DRC-2021-020062 - 0901a06880fb639a

,,,
State of Utah
GARY R. HERBERT
Governor
SPENCER J. COX
Lieutenant Governor
Department of
Environmental Quality
L. Scott Baird
Executive Director
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Ty L. Howard
Director
ba-20z)-020062_
MEMORANDUM
TO: Project File C-2021-30
THROUGH: Phil Goble, Uranium Mill Section Manager pt-(2 it 7-- 7-&-
FROM: Russell J. Topham, PE
DATE: November 2, 2021
SUBJECT: 2021 Engineering Module 73, Inspection of disposal of 1le.(2) decommissioning debris
from in situ recovery facilities — Disposal Activity October 7, 2021
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) [aka in situ recovery (ISR) 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. 95 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
' This definition amends the language given in Section I1e.(2) of the Atomic Energy Act as amended in 1954 to include in
situ recovery (or 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
2021 ISR Decommissioning Debris Disposal File Inspection Report
November 2, 2021
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)
2021 ISR Decommissioning Debris Disposal File Inspection Report
November 2, 2021
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), inspected the disposal of two loads of decommissioning debris from the Cameco facility near
Douglas, Wyoming.
The material included filters, piping, fittings, sectioned tanks and other assorted debris from the in-situ
leach uranium recovery facility noted above and was transported loose in enclosed roll-off containers.
The containers were emptied near the burial site, decontaminated and released prior to the inspector
arriving onsite. The material qualifies as lle.(2) byproduct material, and is appropriate for disposal in
the Impoundment 3 cap. Upon arrival at the mill, the material was staged near the excavation dedicated
for disposal of 11 e.(2) material. (see Photos 1 through 5 in the accompanying Photo Log)
Prior to this inspection, Energy Fuels was required to segregate disposal sites by generator. This
inspection was the first since Amendment 10 to the above-referenced license was approved, wherein the
requirement to segregate 11e.(2) receipts by generator was removed. As such, the inspector did not
consider segregation of materials, but limited the location-based inquiries to proximity to the
impoundment liner.
This inspection focused on the Licensee's implementation of Standard Operating Procedure SOP PBL-
10, which governs disposal of 11e.(2) byproduct material from in situ recovery facilities. (pertinent data
sheets from PBL-10 used in this inspection are attached) Incoming shipments for all materials are
subject to another procedure, SOP PBL-19, which was not the subject of this inspection. PBL-10 still
referenced earlier requirements for segregation of materials by generator, as discussed above. One
recommendation resulting from this inspection, therefore, is revision of PBL- to conform with
Amendment to the License by removing the requirement to segregate the material by generator. The
Licensee used revision R-3.4 of SOP PBL-10, dated February 1, 2018 for this disposal event. 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 assigned for each 11e.(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 below the upper surface of the tailings, as
required in the governing procedure, neither the excavation nor the debris will endanger the integrity of
2021 ISR Decommissioning Debris Disposal File Inspection Report
November 2, 2021
Page 4
the impoundment liner. Although the segregation of materials is no longer required, the map is useful to
demonstrate that lateral placement of the material avoids conflict with the liner system.
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. (see Photo 3 in the accompanying photo log) Once the debris is placed
in the excavation and compressed, the top of debris is surveyed (see Photo 8), after which cover soil is
placed and compacted (see Photos 9 through 11). Lateral locations were checked by the inspector
onsite. The examined disposal data packets included survey data that shows 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.
The limitation to 5,000 cubic yards lifetime from any generator was modified in Amendment 10 to the
License to allow receipt of up to 10,000 cubic yards per year from any generator. The SOP needs
revision to reflect this change. In any event, the totals received by Energy Fuels were found not to
exceed the licensed limits.
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 notice for both loads disposed. It should be
noted that the scheduled burial for these loads were set at October 8 and October 15, 2021, to meet the
10-day notice requirements. However, with inspectors onsite, early burial was authorized. This allowed
