion that the Licensee is complying with this license condition. The Division received notice of the disposal on October 6, 2021, which complies with the 7 days advance notice requirement. The annual summary submittal will be evaluated by DWMRC separately from this inspection. Conclusions and Recommendations The Licensee appears fully compliant with applicable laws, standards, requirements and License Conditions with respect to disposal of 1le.(2) byproduct material generated as decommissioning debris from ISL uranium recovery facilities. A new SOP PBL-10 is expected in December 2021, which will align the SOP with the RML. Segregating source lle.(2) byproduct material is not required with Amendment 10. Attachments: 11e.(2) Byproduct Receipt Notification dated October 4, 2021 Document packet for URI Rosita 11e.(2) byproduct material bearing Bill of Lading # 21ROS-030 Document packet for Crow Butte 11e.(2) byproduct material bearing Bill of Lading # W-03-21 CBR2 Photo 1. 11e.(2) byproduct inaterial to be buried. Photo taken on October 14, 2021. Photo 3. EFR measuring the bottom elevation of thc lle.(2) byproduct material. Photo taken on October 14, 2021. Photo 2. lle.(2) byproduct material to be buried. Photo taken on October 14, 2021. Photo 4. EFR measuring the bottom elevation of the lle.(2) byproduct material. Photo taken on October 14, 2021. Photo 5. EFR measuring the top elevation of the 1le.(2) byproduct material. Photo taken on October 14, 2021. Photo 7. Compacting the final cover over the buried I le.(2) byproduct material. Photo taken on October 14, 2021. Photo 6. EFR measuring the top elevation of the 1 I e.(2) byproduct material. Photo taken on October 14, 2021. eft EIVERGY FUELS Energy Fuels Resources (USA) Inc. 6425 South Highway 191, PO Box 809 Blanding, UT. US, 84511 435 678 2221, fax 435 678 2224 www.energyfuels.com October 4, 2021 VIA Electronic Mail (PDF) and UPS Mr. Doug Hansen State of Utah Department of Environmental Quality 195 North 1950 West PO Box 144880 Salt Lake City, UT 84114-4880 Dear Mr. Hansen 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 one load by October 14th, 2021. 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 Rev. No.: R-3.5 Date: August 4, 2021 ENERGY FUELS RESOURCES (USA) INC. STANDARD OPERATING PROCEDURES Title: 1 le.(2) Byproduct Disposal Page 10 of 12 ATTACHMENT 2 11,42) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM Date: IV /...2.pa 7 Name of employee receiving the load: -`64inc1 . 4011,161, Generator of the Byproduct Material: U RI R S:4a Shipper's Manifest or Bill of Lading number: 2.i KOS - 03 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? (ro.er;1 Wrier Ilf+ober 7 , 20.21 Description of lzproduct material disposal area/activities: 0;rt artti. er+,s.S k c.c. it 7 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? 'goy% Which tailings cell was the material placed in? C. c 1 1 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? ti 04 et ;Al OA pl ; 4re1011 en C.41..1 431.4. 1-0 1701: No.: PBL-10 Rev. No.: R-3.5 Date: August 4, 2021 ENERGY FUELS RESOURCES (USA) INC. STANDARD OPERATING PROCEDURES Title: 1 le.(2) Byproduct Disposal Page l 1 of 12 Manifest or BOL #: R.6SOIO 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 Director for ISL waste disposal? lifs le Documentation of approval ide4Ari... #i orProorrt Was the maximum lift thickness above tailings less than 4 feet thick? fej 0 Was the maximum lift thickness of subsequent lifts less than 2 feet thick? 