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HomeMy WebLinkAboutDRC-2020-016836 - 0901a06880d4bec7ilt State of Utah GARY R. HERBERT Governor SPENCER J. COX Lieutenant Governor Department of Environmental Quality L. Scott Baird Interim Executive Director DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL Ty L. Howard Director DRC-2020-016536 MEMORANDUM TO: THROUGH: FROM: DATE: SUBJECT: Authority Project File C-2020-39 Phil Goble, Uranium Mill Section Manager Heather Mickelson, PE, PG (-4(Lieteitc-/74,tej4,050v.....) 6 \ [61,12k)-2,-0 May 19, 2020 May 7, 2020 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. Radioactive Materials License #UT1900479 Amendment 9, Condition 10.5: "In accordance with the Licensee's submittal to the NRC dated May 20, 1993, the Licensee is hereby authorized to dispose of byproduct material generated at licensed in situ leach (ISL) facilities, subject to the following conditions:" (Conditions are included below in the Requirements section.) R313-12-3 (quoting 10 CFR 40.4): "Byproduct Material means the tailings or wastes produced by the extraction or concentration of uranium or thorium from any ore processed primarily for its source material content, including discrete surface wastes resulting from uranium solution extraction processes."1 10 CFR Part 40 Appendix A, Criterion 2: "To avoid proliferation of small waste disposal sites and thereby reduce perpetual surveillance obligations, byproduct material from in situ extraction operations, such as residues from solution evaporation or contaminated control processes, and wastes from small remote above ground extraction operations must be disposed of at existing large mill tailings disposal sites; unless, considering the nature of the wastes, such as their volume and specific activity, and the costs and environmental impacts of transporting the wastes to a large disposal site, such offsite disposal This definition amends the language given in Section 1 1 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 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 (801) 536-0200 • Fax (801) 536-0222 • T.D.D. (801) 536-4284 www.deq.utah.gov Printed on 100% recycled paper Second Quarter 2020 ISL Decommissioning Debris Disposal Inspection Report May 19, 2020 Page 2 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 four (4) loads of 11 e.(2) byproduct material on May 7, 2020 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 April 23, 2020. Operating Procedures and Records This inspection was specific to the Licensee's implementation of Standard Operating Procedure SOP PBL-10, which governs disposal of 11 e.(2) byproduct material from ISL facilities. Revision R-3.4, dated February 1, 2018, is the most recent version. The Licensee maintains hard copies of the buried 1 1 e.(2) material records onsite. The current year's disposal records are stored inside the White Mesa Mill's office building and prior years' records are stored in an onsite storage container within the restricted area. Copies of the data packets for each load disposed during this inspection are attached to this report. The Licensee maintains a map of Tailings Cell 3 in the mill office that shows the dedicated disposal locations for each 11 e.(2) byproduct material generator. 1le.(2) Byproduct Material Disposal Activities and Description Prior to May 7, 2020, the disposal pit location was determined, located by survey, and excavated. The bottom of the excavation extended into the tailings sand. The 11e.(2) byproduct material was placed near the burial pits and processed for burial (Photo 1). Barrels were crushed prior to disposal to minimize void space. During the May 7, 2020 inspection, the Division observed the final disposal activities. Prior to placement, the excavation depth was surveyed. Once the 11 e.(2) byproduct material was in the excavation, the top of the material was surveyed (Photo 2). Clean cover was then placed over the 1le.(2) byproduct material and then compacted to further minimize void spaces (Photos 3 and 4). The vertical extent of the burial was below the top of the tailings and above the bottom liner. Four (4) loads of 11 e.(2) byproduct material was from Cameco Resources — Cameco-Smith Ranch in Douglas, Wyoming. The material from this load consisted of sediment in supersacks, filter pipes and trash (Photo 1). Close Out Meeting A close out meeting to discuss observations during the inspection included Heather Mickelson, Phil Goble, Logan Shumway (Plant Manager), Terry Slade (Radiation Safety Officer), Garrin Palmer and Tanner Holiday. Second Quarter 2020 ISL Decommissioning Debris Disposal Inspection Report May 19, 2020 Page 3 Requirements and Compliance Determination 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." The activities observed and information gathered during this inspection supports a conclusion that the Licensee is complying with this license condition. Barrels were crushed prior to their placement in the Cell 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." 