Energy Fuels to remove a safety hazard from the Impoundment 3 surface and more easily meet its
ALARA goals.
Observations
Items reviewed during the inspection included:
1. Initiation date for load document packet
2. Generator identification
3. Pre-shipment radiological report
4. Certification of absence of RCRA-listed products (RCRA Certification)
5. Shipper's manifest
6. Bill of Lading
7. Scalehouse weigh ticket
8. 7-Day notice to the Division
9. Equipment release form (used to document decontamination)
10. Disposal event-related surveys
The above list is more extensive than one generated from the Requirements section of this report, but
reflects the items required in SOP PBL-10.
The burial operation commenced after a brief delay as the field crew gathered at the disposal excavation.
During the burial, appropriate safety precautions were followed, including field hands and inspectors
2021 ISR Decommissioning Debris Disposal File Inspection Report
November 2, 2021
Page 5
positioning themselves upwind of the burial to prevent inhalation of dust or contaminants. As detailed
in the photos, the material was placed in the excavation following survey of the excavation depth. The
top of the material was surveyed once placed in the excavation. The survey data demonstrates that the
disposal operation did not impact the impoundment liner. Following the survey, clean fill was placed
over the debris to complete the burial.
The equipment operator densified the cover soil by wheel walking the loader over the cover soil several
times. The surface was yielding, due to excess pore water in the cover soil. Therefore, the decision was
made to defer this portion of the inspection until the next burial operation, which was anticipated to take
place the week of October 11. Photo 12 in the attached Photo Log shows completion of that operation
following a disposal operation carried out October 14, 2021.
Following the disposal operation, the inspector reported his findings to Mr. Logan Shumway, Plant
Manager.
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 uranium recovery facilities during this operation.
The inspection should be closed out.
SOP PBL-10 should be revised to reflect the generator quantity and burial location standards established
in Amendment 10 to Radioactive Material License #UT19 479.
Photo 1: Excavation prepared to receive 11e,(2) material for burial. One of the
two loads buried this day is staged on the rim of the excavation. Cover
material is staged behind the excavation. Photo taken October 7, 2021.
Photo 2: Surveying the top of the excavation prior to placing two loads of
decommissioning debris from Cameco's Douglas, Wyoming facility into the
excavation. Photo taken October 7, 2021.
Photo 3: Surveying the bottom of the excavation prior to placing two loads of Photo 4: Material from Cameco's Smith Ranch operation near Douglas,
decommissioning debris from Cameco's Douglas, Wyoming facility into the Wyoming. Load 2021-SAT2-14. Photo taken October 7, 2021.
excavation. Photo taken October 7, 2021..
Photo 5: Material from Cameco's Smith Ranch operation near Douglas, Photo 6: Introducing decommissioning debris load 2021-SAT2-14 into the
Wyoming. Load 2021-CCP-15. Photo taken October 7, 2021. excavation. Photo taken October 7, 2021.
Photo 7: Introducing decommissioning debris load 2021-CPP-15 into the Photo 8: Workers surveying the top of the emplaced decommissioning debris.
excavation. Photo taken October 7, 2021. Photo taken October 7, 2021.
Photo 9: Placing capping soil over decommissioning debris from Cameco's Photo 10: Continued placement of capping soil over decommissioning debris
Douglas, Wyoming facility. Photo taken October 7, 2021. from Cameco's Douglas, Wyoming facility. Photo taken October 7, 2021.
Photo 11: Wheel walking capping soil that was placed over decommissioning
debris from Cameco's Douglas, Wyoming facility to densify the cap. Photo
taken October 7, 2021.
Photo 12: Wheel walking capping soil that was placed over decommissioning
debris from Cameco's Douglas, Wyoming facility to densify the cap. Photo
taken October 14, 2021.
OFENERGY 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
September 22, 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) UTI 900479 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 8, 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,
Ganin Palmer
cc: Denver Central Files
]nergy Fuels Resources (USA) Corp.
ihite Mesa Mill Transaction No.
5425 S. Highway 191 57003
31anding UT 84511
Date Time Scale
In: 10/01/2021 14:24 1
Out: 10/01/2021 14:49 1
lehicle ID: 1002
Frailer ID:
kccount ID: 11(e)2 WYO SMITH RANCH / HIGHLAND
Drder ID:
Dwner ID:
qaterial ID: 11(e)2 Mat 11(e)2 Material Receipt
Destin. ID: BLANDING
ZCi-4 2v 2L5AT2 -it-
omments: BOL 2021-SAT2-14 CONT 2160
Dperator: 4 Charge by Weight
Gross:
Tare:
Net:
48780 lb (M)
44280 lb
4500 lb
Signature:
Shipper No. 2021-SAT'