11..s Ar Has 4 foot of tailings sands been maintained under each disposal area? .6.5 g Is the bottom of each disposal area at least 12 feet from the sides or dikes of the tailings cell? life., ...V Will the elevation of the material exceed the plane or grade of the elevation of the uppermost flexible membrane liner of the cell? 44 .41ie How was this confirmed (e.g., survey or review) Sute..". 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? .Arrt, c..t ?2a; l+(A. ,. pies f-ce- aj 4--;AAA4. fr-r t;-44. Were void spaces filled with tailings? Was the shipment properly covered? YL 1-4„ No.: PBL-10 Rev. No.: R-3.5 Date: August 4, 2021 ENERGY FUELS RESOURCES (USA) INC. STANDARD OPERATING PROCEDURES Title: 1le.(2) Byproduct Disposal Page 12 of 12 Manifest or BOL #: z R.OS Are additional settlement monitors required to be placed? IVA If required, where were the settlement markers placed? "org% Radiological receipt survey measurements: D,2 frfr/Mr P4 0 Breathing Zone: 1. Was a Breathing Zone Sample collected? Yes o 2. If yes, what were the results of the sampling? Was a photograph taken during the unloading activities? r No URI, INC. STRAIGHT BILL OF LADING FOR BYPRODUCT MATERIAL Shipment No. 21ROS-030 Trailer # Date: 10/11/2021 Seal # n/a NAME OF CARRIER: Cosby Trucking DR IVER:Pe0,17:5 SHIPPER (from) URI, Inc. STREET 3021 CR 333 CITY San Diego USA STATE Texas ZIP 78384 COUNTRY PHONE 361-595-5731 l STATE UT I ZIP 84511 PHONE 435-678-2221 as the app re 1 Carrier acknowle available and Carrier Sign to Cosig ee's Si nature COSIGNEE (to) Energy Fuels- White Mesa Mill DESTINATION STREET 6425 S. Hwy 191 an, Blanding COUNTRY U.S.A. SHIPPER's CERTIFICATION This is to certify that the above materials are properly classified, described, packaged, marked, placarded and labeled, and are in proper condition for transportation according to the applicable regulations of the Department of Transportation. THIS VEHICLE IS CONSIDERED A PACKA IN COMPLIANCE WITH 49 CFR 173.427 (c) Shipper's Signature Date 1 0/11/2021 Carrier Signature 3 Date Relinquished Date Received CARR1ER's CERTIFICATION ipt of packages and required placards. Carrier certifies emergency response information was made priate em res se document in the vehicle. Department of Transportation. Date Received Date Relinquished tg/ Date Received Da e Relinquis Carrier Sign CONSIGNEE's RECIEPT of SHIPMENT CONTENTS EXCLUSIVE USE SHIPMENT ***These contents are contaminated with natural uranium and its daughters 226Ra and 230Th ' IDENTIFICATION NUMBER: UN 2912 PROPER SHIPPING NAME: RADIOACTIVE MATERIAL. low specific activity (LSA-I). HAZARD CLASS: 7 FORM: Solid Oxide ACTIVITY: 0.0008 TBq SPECIAL INSTRUCTIONS: Do not remove contents without authorization WEIGHT: Tare lbs. NET lbs. GROSS /13-7,/õ lbs. VOLUME: 25 ycl3 EMERGENCY CONTACTS 24 HOUR CHEMTREC: 800-424-9300 password: URI URI DISTRICT: 361-228-2690 (Vikas Joshi) RM License No. R03653 Energy Fuels Resources (USA) Corp. White Mesa Mill Transaction No. 6425 S. Highway 191 57045 Blanding UT 84511 Date Time Scale In: 10/13/2021 07:24 1 Out: 10/13/2021 07:38 1 Vehicle ID: 815 COSBY TRUCKING Trailer ID: Account ID: URI-ROSITA URI-ROSITA Order ID: Owner ID: Material ID: 11(e)2 Mat 11(e)2 Material Receipt Destin. ID: BLANDING Gross: 46380 lb (M) Tare: 33340 lb Net: 13040 lb Comments: BOL21ROS-030 TRL5 Operator: 4 Charge by Weight Signature: BOL # Controled Elevation used (Cell 3) Area 21R0S-030 5607.675 Elevation Transit Shot Initial shot for trench 0.01 Top of trench 5603.285 4.4 Bottom of trench 5597.645 10.04 Initial shot used for material 0.01. Top of material in trench 5601.655 6.03 Top of cell 3 Liner 5608.5 Feet below liner 6.845 PBL-10 ENERGY FUELS RESOURCES (USA) INC. Rev. No.: R-3.5 STANDARD OPERATING PROCEDURES Date: Au ust 4, 2021 Title: 1 le.