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 descriptions of the ISL waste and the disposal locations, as well as all actions required by this license condition." 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: "ISL Disposal Requirements. The licensee shall perform ISL disposal activities in accordance with the currently Director approved Standard Operating Procedure (SOP) for ISL disposal. Said plan includes the following minimum provisions: (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 shall not exceed the plane or grade of the elevations of the uppermost flexible membrane liner of the tailings cell; (3) Such ISL byproduct material shall 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 shall 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: a. There are at least four 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." Second Quarter 2020 ISL Decommissioning Debris Disposal Inspection Report May 19, 2020 Page 4 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 segregating generator 11 e.(2) byproduct material streams, 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 seven 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." 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 April 23, 2020, which is greater than 7 days in advance of burial that occurred on May 7, 2020. 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 11 e.(2) byproduct material generated as decommissioning debris from ISL uranium recovery facilities. Attachments: 1le.(2) Byproduct Receipt Notification dated April 21, 2020 Document packet for Cameco-Smith Ranch 1le.(2) byproduct material bearing Bill of Lading # 2020-SEL- 01 Document packet for Cameco-Smith Ranch 1 le.(2) byproduct material bearing Bill of Lading # 2020-SEL- 0002 Document packet for Cameco-Smith Ranch 1le.(2) byproduct material bearing Bill of Lading # 2020-SEL- 003 Document packet for Cameco-Smith Ranch 1 le.(2) byproduct material bearing Bill of Lading # 2020-CPP- 004 Photo 1. Cameco-Smith Ranch 1le.(2) byproduct material to be buried. Photo taken on May 7, 2020. Photo 2. EFR measuring the top elevation of the Cameco-Smith Ranch buried I I e.(2) byproduct material. Photo taken on May 7, 2020. Photo 3. Compacting the Cameco-Smith Ranch 1le.(2) byproduct material and Photo 4. Final cover of the compacted clean cover over the buried Cameco-Smith placing clean cover. Photo taken on May 7, 2020.. Ranch 1le.(2) byproduct material. Photo taken on May 7, 2020. Energy Fuels Resources (USA) Inc. Clog 6425 South Highway 191, PO Box 809 Blanding, UT. US, 84511 ENERGY FUELS 435 678 2221, fax 435 678 2224 DRC- 2020 — oosm39 www.energyfuels.com Div o ragement and Rad.ation Control APR 2 3 2020 April 21, 2020 VIA Electronic Mail (PDF) and UPS Mr. Howard 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. Howard, Re: 11e.(2) Byproduct Receipt Notification Pursuant to Radioactive Materials License (RML) UT1900479 condition 10.5.F, Energy Fuels Resources (USA) Inc. is hereby notifying the Division of Waste Management and Radiation Control that the White Mesa Uranium Mill will be receiving and disposing of four loads by May 8th, 2020. 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 No.: PBL-10 Rev. No.: R-3.4 Date: February 1, 2018 ENERGY FUELS RESOURCES (USA) INC. STANDARD OPERATING PROCEDURES Title: 1 1 e.(2) Byproduct Disposal Page 11 of 13 ATTACHMENT 2 lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM Date: Li/2( NO Name of employee receiving the load: 1+ L.. 44..."- 0"'%•44-r- 14011; °Lc? Generator of the Byproduct Material: C..4...A.44.47 Shipper's Manifest or Bill of Lading number: Z.0 - Was the State of Utah given notice to the receipt/disposal activities associated with this load? o No Who gave and when was the, notification given? 1 zi Izo Description of byproduct material disposal area/activities: Has each drum been inspected to identify the presence of any void spaces? Have all drinns with void spaces been filled With tailings sands or soil? Which tailings cell was the material placed in? I 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? ,AA t..-4 ex- IA Gt.) 04 Lt. i e.... r_e." & (A.._ 1-1"AN.4 C.0-)t.44 AO LA-• ". f C, 44.4- Was the material segegated from any Mill material or equipment disposed of in the cell? Was the material segregated from byproduct material from other ISL sources disposed of in the cell? At No.: PBL-10 Rev. No.: R-3.4 Date: February 1, 2018 ENERGY FUELS RESOURCES (USA) INC. STANDARD OPERATING PROCEDURES Title: 11e.(2) Byproduct Disposal Page 12 of 13 Manifest or BOL #: oZo - -0 ( Have the thickness and placement measurements been verified and documented for the disposal area by the engineer, specifically: Engineer's or Environmental Coordinator' s Initials Was the material placed in a cell approved by the executive Secretary for ISL waste disposal? Documentation of a royal Le # / iv(' Was the ISL material segregated from disposed Mill material and other ISL material? po Refer to plat(s) used to confirm. ev/ 3 //e. Z 8, 4,,,v•I 4". 