STRAIGHT BILL OF LADING
ORIGINAL—NOT NEGOTIABLE

Carrier No. NA

GREENFIELD LOGISTICS

Date

(NAME OF CARRIER) (SCAC)

Time
Collected on Delivery shipmcnts, the letters COD must appear before consignees name or as otherwise
provided in item 430, Sec, I.
To: Consignee Energy Fliels
Street: 6425 South HWY 191
City: Blanding State: UT Zip Code: 84511
... _
From: Shipper Cameco Resources
Street: 762 Ross Road
City: Douglas State: WY Zip Code: 82633
24 hr Emergency Contact Tel. No: 1 [phone]
Kr. John Zaidan; Contractual Agreement with National Response Corporatioi
Route: See Attached Vehicle:
Number N/A
No,of units &
container type HM Basic Description
Proper Shipping Name, Hazard Class,IdermEcatiors Number (LtIvl or NA). Packing group, per 172.101, 172 202, 172.203 Total Quantity
(Wei ght, Volume, Gallons, Mt)
Weight
( Subject to
Correction)
Rate Charges
(For Carrier Use Only)
I Roll Off X UN29I2, RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY (LSA-I),
CLASS 7 13.2m3 (17.29ycPi
RADIONUCLIDE: NATURAL URANIUM, THORIUM-230 AND RADIUM-
226
PHYSICAL FORM: SOLID
CHEMICAL FORM: UNAT WITH DAUGHTERS
TOTAL ACTIVITY:
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, OR BREAK SEAL
PLACARDS TENDERED: YES: X NO:
REMIT C.O.D. TO:
ADDRESS N/A
Note.(1) Where the rate is dependent on value, shippers arc required 10 state
specincally on writing the agreed or declared value of Me property, as follows: The
agreed or declared value of the property is hereby specifically stated by the shipper to
be dOi exceeding ,, r .
(2) Where the applicable tariff provisions specify a bmnatton of the earner's liability
absent a release or a value declaration by the shipper and the shipper does not release
the carries liability or declare a value. the carries liability shall be limited to the
extent provided by such provisions_ See NWT. item 172.
(3) Commodities requinng special or additional care or attention in handling or
slowing must be so marked and packaged as to ensure safe transportation. Sm
Section 210) of item 360 Bills of Lading, Freight Bills, and Statements o f Charg es
and Section l(a) a tbc Contract terms and conditions (or a list of such articles.
thereby declare that the contents of this consignment are hilly and aecurately described above
by the proper shipping name and arc classified. packaged, marked and labeled/placard and
are in all respects in proper condition for transport according to applicable international and
national governmental regulations
COD Amt: $
N/A
C.O.D.
FEE: N/A
PREPAID
c
COLLECT
Li
ON BEHALF OF SHIPPER
/
72-j.7/ ei4e..,,,Aftie4
Signatura
'unmet to h, ,.,rin ell., cont3thons 11 this
shipment is to be delivered to the consignee
without recourse on the consignor, the consignor
shall sign the following staierneni,
The carrier shall not makc delivery of this
shipment without payment of freight and all other
lawful charges.
N/A
TOTAL
CHARGE': N/A
FREIGHT CHARGES
FREIGHT PREPAID
exCepl. Check box if charges
when box Li am to be collected (Signature of Consianor)
RECEIVED, sat,ect to the elassiticahons and tariffs in effect OA the date aims ofthif Nil of lading, the property described abort in apparent good order, except as noted (con Una and condamo of =lona of wimp. unknown), marked, consigned, and destined as indicated Above which said carrier (the wmd earner ening undergood throunhout dm coronet as meaning any person or corporal inn ir possassion of this propcny under the cordritall was to wry la as a.m. pace of dehrety at sad destination. If on its meta mbar.. to dativnr to another cattle, on Me route re secd destination lt is mataally agreed as to each sante, or pp. ony ot said property over all or say portion of said route to destination and as to each party at any hmo ,n monied in all or any said property, that cvcry WV. to ac redefined hereunder shall be se*. to all ine bill alining harms and conditions in the governing classification on the data of Om shipment.
Shipper hereby unites that he is (amiliaa with all the lading terms and oonditions in the governing classification and the said terns and conditions ate Ivreby agrend in by dm elliptic, and accepted for himself and ins assigns.
SHIPPER: CAMECO RESOURCES CARRIER: GREENFIELD LOGISTICS _ ,
PER /`' ili/ 67-16—/- PER
DATE 96V/2.1 1)ATE ...3 (5 - Z._ j