(2) Byproduct Disposal Page 10 of 12 ATTACHMENT 2 le. 2 BYPRODUCT MATERIAL DISPOSAL DOCUMENTAT ON FORM Date: 10 /1142021 Name of employee receiving the load: ,---(Nine(d Po )1, cla-t Generator of the Byproduct Material: C. r LL) Shipper's Manifest or Bill of Lading number: 0 - C 8 F. 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? (ir-,krr;n ?airier L.4:41/0er- H .2.0.3.. Description of byproduct material disposal area/activities: ir r ci 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? /urn Which tailings cell was the material placed in? Ce)/ 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? wo—c phhccd, Wit4 6!„.1 Ac., No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC. i. Rev. No.: R-3.5 STANDARD OPERATING PROCEDURES Page 11 of 12 Date: August 4, 2021 Title: lle.(2) Byproduct Disposal Manifest or BOL #: tA) - os-ai GRA 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 Director for ISL waste disposal? Yr., Documentation of approval .A..c...s. # 40 7 fog? Iff Was the maximum lift thickness above tailings less than 4 feet thick? 1/f f Re Was the maximum lift thickness of subsequent lifts less than 2 feet thick? lief e Has 4 foot of tailings sands been maintained under each disposal area? eel 0 Is the bottom of each Ssposal area at least 12 feet from the sides or dikes of the tailings cell? I t s 4r Will the elevation of the material exceed the plane or grade of the elevation of the uppermost flexible membrane liner of the cell? .4.4 How was this confirmed (e.g., survey or review) Sses41,. 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? Area, we-) 6,14.4-- 41.- 4- I rst-- (0 Were void spaces filled with tailings? Ycs Was the shipment properly covered? )4), sc.._ No.: PBL-10 Rev. No.: R-3.5 Date: August 4, 2021 ENERGY FUELS RESOURCES (USA) INC. STANDARD OPERATING PROCEDURES Title: 1 1842) Byproduct Disposal Page 12 of 12 Manifest or BOL #: ti)-n1-2.1 Cßi. Are additional settlement monitors required to be placed? If requited, where were the settlement markers placed? Aor.4 Radiological receipt survey measurements: 0.3 righ11C 0 Breathing Zone: 1. Was a Breathing Zone Sample collected? Yes oDs 2. If yes, what were the results of the sampling? Was a photograph taken during the unloading activities? STRAIGHT BILL OF LADING ORIGINAL--NOT NEGOTIABLE Page 1 of 1 Greenfield Logistics, LLC Date 10/7/2021 Name of Carrier iSCAC on Coftect on Delivery shipments, the letters COD must appear before consignee's natne or as otherwise provided in Item 430, Sec. 1. To: Consignee Energy Fuels Resources USA Inc From: Shipper Crow Butte Resources, inc. Street: 86 Crow Butte Rd. City Crawford State NE Zip Code 69339 Street 6425 S. Hwy 191 24 hr. Emergency Contact Te(. No:1308) 665-1393 City Blanding State UT Zip Code 84511 ERAP 1-905-885-8745 Route 1 f Vehicle: 1 Nmber 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 UN2912, RADIOACTIVE MATERIAL, Low Specific Activity (LSA-I), CLASS 7 30 cubic yards Natural Uranium, Thorium-230 and Radium-226 PHYSICAL FORM: Solid byproduct material CHEMICAL FORM: NATURAL URANIUM OXIDE U04-2H20 L.ABELS APPLIED: NIA per 49 CFR 172.203 (d)(4) TRANSPORT INDEX: N/A per 49 CFR 172.203(05) ACTIVITY OF SHIPMENT: _8.472007_13g EXCLUSIVE USE SHIPMENT THIS VEHICLE IS ASSIGNED FOR EXCLUSIVE USE OF CAMECO RESOURCES UNDER PROVISIONS OF 49 CFR 173.427 (a)(vi) INCLUDING EXEMPTION FROM MARKING AND LABELING REQUIREMENTS DO NOT LOAD OTHER FREIGHT IN THIS VEHICLE, TRANSFER EN ROUTE, OR BREAK SEAL CBR SHIPMENT #: W-03-21 CBR2 Note(n) Were the rate S dependant on value, shippers are required to state apeerfically or wthang the ag-eed or declared vane of the property, as follows- The agreed CT deciared value of the