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? rej Has 4 foot of tailings sands been maintained under each disposal area? Refer to drawin used to confirm tell 3 Is the bottom of each disposal area at least 1 2 feet from the sides or dikes of the tailings cell? Yes. Refer to drawin . used to confirm. // 3 4ftir.4 Will the elevation of the material exceed the plane or grade of the elevation of the uppermost flexible membrane liner of the cell? .A4 17 How was this confirmed (e.g., survey or review) 1,t el", 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 re, J Cœ0 -uft-f 4 Were void spaces filled with tailings? y, Was the shipment properly covered? Ycs No.: PBL-10 Rev. No.: R-3.4 Date: February 1, 2018 ENERGY FUELS RESOURCES (USA) INC. STANDARD OPERATING PROCEDURES Title: lle.(2) Byproduct Disposal Page 13 of 13 Manifest or BOL Zo 0 - • ( Are additional settlement monitors required to be placed for this generator? Alk If required, wherkwere the settlement markers placed? i Radiological receipt survey measurements: AZ. I 41.4r- 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 Shipper No. 2020-SEL-0 t STRAIGHT BILL OF LADING ORIGINAL—NOT NEGOTIABLE Carrier No. NA GREENFIELD LOGISTICS (NAME OF CARRIER) (SCAC) Time q: Collected Oci Delivery shipments, the letters COD must appear before consignee s name or as otherwise provided in item 430, Sec, 1. 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 (905) 885-8745 Mr. John Zaidan; Contractual Agreement with Quantum Murray Route: See Attached Vehicle: Number N/A No,of units & container type HM Basic Description Proper Shipping Name, Hazard Class,Identilleation Number (UM or NA), Packing group, per 172 101, 172,202, 172,203 Total Quantity (Weight, Volume, Gallons, Mc) Weight (s,,w. i, Correction) Rate Charges (For Cartier Use Only) 1 Roll ofr ‘,. A UN2912, RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY (LSA-1), CLASS 7 7.6m3 (10y(13) RADIONUCLIDE: NATURAL URANIUM, T1ORIUM-230, RADIUM-226 AND LEAD-210 PHYSICAL FORM: SOLID CHEMICAL FORM: IRON OXIDE t -. TOTAL ACTIVITY: .3.81E813q (0.010 Ci) Z0,. ( „, ... 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 DO NOT LOAD OTHER FREIGHT IN THIS VEHICLE, TRANSFER EN ROUTE, OR BREAK SEAL — PLACARDS TENDERED: YES: X NO: ADDRESS N/A Nolc,(1) Where the rate is dependent cm value, shippers are required to stale specifically ca„amg tbc mew se skewed yak. orde pro,„„y, aa follows, Tho es,„d „declared sotso of th. propony „ bemby specifically claw by obc gappes te bc not exceeding pm 1 hereby declare Mai the contents of this conwgnment are fully and accurately described above by the proper shipping name and are classified, packaged, marked, and labeled//placard, and arc ni all respecis in proper condition tbr transport accardIng to applicable international and COD And. S N/A C OD. FEE N/A PREPAID o COLLECT (2) Where the applicable milli provisions specify a linnuabon of ihe carrier's liability nationol g.....lol rcgolmio.n o absent a release or a value declaration by the sluppar and the Shipper does not release the carrier's liability or declare a value, the nitric?, liability shall be Moiled to the extent promded by such provisions, see MEL item 172. 'htrWoelltt Nieien 7 of not COndintiti if nin shipment is to be delivered to the Consignee valour rocoure on the consignor, the consignor TOTAL CHARW N/A (3) Conunodthes requinng spacial or additional care or attention in handhng or stowing MN be so marked and packaged as to ensure sate transportation See Section 2(c) of itein 360, Bills &Lading, Freight Rills, and Statements ot Charges ON BEHAVOF SHIPPER shall sign the following statenietit The carrier shall not make dentry dais shipment without payment of freight and all other lawful charges FREIGHT CHARGES FREIGHT PREPAID and Section lee of the Contract ikons and conditions for a ha dwell articles Signature N/A meat Cinek bias if charges titi, utaxitoknea ulp b.. 0 art tn he colistss4 MEMO seine to the ehosificetiems end wan In died on the dote of mon of this NI of Urban, the property de...bed Anne ín uppetent good order. except as noted (woe. and tootfittett of contents of pan= ontothha meted, manned, nod sloped as isdosiol shoos ‘4”,/, odd .,,,,k, (O. hod ,,,,,,,,,,,,, entlennoal Ihtoothnet dhs oenugat ...ohs osy pt.. ot omoo.tan et posonsion etthis pooperty alder the contact) wan to on ro th mad plane of &be* at maid destitution, rf..o to mut, otherwire oo dnlo. re tooth., prone on the moo to *id destination It is mutua)y agreed es touch corm art or toy 0( and properly over Ala say porton ersed Mk (0 donee. end as to nob ratty et any Wee internted et ell or ney sad property, that every service ie be trammed