czo-em-Leo /414 /6 A 4/7
101-71

Rev 6 - January 6, 2020
Page 1 of 1
WYO-RPP-FORM-031 Bill of Lading

BOL #
Controled Elevation used (Cell 3)
Area
2021-SAT2-14/ 2021-CPP-15
5607.675
Elevation Transit Shot
Initial shot for trench 0.01
Top of trench 5602.375 5.31
Bottom of trench 5597.675 10.01
Initial shot used for material 0.01
Too of material in trench 5600.955 6.73
Top of cell 3 Liner 5608.5
Feet below liner 7.545
4
No.: PBL-10
Rev. No.: R-3.5 Date: August 4, 2021
ENERGY FUELS RESOURCES (USA) NC. STANDARD OPERATING PROCEDURES Title: lle.(2) Byproduct Disposal Page 10 of 12

ATTACHMENT 2
llea) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date: lb /I Alb 2.1
Name of employee receiving the load:"<Aner
Generator of the Byproduct Material: Lestyler" Re_souisceS
Shipper's Manifest or Bill of Lading number: xo2.-1 sirrp.-I
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?
CrArriii Navy- Sop 22. Apai
Descriktion of byprcduct material disposal area/activities: -rdtVlon Shee3
Has each drum been inspected to identify the presence of any void spaces? "/'/it
Have all drums with void spaces been filled with tailings sands or soil? Ade,.
Which tailings cell was the material placed in? Gen
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? I
/44,64-er;ai ph.00. 4.1-ent11 iJ1. s11 40 4se. Sokii)S
Engineer's or
Environmental
Coordinator's
Initials
Was the material placed in a cell approved by the Director for ISL
waste disposal? 1/4fr
Documentation of approval -AI a / fee
Was the maximum lift thickness above tailings less than 4 feet
thick? /.e)*
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?
Is the bottom of each disposal area at least 12 feet from the sides or dikes
of the tailings cell?
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)
C.4 e'vt
No.: PBL-10
Rev. No.: R-3.5
Date: August 4, 2021
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES Title: 11e.(2) Byproduct Disposal
Page 1 l of 12

Manifest or BOL #: A.02.1 - c1/4-ra
Have the thickness and placement measurements been verified and documented for the disposal area by
the engineer, specifically:
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?
4-40,1- el--; Ci, 1 itt I+, S f i r...-, Gk. i f rc.....g-t.4. -1-1,44- 4- L.,.4 ci ch.,..~... .h.: 4-1,, s^...As
Were void spaces filled with tailings? virj
Was the shipment properly covered?
/Li _s Z.- L.- A..1.7skir -

