DRC-2020-016947 - 0901a06880d50559

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
Diremor
C-2.02r2 -01C7947
MEMORANDUM
TO:
THROUGH:
Project File C-2020-40
Phil Goble, Uranium Mill Section Manager 1/71e. r/47
FROM:
DATE:
Heather Mickelson, PE, PG -R_eget_ (4414,4(jscm_.) \<:=1,12-02.
September 9, 2020
SUBJECT: August 26, 2020 Inspection of the Disposal of 1le.(2) Decommissioning Debris from In
Situ Leach Facilities at the White Mesa Uranium Mill. Radioactive Material License No.
UT 1900479.
Authority
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 I 1 e.(2) of the Atomic Energy Act as amended in 1954 to include 1SL
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
Third Quarter 2020 ISL Decommissioning Debris Disposal Inspection Report
September 9, 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) observed the disposal of three (3) loads of 11 e.(2) byproduct material on August 26, 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 August 11, 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 1 1 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 11e.(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. The current map is attached to this report.
11 e.(2) Byproduct Material Disposal Activities and Description
Prior to August 26, 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 (Photos 1 and 5).
During the August 26, 2020 inspection, the Division observed the final disposal activities. Prior to
placement, the excavation depth was surveyed (Photo 2). Once the 11e.(2) byproduct material was in
the excavation, the top of the material was surveyed (Photos 3 and 7). Clean cover was then placed over
the 11 e.(2) byproduct material and then compacted to further minimize void spaces (Photos 4 and 8).
The vertical extent of the burial was below the top of the tailings and above the bottom liner.
One load of 11 e.(2) byproduct material was from URI Rosita in San Diego, Texas. The material from
this load consisted of pipe and supersacks (Photo 1). Two (2) loads of 11 e.(2) byproduct material was
from URI Kingsville in Kingsville, Texas. The material from these loads consisted of supersacks, filter
and drisco pipes, pumps and trash (Photo 5).
Close Out Meeting
A close out meeting to discuss observations during the inspection included Heather Mickelson, Terry
Slade (Radiation Safety Officer) and Garrin Palmer.
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
Third Quarter 2020 ISL Decommissioning Debris Disposal Inspection Report
September 9, 2020
Page 3
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 not present during this disposal
inspection.
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 1 1 e.(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 1 1 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."
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
Third Quarter 2020 ISL Decommissioning Debris Disposal Inspection Report
September 9, 2020
Page 4
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
August 11, 2020, which is greater than 7 days in advance of burial that occurred on August 26, 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 August 5, 2020
Document packet for URI Rosita 1 le.(2) byproduct material bearing Bill of Lading #20ROS-014
Document packet for URI Kingsville 1 le.(2) byproduct material bearing Bill of Lading #KVD-001
Document packet for URI Kingsville 1le.(2) byproduct material bearing Bill of Lading #KVD-002
Photo 1. URI Rosita 11 e.(2) byproduct material to he buried. Photo taken on August Photo 2. EFR measuring the bottom elevation ot the URI Rostut burled l l c.t
26, 2020. byproduct material. Photo taken on August 26, 2020.
Photo 3. EFR measuring the top elevation of the URI Rosita lle.(2) byproduct Photo 4. Compacting the final cover over the buried URI Rosita 1 le.(2) byproduct
material. Photo taken on August 26, 2020. material. Photo taken on August 26, 2020.
Photo 5. URI Kingville l le(2) byproduct material to he buried. Photo taken on
August 26, 2020.
Photo 7. EFR measuring the top elevation of the URI Kingville 1 le.(2) byproduct
material. Photo taken on August 26, 2020.
Photo 6. EFR placing the I jR I Kingvi Ile 1 l e.(2) byproduct material into the pit. Photo
taken on August 26, 2020.
Photo 8. Compacting the final cover over the buried URI Kingman 1 le.(2) byproduct
material. Photo taken on August 26, 2020.
ENERGYFUELS
Energy Fuels Resources (USA) inc.
6425 South Highway 191, PO Box 809
Blanding, UT. US, 84511
435 678 2221, fax [phone]
www.energyfuels.com
Div of Waste Management and Radiation Control
AUG 1 1 2020
PRC-20/10-013609
August 5, 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: 1le.(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 August 26th, 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,
Garrin 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 le,(2) Byproduct Disposal Page 11 of 13
ATTACHMENT 2
11.e. 2 BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date: S Lc .1 2
Name of employee receiving the load: Pe-r1,;•,,strAA, cd- WA. Ay
Generator of the Byproduct Material: t.;r Ras; +4-
Shipper's Manifest or Bill of Lading number: 20 (2.0S- o 14
Was the State of Utah given notice to the receipt/disposal activities associated with this load? Yes or
No
Who gave and when was the notification given?
2n
Description of byproduct material disposal area/activities:
pz
Has each drtun been inspected to identify the presence of any void spaces?
Have all drums with void spaces been filled with tailings sands or soil?
4-
/VA
Which tailings cell was the material placed in? 4-c-1 .3
Was the material placed on a tailings beach area cf the cell or on an area of the cell that was underlain
by tailings sands?
_14 4,1 t rv"eaft.A. L4.-4
Was the material segregated from any Mill material or equipment disposed of in the cell?
YcJ
Was the material segregated from byproduct material from other 1SL sources disposed of in the cell?
\le.3
No.: PBL-10
Rev. No.: R-3.4
Date: February 1,
2018
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 11e.(2) Byproduct DisposaJ
Page 12 of 13