herennolcr shnit be .1/. loth the bd1 of lading lams and onecktionn to the govethong dashficatten on the date of the shipment Shwa hereby <chines that ha a &nil. watt all the loduto terms red condihnes in the geranium classilionon sad ore Said Inner and =Woos ere hereby awned to by ths stepper and mowed for Annear end he amps. SHIPPER: CAMECO RESOURCES CARRIER: GREENFIELD LOGISTICS PER PE DATE DA Ot/171)/M70 Rev 6 - January 6, 2020 Page 1 of 1 WYO-RPP-FORM-031 Bill of Lading Cameco Controled Elevation used (Cell 3) BOL # Area 5612.6 2020-SEL-001 Elevation Transit Shot Initial shot for trench 1.48 Top of trench 5606.48 7.6 Bottom of trench 5600.18 13.9 Initial shot used for material 1.48 Top of material in trench 5605.32 8.76 Top of cell 3 Liner 5608.5 Feet below l ner 3.18 Comments: CONTAINER GFLU 001193 lo 0-0 - Operator: 4 JICharg by Weight Signature: Energy Fuels Resources (USA) Corp. White Mesa Mill Transaction No. 6425 S. Highway 191 55278 Blanding UT 84511 Date Time Scale In: 04/21/2020 08:57 1 Out: 04/21/2020 09:40 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 Gross: 59840 lb (M) Tare: 44700 lb Net: 15140 lb I No.: PBL-10 Rev. No.: R-3.4 Date: February 1, 2018 ENERGY FUELS RESOURCES (USA) INC. STANDARD OPERATING PROCEDURES Title: 11e.(2) Byproduct Disposal ATTACHMENT 2 1 le.(2) BYPRODUCT MATERIAL, DISPOSAL DOCUMENTATION FORM Date: / V-11 26 Name of employee receiving the load: it; elLe. kJ/L-5 Generator of the Byproduct Material: f Shipper's Manifest or Bill of Lading number: 2n zo - sac, - Doo z. Was the State of Utah given notice to the receipt/disposal activities associated with this load. No Who gave and when was the notifi ation given?,, Pe 2.1 z Description of byproduct material disposal area/activities: •••stA Led- Has each drum been inspected to identify the presence of any yoid spaces? /1- Have all drums with void spaces been filled vvith tailings sands or soil? Am- Which tailings cell was the material placed in? C c- / / 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? V Lk. "Arta Was the material segregated from any Mill material or equipment disposed of in the cell? Was the material segregated from byproduct material from other 1SL sources disposed of in the cell? 1cz i- 3 No.: PBL-10 Rev. No.: R-3.4 Date: February 1, 2018 ENERGY FUELS RESOURCES (USA) INC. STANDARD OPERATING PROCEDURES Title: 1le.(2) Byproduct Disposal Page 12 of 13 Manifest or BOL #: .*Z.0 Z-0 C., —0 0 a Have the thickness and placement measurements been verified and documented for the disposal area by the engineer, specifically: EnOneer's or Environmental Coordinator' s Initials Was the material placed in a ce I approved by the executive Secretary for 1SL waste disposal? re6 Documentation of approval A,' or/ or,V1f Was the ISL material segegated from disposed Mill material and o her ISL material? Refer to plat(s) used to confirm. Cell 3 lIe. 7 0,' it 1 Immo- Was the maximum lift thickness above tailings less than 4 feet thick? fr;i- Was the maxim= lift thickness of subsequent lifts less than 2 feet thick? kf it Has 4 foot of tailings sands been maintained under each disposal area? ,P,rs Refer to drawin s used to confirm Cell 3 it Is the bottom of each disposal area at least 12 feet from the sides or dikes of the tailings cell? g f Refer to drawings used to confirm. All 3 A. Wi11 the elevation of the material exceed the plane or grade of the elevation of the uppermost flexible membrane liner of the cell? it4 How was this confirmed (e.g., survey or review) 5iteme 4„, 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 rt.". AA'c' S Were void spaces filled with tailings? Was the shipment properly covered? Ye.A, v No.: PBL-10 Rev. No.: R-3.4 Date: February 1, 2018 ENERGY FUELS RESOURCES (USA) INC. STANDARD OPERATING PROCEDURES Title: 11e.(2) Byproduct Disposal Page 13 of 13 IVIanifest or BOL #: 2020 - SE'fro (2° Are additional settlement monitors required to be placed for this generator? If required, where were the settlement markers placed? iv Radiological receipt survey measurements: . 0A2-114,- , 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 activitie Yes oi No STRAIGHT BILL OF LADING ORIGINAL—NOT NEGOTIABLE Shipper No. 2020-SEL- owg Carrier No. NA Date itzgizow GREENFIELD LOGISTICS (NAME OF CARRIER) (SCAC) Time Heeled on Delivery shipments, the letters COD must appear before consisnee's name or as otherwise provided in item 430, Sec, 1. 