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 12 of 12

Manifest or BOL #: - 3/11-2-11
Are additional settlement monitors required to be placed?
Alf)
If required, where were the settlement markers placed?
AeeA
Radiological receipt survey measurements:
O. 07 MR/hr. PID— 0
Breathing Zone:
1. Was a Breathing Zone Sample collected? Yes
2. If yes, what were the results of the sampling?
tiO
Was a photograph taken during the unloading activities Yes No
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
September 29, 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 15th, 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 2o 21- 6-P8 - is
cc: Denver Central Files
Energy Fuels Resources (USA) Corp.
White Mesa Mill Transaction No.
6425 S. Highway 191 57011
Blanding UT 84511
Date Time Scale
In: 10/05/2021 09:52 1
Out: 10/05/2021 10:24 1
Vehicle ID: 1002
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
Destin. ID:• BLANDING
6ex-417-1 6W-is
Gross: 55080 lb (M)
Tare: 44200 lb
Net: 10880 lb
Comments: BOL 2021-CPP-15 CON 001018
Operator: 4 Char e by Weight
Signature:

Shipper No.

STRAIGHT BILL OF LADING
ORIGINAL—NOT NEGOTIABLE Carrier No. NA
GREENFIELD LOGISTICS Date

(NAME OF CARRIER) (SCAC)
Time
Collected on Delivery shipments, the letters COD must appear before consignees name or as otherwise
provided in item 430, Sec. I .
To: Consignee Energy Fuels
Street: 6425 South HWY 191
City: Blanding State: UT Zip Code: 84511
From: Shipper Cameco Resources
Street: 762 Ross Road
City: Douglas State: WY Zip Code: 82633
24 hr Emergency Contact Tel. No: 1 [phone]
Mr. John Zaidan; Contractual Agreement with National Response Corporation
Route: See Attached Vehicle:
Number N/A
No.of units &
container type HM Basic Description
Proper Shipping Name, Hazard Class,Identification Number (11M in NA), Packing group, per 172.101, 172.202, 172.203 Total Quantity
(Weight, volUnie, Gallons, etc)
Weight (subj.,
Correction)
Rate Charges
(For Comer Usc Only)
I Roll Off X IJN2912, RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY (LSA-1),
CLASS 7 18.9m (24.7yd3)
RADIONUCLIDE: NATURAL URANIUM, THORIUM-230 AND RADIUM-
226
PHYSICAL FORM: SOLID
CHEMICAL FORM: UNAT WITH DAUGHTERS
TOTAL ACTIVITY:
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, OR BREAK SEAL
PLACARDS TENDERED: YES X NO:
REMIT C.O.D. TO:
ADDRESS N/A
Note (I) Where th eme rate zs dt on value, shippers are required to gate
speoofmally on writing the agreed or declared vidue of the property. as follows The
.grood or dooi.00 or400 onbo proporLy . boroby vooibuily sbood by tho ith ,0
be not mu:coding ,er
(2) Where the applicable tariff prov.ions specify a limitation of the earner's liabtlay
absent a release or a value declaration by the shipper and the shipper does not release
the eartiren liability or declare a value, the carriers liability shall be landed to the
extent provrded by such provisions Sec NNW!, nem 172.
(3) Cortunodmes requiring special or addittonal tare or attenhoo in handling or
stoning must be so marked and packaged as to ensure safe transportation. See
Section 2(e) ducat 360, f3ills of Lading, Freight Bills, and Statements of Charges and
Section 1(a) of the Contract terms and crmdi lions for a list dutch articles
I hereby declare that the contents of this consignment are
the proper shipping name and art clasnfied, packaged,
all respects in proper condition for transport according
r'guldic'''
ON BEEALF OF SUPPER
flIt -7; , , ,se [ - - ,
Signature
fully arid accurately described above by
trucked, and labelcdPplaearel, and are in
to applicable International and national
COD Aim' S
N/A FEE: N/A PREPAID
o
COLLECT
o
^1.1'. jeCA JO SOCILIOD 0, 110 C0,10004 I '' ,S
shipment is to be delivered to the consignee without
recourse on the consignor, the consignor shall sign
the following Mamma
Thc carrier shall not make delivery of this shipment
wuhniu payment of freight and all other lawfil
charges.
N/A _
TOTAL
C"ACWS- N/A
FREIGHT CHARGES
FREIGHT PREMID
except Check nox if charges
when box at n are to be collected
4,1-. - -
/Stalwart of coRtgagn
caCalOE1.1, subject to No ClusirNalrOnl VW tan lis ln diem on Mc date Prime grins Bill of lading, the property dcsaibed above in apparent eond rader, accept as naiad IcalltrIS itbe condition of eon.. of packages anknuan), marked, eneugrea and deathak ia indicated ct.oc ,ckich yid Nc,c, ldre wcrd cyci., xj,,, umancopc
luoughual this woe. as meaning any porton or corporation in possession of Ns property ander dy comma) agrees En oany to its usual place of delivery st mid el...Marino if or ih route otheraion N deliver tu extra cania en the male De said elestinalten Et is mutual], agreed as to each clime ore or arty of said prowy 0., .11 p
any portion au. nate 111 destination and as le eath early al eny tune inbound m ell or any said property, gat every smite to bc patterned hereunder shall he subioci in all the bill of ading toqns and conditions in the govemine chinsficaliOn CM NC Clue erne thipNeN
gruppa Kerby caCtica the he is termitic with all the Wag WT. and eatelibons rn de gowning elasafaanon and dra said term and conditions aro hereby aprnsed to by dre shipper and accepted lbr himself and his assigns
SHIPPER: CAMECO RESOURCES CARRIER: GREENFIELD LOGISTICS
PER .-.."7-L,...;,, c,../..„4 _zwz-- PER ler: zie -<,-..-----
DATE la I 417—I DATE 119-q .4.)
ces.; 7 (-14.4