property is hereby spectficaay stated by the shipper to be not exceedin c Per . (2) Where the appiiinatle telt promisors specify a irritation of the carrier's lability absent a release or a value declaration by the shipper arra the shipper does not release the carrier's aridity or declare a value, tie carrier's Fat:laity shah be ranted to the extent provided try such provisions See FICAFL item 172 ;3) Corneedthes recruit-1g special or additional care Or attention in handfing or stowing must be so marked and packaged as to ensure safe transportation See Section 21e1 of Item 360, Has of Lading, Freight RCS, and Statements of Charges and Section t(a) of the Contract terms and conditons for a list of such articles i hereby deciare that the contents of this consignment are fully and accurately descrioect above by the proper shipping name and am classified, packaged, marked arid labeledhelacard and are in all respects in pi oder xnd ton for transport according to applicable international and nabonal governmental regulatons. ON BEHALF OF SHIPPER d i..\ cz,y,&•\,\3„, \....NV COO Ant $ C.0,0 FEE. PREPAID 0 COLLECT c $ nte entio sediment be Subject to Seettv 7 a mns dens n to devoted to tee emcee veticof recouree en consigner, es cottoned/. stet eine the ettmearre aciculate Me nit :erne end not treke delivey ettlet fetenern wiMag PS ....i A teat and et eine Ireful elven TOTAL ( er eentara* c HARGES. $ FREIGHT CHARGES FR E1GAT PREPAID Reck box ROWORs need! ween ton el , re tobe VA Is checked mud Signature RECEIVED, subject to the dessifiretions arid tariffs in React orr tne date of issue of this 901 of Lading, the property described above in apparent good order, except as noted (contents and condition of contena of pacritages unknown), marked, consgned, and destined as indicated above white said carder (the word carrier being understood throughout ths centract as meaning any person or corporation in possession of les property under the contract) agrees to carry to its usual place of dervery at sac riestnabon, it on its route, otherwise to deliver to another carrier on the rOute to said destnation It is mutually agreed as OD eadh carrier of all or any of, sad property over all Or any portion of said route to destinaton and as to each party at any time interested in all or any said property, that every service to be performed hereunder shall he subrect to all the bill of fading terms and conditons in the governing classification on the date of the shipment Shipper hereby cerhfies that he is farreiar with all tFe lading terms erd conditions in the gwerning classification and the said terms and conditens are neretny agreed to by the shipper and accepted for himself and Its assigns. SHIPPER Crow Butte Resources, Inc. CARRIER: Greenfield Logistics, LLC PER: PER: --- DATE: -11:3- \ DATE: / 0 1,- D -1 C f*- arz_ 2 Energy Fuels Resources (USA) Corp. White Mesa Mill 6425 S. Highway 191 Blanding UT 84511 Vehicle ID: 1002 Trailer ID: Account ID: 11(e)2 NEB CROWE BUTTE Order ID: Owner ID: Material ID: 11(e)2 Mat 11(e)2 Material Receipt Destin. ID: BLANDING Transaction No. 57034 Date Time Scale In: 10/11/2021 07:58 1 Out: 10/11/2021 08:50 1 Gross: 67360 lb (M) Tare: 44020 lb Net: 23340 lb Comments: BOL#W-03-21 CBR2 Dperator: 4 Charge by Weight 3ignature: BOL # Controled Elevation used (Cell 3) Area W-03-21CBR2 5607.675 Elevation Transit Shot Initial shot for trench 0.01 Top of trench 5603.285 4.4 Bottom of trench 5597.645 10.04 Initial shot used for material 0.01 Top of material in trench 5601.655 6.03 Top of cell 3 Liner 5608.5 Feet below liner 6.845 Signature* MR/ 6410 Phillip Go e (Oct 27, 2021 15 06 MDT) Email: pgoble@utah.gov