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 (905) 885-8745 Mr. John Zaidan; Contractual Agreement with Quantum Murray Route: See Attached Vehicle: Number N/A No.of units & container type HM Basic Description Proper Shipping Name, Retard Class,IdentificatIon Number (UM or NA) Packing group, per 172.101, 172 202, 172 ND Total Quantity (Weight, Volum, ((allons. cm) Weight 0„,,,, to Comedian) Rate Charges (For Carrier Use Oniy) I Roll Off X UN2912, RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY (LSA-1), CLASS 7 9.9m3 (13yd3) RADIONUCLIDE: NATURAL URANIUM, THORIUM-230, RADIUM-226 AND LEAD-210 PHYSICAL FORM: SOLID CHEMICAL FORM: IRON OXIDE TOTAL ACTIVITY: ',4.95E8 Bq (0.013 Ci) EXCLUSIVE USE SHIPMENT: THIS VEHICLE IS ASSIGNED FOR EXCLUSIVE USE OF CAMECO RESOURCES, 1NC. UNDER PROVISIONS OF 49 CFR 173.427 INCLUDING EXEMPTING FROM MARKING AND DO NOT LOAD OTHER FREIGHT IN THIS VEHICLE, TRANSFER EN ROUTE, OR BREAK SEAL PLACARDS TENDERED: YES: X NO: ADDRESS N/A Note-(1) Where ilte Itile as dependent on value, shippers ere required to wale speergeelly en emit, the weed er gedeted yew or tho ,,,,,,,i, .. Eon., Th. weed et. erehned „ale, etithe pr000fly i, hereby speeirteolly stated hy the ohippeo to be oat exceeding, IN, . I hereby declare that the rontents of this consignment are fully and accurately described above by the proper shipping name end ere classified, packaged, marked, and labelcd//placul, and are m all respects in proper condition for transpott according to applicable international and COD Ann S N/A C.O.D. FEE N/A PREPAID t, COLLECT (2) Where the applicable tariff specify a limitation of the earner's liability provisions willnalli Smfililisiwi) .17iinhons d absent a release or a va)ue declaration by the shipper and tlic shipper does riot release the carries liability or declare a value, the carrier's brashly shall be limited to roc WPM provided by such provisions See NMEL Item 171 roam to section 1 00 the =UAWroo gibcr shipment is io be delivered to the consignee without recourse on the consignor. the consignor 1 OTAL CHARG'I NI A (3) Commodities requiring special or additional care or attention in handling or stowing must be so marked asi packaged es to ensure safe lmnsponalion See Section 2(e) of ilein 340, Bills of Lading, Freight BdIs, and Statements of Charges ON BEHALF OF SHIPPER \ js c) LP Lik shall sign the following statement: The carrier shell not make delivery of this shipment without payment of freight and all other lawful charges FREIGHT CHARGES FREIGHT PREPAID and SeCtiort 1(o) elite Contract terms end conditions for a list of such articles Signature X& except Check box if charges ESSItaloteritCrolfithRES1 sidien1vvi a. Pa tetha a at RECEIVED subject to the elnsificatiorm ancl ter;Irs in efligt on ilm <late dig...411as FPO nfladmR. the poverty desenbed above in apporent food order mapt en noted (coma. ad madam a moan, apookapos entaran). muted ronagned, nod deained a talented WM. which and amer (the word enroar ha.ag understood thaeoghout Ns contract am moms any pawn or empertano In rooteasen of OM poolvey ander Ihe center) arms to carry se its trod plea of &ban a said deanahm !ton an gmte.otherwine to deli,. to mother eanier oa the route to amid &Attainss. It la mutually agreed . to mat enr.-in. of .lt et en, at; earl pmpervy over arl or any protium aged route to &amebae and as ro emelt parry army tint inatorted in al or roW sad nroperp, Ihnt may maim lo tro performed ?maunder shrill be subject to all the bal of Wino terrol end Sweetens in ea governing oltheiseurion on Mt date ache stoma, an*sv hereby ceollita th.1 he is familiar with all the ladms letom and condittona re the pawning eleasrliaanon and the mod lona end condoms ex bertbY Weed re bY the WM.,' and ...Pod le, in.telt eee la:, aSelir. SHIPPER: CAMECO RESOURCES CARRIER: GREENFIELD LOGISTICS ...------ PER SI\ -)4 (.41/Att•-• PER DATE 411.3 102.0 DAT ZOri) Rev 6 -January 6, 2020 Page 1 of 1 WYO-RPP-FORM-031 Bin of Lading Cameco Controled Elevation used (Cell 3) BOL # Area 5612.6 2020-SEL-002 Elevation Transit Shot Initial shot for trench 1.48 Top of trench 5606.48 7.6 Bottom of trench 5600.18 13.9 Initial shot used for material 1.48 Top of material in trench 5605.32 8.76 Top of cell 3 Liner 5608.5 Feet below liner 3.18 Energy Fuels Resources (USA) Corp. White Mesa Mill 6425 S. Highway 191 Blanding UT 84511 Transaction No. 55292 Date Time Scale In: 04/24/2020 08:20 1 Out: 04/24/2020 09:00 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 Comments: CONTAINER# GFLU001041 Operator: 4 Charge by Weight Gross: 64520 lb (M) Tare: 43980 lb Net: 20540 lb Signature: 1 No.: PBL-10 Rev. No.: R-3.4 Date: February 1, 2018 ENERGY FUELS RESOURCES (USA) INC. STANDARD OPERATING PROCEDURES Title: lle.(2) Byproduct Disposal I Page 11 of 13 ATTACHMENT 2 Ilea) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM Date: 412T1 ZO Name of employee receiving the load: PA eg_rtc:1-04-5 Generator of the Byproduct Material: f" - Shipper's Manifest or Bill of Lading number: -0.0 2_0 E a Was the State of Utah given notice to the receipt/disposal activities associated with this load No Who gave and when was the notification giv ? t t Z Description of byproduct material disposal area/activities: FIas 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? A/A- Which tailings cell was the material placed in? Was the material placed on a tailings beach area of the cell or on an area of the cell that was underlain by tailings sands? . Was the material segegated from any Mill material or equipment disposed of in the cell? Was the material segregated from byproduct material from other ISL sources disposed of in the cell? e No.: PBL-10 Rev. No.: R-3.4 Date: February I , 2018 ENERGY FUELS RESOURCES (USA) INC. STANDARD OPERATING PROCEDURES Title: 1 le.