/O. -3"---24

Rev 6 -January 6, 2020
Page 1 of 1
WYO-RPP-FORM-031 Bill of Lading

BOL #
Controled Elevation used (Cell 3)
Area
2021-SAT2-14/ 2021-CPP-15
5607.675
Elevation Transit Shot
Initial shot for trench 0.01
Top of trench 5602.375 5.31
Bottom of trench 5597.675 10.01
Initial shot used for material 0.01
TOD of material In trench 5600.955 6.73
Top of cell 3 Liner 5608.5
Feet below liner 7.545
No.: PBL-10
Rev. No.: R-3.5
Date: August 4, 2021
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES Page 10 of 12 Title: 1 le.(2) Byproduct Disposal
ATTACHMENT 2
lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date: ,ols/
Name of employee receiving the load:
Generator of the Byproduct Material: 6 J..- OA- 11 ••• f- g--S
Shipper's Manifest or Bill of Lading number: P c
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?
Description of byproduct material disposal area/activities: r, 3 1>
Has each drum been inspected to identify the presence of any void spaces? AÌA
Have all drums with void spaces been filled with tailings sands or soil? //A
Which tailings cell was the material placed in? „.7)•-77
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?
1 *3
No.: PBL-10
Rev. No.: R-3.5
Date: August 4, 2021
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 1 e.(2) Byproduct Disposal
Page 1 l of 12

Manifest or BOL #: 2.o c_PP- IS
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?
-`-. Documentation of approval /, t e.,1$e 4 ar if od Y 7 ie
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? 1,
Has 4 foot of tailings sands been maintained under each disposal
area? 'r e..5"
Is the bottom of each disposal area at least 12 feet from the sides or dikes
of the tailings cell? 'tics
-...- Will the elevation of the material exceed the plane or grade of the
elevation of the uppermost flexible membrane liner of the cell? Alo
How was this confirmed (e.g., survey or review) .,-
How was the area compacted? Was each lift compacted by heavy equipment (such as a Cat D-6) at least
4 times prior to placement of subsequent lifts? A _•.•. Li) c- 4A., f pd.it la L- 014 c Lt
eL,-- 17;1 .
Were void spaces filled with tailings?
_S
Was the shipment properly covered?
y,- SE leo
PBL-10
Rev. No.: R-3.5
Date: Moist 4, 2021
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES Page 12 of 12 Title: lle.(2) Byproduct Disposal
Manifest or BOL #: 2o2 PPiS-
Are additional settlement monitors required to be placed?

If required, where were the settlement markers placed?
Radiological receipt survey measurements:
„2. / LA."
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? Yes or No