(2) Byproduct Disposal Page 12 of 13 Manifest or BOL #: Z 2 o - S —003 Have the thickness and placement measurements been verified and documented for the disposal area by the engineer, specifically: Engineer's or Environmental Coordinator's Initials Was the material placed in a cell approved by the executive Secretary for ISL waste disposal? fif riT _p_Q9..tation9_f_g_pF2_v_athzuaes_.69_Afen Was the ISL material segregated from disposed Mill material and other ISL material? 1' el itefe_1101111191111Lit2....C.011.2 2.1.1A0enfinn .e L.% Was the maximum lift thickness above tailings less than 4 feet thick? Ye_f Air Was the maximum lift thickness of subsequent lifts less than 2 feet thick? Yrs it Has 4 foot of tailings sands been maintained under each disposal area? Ye 0." • e 1.2.s_t_r to drawings _us nfinn CS, 3 C.,..4r.0-0., Is the bottom of each disposal area at least 1 2 feet from the sides or dikes of the tailings cell? Yes l_q_fer to drawings useIcLq.(._..m_._.c.Le._2_._CLqj?...g_rztzz4tfinn :0 Will the elevation of the material exceed the plane or grade of the elevation of the uppermost flexible membrane liner of the cell? .44. OP How was this confirmed (e.g., survey or review) 6tvus 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? At- S.".t. c i c À.;Aft) f CML I - L. 6. t 4 g ve-- Were void spaces filled with tailings? Was the shipment properly covered? c•Ja r No.: PBL-10 Rev. No.: R-3.4 Date: February 1, 2018 ENERGY FUELS RESOURCES (USA) INC. STANDARD OPERATING PROCEDURES Title: 11 e.(2) Byproduct Disposal Page 13 of 13 Manifest or BOL #: > ao Are additional settlement monitors required to be placed for this generator? A/ A- If required, where were the settletnent markers placed? ,44 Radiological receipt survey measuremeqtt‘r_ 1) -0 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 r No STRAIGHT BILL OF LADING ORIGINAL—NOT NEGOTIABLE Shipper No. 2020-SEL- Carrier No. NA GREENFIELD LOGISTICS Date 447 Izo (NAME OF CARRIER) (SCAC) Time Collected on Deliveiy sripments, the letters COD must appear before consignee's name or as otherwise provided in item 430, Sec. 1. 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 (905) 885-8145 Mr. John Zaidan; Contractual Agreement with Quantum Murray Route: See Attached Vehicle. Number N/A No.of units & container type HM Basic Description Proper Shipping Name, 1Deard Class,ideetincation Number (IJM or NA), Packing group, per In 101, 172 202, 172 203 Total Quantity (Weight, Volume, Gallons, ote) Weight (gabjecuo Correction) Rate Charges (iiM Carom Uso Only) 1 Roll Off _ A UN2912, RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY (LSA-1), CLASS 7 9.9m3 (I3yd3) RADIONUCLIDE: NATURAL URANIUM, THORIUM-230, RADIUM-226 AND LEAD-210 PHYSICAL FORM: SOLID CHEMICAL FORM: IRON OXIDE TOTAL ACTIVITY: i'4.95E8 Bq (0 013 Ci) 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 DO NOT LOAD OTHER FREIGHT IN THIS VEHICLE, TRANSFER EN ROUTE, OR BREAK SEAL PLACARDS TENDERED: YES: X NO: ADDRESS N/A Note-(1) Where the rate is dependent on value, shippers arc required to stale specifically on writing the agreed or declared value of tle property, as follow The agreed or &dared value of thc prOpcity N hereby specifically stated ty the shipper to be not exceeding per I hereby deciam that Mc contents of this conugnmera ate fully and accurately described above t0 the proper shipping name and are classified, packaged, marked, and labelod//placard, and are in all iespects in proper condition tbr transport according to appficable international and COD Ann, S N/A C.0.13 FEE) VA PREPAID o COLLECT (2) Where the applicable tariff atavism= specify a limillhon of the carrier's liability national governmental regulations. o absent a IOWA an a value declaration by the shipper and the appear does not release the carrier's liability or declare a value, the carrier's habliny shall be limited us the went provided by such proms:ions, So WEL item 172. to ion of lag Candi was it riars Tar'''. baraeti t shipment i to be deflected to the consignee s without recourse on the consignor, the musignor CHARG"' N/A (3) ComMOdifieS sugaring wend or additional targ ar allontion an handling or stowing ailust be so marked and packaged as ro ersvat safe transportation. See Section 2(c) ahem 360, Bills of Lading, NM= Bills, and Statements of Charges ON BEHALF OF SHIPPER n 4111/ 6A-454 hall sign tlic following statement The carrier atoll tat make delivery of llus Moment without payment of freight and all other lawIlit FREIGHT CHARGES FREIGHT PREPAID and Section 1(a) of the Contract terms and condiuons for a list of such articles Signature charges. N/A except Check box if charges igenaaaeofeennimql alien tem rk 1.1nbrr edt RECEIVED, subject to de ebastlicatame and tarifa in ellest ea Ultima ofonen oldie NI ad Lading, the property desenbed ob.+, III +poemo good order, =root es nand Komar and minim. orient.. at Ranee mammal mind consigned mad doodled as indicated above wh ch reid carrier (the weed ...jar hake andemood ththettheathhta ooternet n. nthemen any wean et nerponatine re passel... of this ptopody alder the =Arad) eve.. entry to th, ...et pthee arddlYny al and deettatthan, don es ,oeta, nth... to &Over to another comer on the name to aatd damnation it is nethelly owed a. to each vow of all or any d sold property over ali or en, porton demi route to dalmatian and et touch party at any time inthretth.al in all to any nod Fopefty, that every orrice to be perfooned hereunder shell be subject to all the hill of Wog bYrna end condemn in the inverting chastlicatmn on the date of the sh,pthent Shipper hntebynedifies that he is Alniallf urth all the lading throw and cantlitgthe in the governing eta...Pence and the mid tents, and eentdeoms tet Ithreby arced to by the stopper end accepted tat Iivm au if and hie amine, SHIPPER: CAMECO RESOURCES CARRIER: GREENFIELD LOGISTICS PER PER DATE .1 DATE 04n.,-7.17670 \\6„.../...4.1—" —1dt Rev 6 - January 6, 2020 Page 1 of 1 WYO-RPP-FORM-031 Bill of Lading Ca meat Controled Elevation used (Cell 3) BOL # Area 5612.6 2020-SEL-003 Elevation Transit Shot Initial shot for trench 1.48 Top of trench 5606.48 7.6 Bottom of trench 5600.18 13.9 Initial shot used for material 1.48 Top of material in trench 5605.32 8.76 Top of cell 3 Liner 5608.5 Feet below liner 3.18 Energy Fuels Resources (USA) Corp. White Mesa Mill Transaction No. 6425 S. Highway 191 55302 Blanding UT 84511 Date Time Scale In: 04/28/2020 08:21 1 Out: 04/28/2020 09:03 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 Gross: Tare: Net: 65160 lb (M) 44060 lb 21100 lb Comments: CONT#GFLU001156 o Operator: 4 Ch ge by Weight Signature: I No.: PBL-10 Rev. No.: R-3.4 Date: February 1, 2018 ENERGY FUELS RESOURCES (USA) INC. STANDARD OPERATING PROCEDURES Title: 11 e.(2) Byproduct Disposal I Page I l of 13 ATTACHMENT 2 flea) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM Date: 912.912t) Name of employee receiving the load: 14„..-K, L 04-1- A,— Generator of the Byproduct Material: 0-04 e-c, 0 S ; 4-1"- fa Shipper's Manifest or Bill of Lading number: 20 C- PP — Li Was the State of Utah given notice to the receipt/disposal activities associated with this load No or Who gave and when was the notification.giveq? Z-t/2 0 Description of byproduct material disposal area/activities: c`i FE".4.40 a-AA Has each drum been inspected to identify the presence of any void spaces? Have all drums With void spaCes been filld With"tailings sands or soil? Which tailings cell was the material placed in? Ge..1 1 _3 Am- 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 Lomsç re,A-f f L-5,1" 1.4-,C.s CAtot...+P. Was the material segregated from any Mill material or equipment disposed of in the cell? ycs Was the material segregated from byproduct material from other ISL sources disposed of in the cell? No.: PBL-10 Rev. No.: R-3.4 Date: February 1, 2018 ENERGY FUELS RESOURCES (USA) INC. STANDARD OPERATING PROCEDURES Title: 11e.(2) Byproduct Disposal Page 12 of 13 Manifest or BOL #: 2.0 0 4 Have the thickness and placement measurements been verified and documented for the disposal area by the engineer, specifically: Engineer's or Environmental Coordinator' s Initials Was the material placed in a cell approved by the executive Secretary for ISL waste disposal? yei g? Documentation of ajw_r_oval 1.,k,gove 0. tir/O,Y7f Was the ISL material segyegated from disposed Mill material and other ISL material? Ye. i ab Refer to plat(s) used to confirm. eet/ 3 lle.e, Av./ ,f,.., Was the maximum lift thickness above tailings less than 4 feet thick? V. 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? y',1 Refer to drawings used to confirm esit I: AR lir. Is the bottom of each disposal area at least 12 feet from the sides or dikes of the tailings cell? Veo Refer to drawings used to confirm. 1-. "tor I Will the elevation of the material exceed the plane or gra e of the elevation of the uppermost flexible membrane liner of the cell? /14 How was this confirmed (e.g., survey or review) 5 g e 1/4)- 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? 1-4)4-5 c- A"-f tAk 17Z-ci Were void spaces filled with tailings? Yc. 5 Was the shipment properly covered? Ye-S v c. A No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC. Rev. No.: R-3.4 STANDARD OPERATING PROCEDURES Page 13 of 13 Date: February 1, Title: I1e.(2) Byproduct Disposal 2018 Manifest or BOL #: Are additional settlement monitors required to be placed for this generator? If required, where were the settlement markers placed? Radiological receipt survey measurements: 0 4A,42_ 1 kr- 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 STRAIGHT BILL, OF LADING ORIGINAL--NOT NEGOTIABLE Shipper No. 2020-CPP- Carrier No. NA Date 446 Time GREENFIELD LOGISTICS (NAME OF CARRIER) (SCAC) Collected on Delivery shipments, tge letters CO5 must appear befOie consignee's 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 Slate: WY Zip Code: 82633 24 hr Emergency Contact Tel. No- 1 (905) 885-8745 Mr, John Zaidan; Contractual Agreement with Quantum Murray Route: See Attached Vehicle: Number N/A No.of units & container type HM Basic Description Proper Shipping Name, Hazard CleSAIdentification Number (UM or NA), Packing group, per 172 101, 172 202, 172.203 Total Quantity tWerght, Volume, Gallons, etc ) Weight Cs„*„,. Correction) Rate Charges (FOT Carrier Use Only) 1 Roll Off .„,.. A UN2912, RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY (LSA-1), CLASS 7 15.Im3 (19.76yd3) RADIONUCLIDE: NATURAL URANIUM, THORIUM-230, RAD1UM-226 AND LEAD-210 fr. PHYSICAL FORM: SOLID CHEMICAL FORM: UNAT WITH DAUGHTERS TOTAL ACTIVITY: 9.99E7 Bq (0 003 Ci) c....0<e1 -2,,b, 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 (.1 .36 DO NOT LOAD OTHER FREIGHT IN THIS VEHICLE, TRANSFER EN ROUTE, OR I3REAK SEAL PLACARDS TENDERED: YES: X NO: ADDRESS N/A Notim(l) Where the rate is dependent on value, shippers arc required to nate apecy fiwity.m.", on awned ,,.. d,,,g,,,,,,,t ,,,,t0, a ate pieperiy, Ili wee, The agreed or declared value Mau property is hereby specifically stmed by the simmer to bc not exceeding Per I hereby declare that ale contents of this consignment are flinY and accurately described abate bY lbe ProPer shipplog mime and arc classified, paCkaged, muted, anti labciedfiplacard, end ate in all respects in prom condition for transom according to applicable international end COD Ana S N/A C 0 D FEE. NIA PREPAID e COLLECT - (2) Whore the applicable tariffprovisions speary a limitation of the carrier's liability national governmental togelatilms o Anent a rekese or a value declaration by the shipper end the shipper does not release th carri e er's liability or declare a value, the carner's liabihly shall be honied to th e extent provided b) such provisions. See NMFL nem 172. "Subleclu, uaTa, , of tte conditions it this t shipment is to be activated o theconsignee without tecourse on the consignor, the conugnor TOTAL CIIARGES N/A (3) Commodities requiring speual or additional care or attention in handling or num ng must be so marked and packaged as to ensure safe transportation Scc Sectron 2(c) dams 360, Bills of Lading, Freight Bills, and Statements of Charges ON BEHALF OF SHIPPER VA-2..? e 4.4- shall sign the following statement The Dana shall not make delivery dads shipment without payment of freight and all other lawfia FREIGHT CHARGES FREIGHT PREPAID end Section I (a) of the Contract terms and conditions for a hst Mauch articles Signature charges. --.—Nat--- except Check bav if charges ioletw of Cgingiggori lag, tow 0 he ',ad RECEIVED, Masa to the elartinermanc end wmrs le Apo per the drne of.. on. Bill of Loran. the pro.. described above in apparent good order, =apt ar awed lconients and coediton dean.oa ape..a, eatoopert, naked, ...good, oad destined a. Mi.. chow winch tied cannerdt, word a...W. ‘,„,,,,,,,,,,41„.....bo.dps,,,,,,,,,,,,,,,,,,,,n,„4„,,,,,,,,nppc, in pp..... of thin proper., end.. dt. ono..? co....cy to ....I Finsc of dclrocry a sa4 destination if. id rOele, ...se . deliver te onother alma on die rot. to said dome.. It in inalually agreed .. to es. maw of all or anyee, ertd property ow all or eny )141111011 of add none to ...eon and an tom. party pinny inne interested III all or any odd property, thal very servrto ir, he performed hereander shalt le mesa to el Me bill ortadmo wrestled madames in the noverning chorine.. en the date of el* clime*, Shipper hereby, certifies thal be a familiar with all ihe Wien term mid condi.. in the...on classiticohon and the cud lann and .1111113.• aye h rnby speed at by ihe rhirp...i..e,ea eikaiee.i ,..i ... SHIPPER: CAMECO RESOURCES CARRIE • GREENFIELD LOGISTICS PER ,. ''.724,,, e r- PER DATE d):/ii‘-'6 9724/ DA eni2ct I ZIP Rev 6 -January 6, 2020 Page 1 of 1 WYO-RPP-FORM-031. Bill of Lading Energy Fuels Resources (USA) Corp. White Mesa Mill Transaction No. 6425 S. Highway 191 55313 Blanding UT 84511 Date Time scale In: 04/30/2020 12:22 1 Out: 04/30/2020 12:47 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 Gross: Tare: Net: 51740 lb (M) 44380 lb 7360 lb Comments: CONTAILER GFLU 1235 Operator: 4 arg by Weight Signature: Ca meco Controled Elevation used (Cell 3) BOL # Area 5612.6 2020-CPP-004 Elevation Transit Shot Initial shot for trench 1.48 Top of trench 5606.48 7.6 Bottom of trench 5600.18 13.9 Initial shot used for material 1.48 Top of material in trench 5605.32 8.76 Top of cell 3 Liner 5608.5 Feet below liner 3.18