Manifest or BOL #: 2,02,05 - 014
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 ma erial placed in a cell approved by the execu ive Secretary
for ISL waste disposal? Y
Aiie Documentation of approval hie-e45c ii3O,17f
Was the ISL ma erial segregated from disposed Mill material and other
ISL material? Y,5 .
Refer to p1at() used to confirm. ,f// He. z, A Id Was the maximum lift thickness above tailings less than 4 feet
thick? Yc5.,
Was the maximum lift thickness of subsequent lifts less than 2 feet
thick? re..-i
Has 4 foot of tailings sands been maintained under each disposal
area? re„,-
Refer to drawings used to confirm 7, / t Oevii--,1, 5
Is the bottom of each disposal area at least 1 2 feet from the sides or
dikes of the tailings cell? Yri A' Refer to drawings used to conftnn /I 3 6, . mi.., ,,,
Will the elevation of the material exceed the plane or grade of the
elevation of the uppermost flexible membrane liner of the cell?
How was this 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? •
Were void spaces filled with tailings?
Was the shipment properly covered?
4,3 s
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 13 of 13

Manifest or BOL #: 2oJ1o.5 -o iLí
Are additional settlement monitors required to be placed for this generator?
A-
If required, where were the settlement markers placed?
Radiological receipt survey measurements:
0 .1c., SPIf -0
Breathing Zone:
1. Was a Breathing Zone Sample collected? Yes or
2. If yes, what were the results of the sampling?
Was a photograph taken during the unloading activities. r No
Generator of Byproduct material:
BOL #
Controled Elevation used (Cell 3)
Area
URI Rosita
20110S-014
5613.04
Elevation Transit Shot
Initial shot for trench 2.2
Top of trench 5609.64 5.6
Bottom of trench 5602.44 12.8
Initial shot used for material 2.2
Top of material in trench 5606.82 8.42
Top of cell 3 Liner 5608.5
Feet below liner 1.68
Energy Fuels Resources (USA) Corp.
White Mesa Mill
6425 S. Highway 191
Blanding UT 84511
Transaction No.
55652
Date Time Scale
In: 08/05/2020 09:49 1
Out: 08/05/2020 10:24 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: 52300 lb (M)
Tare: 32920 lb
Net: 19380 lb
Comments: TRL#5
Operator: 4 Charge by Weight
Signature:
STRAIGHT BILL OF LADING FOR BYPRODUCT
MATERIAL URI, INC.
NAME OF CARRIEPR: Cosby Trucking
RM License No. R03653 Shipment No. 20ROS-014 Trailer #
Date: 8/3/2020 Seal # n/a
DRIVER:
SHIPPER (from) URI:pc.
STREET 3021 CR 333
cm San Diego ' STATE Texas ZIP 78384
COUNTRY USA - PHONE [phone]
COSIGNEE (to) Energy Fuels- White Mesa Mill _
DESTINA71ON STREET 6425 S. Hwy 191 . .
ant Blanding STATE UT ZIP 84511
COUNTRY U.S.A. PHONE [phone]
' CONTENTS
EXCLUSIVE USE SHIPMENT :
***These contents are contaminated with
IDENTIFICATION NUMBER: UN 2912
natural uranium aria its daughters 226Fia and 230Tli ***
MATERIAL. low specific activity (LSA-I). PROPER SHIPPING NAME: RADIOACTIVE
HAZARD CLASS: 7 FORM: Solid Oxide ACTIVITY: 0.0008 TBct
SPECIAL INSTRUCTIONS: Do not remove contents without authorization
WEIGHT: Tare lbs. NET lbs. GROSS 53. inet lbs„ VOLUME: 25 vd3
INNIIIIIIIIIIIMINIMIIIIIIMIS EMERGENCY CONTACTS 24 HOUR
CHEMTREC: 800-424-9300 password: URI
URI DISTRICT: 361-331-5585 (Joshua Holland)
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 PACKAG MPLIANCE WITH 49 CFR 173.427 (c) •. Shippees Signature Date-813/2020
CARRIER's CERTIFICATION
Carrier 1 ledges rect of packagl nct required placards. Carrier certifies emergency response igformatiori was made av 1 . s the appr mer e ohm document in the vehicle. Department of Tramnortation. Car er S • natur ee Date Received Date Relinquished
Carr gnature 2 Date Received Date RAlinquished
Carrier Signature 3 Date Received Date Ret.
.. : 1---- CONSIGNEE's RECIEPT of SHIPMENT
Cosignee's Signature
......."A.,.....-------'
Datel .
11-41
1
No.: PEL-10
Rev. No.: R-3.4
Date: February 1,
I 2018
ENERGY FUELS RESOURCES (USA) INC. STANDARD OPERATING PROCEDURES
Title: 1 le,(2) Byproduct Disposal
ATTACHMENT 2
11e42) BYPRODUCT MATERIAL DISPOSAL DOCUMEN'TATIONPORIVI
Date: SfiZ/26
Name of employee receiving the load: i p„
Generator of the Byproduct Material:
Shipper's Manifest or Bill of Lading number: ZD v l - c>
Was the State of Utah given notice to the receipt/disposal activities associated with this load?
No
Who gave and when was the notificatio given?
2 6,
Description of byproduct material disposal area/activities:
r./ ek-I-5cfd ìØ PA,
Has each drum been inspected to identify the presence of any void spaces?
Have all drums with void spaces been filldd with tailings sands or soil? AO-
Which tailings cell was the material placed in? (_ct i 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?
Alt f 0. IL 1 lAr
Was the material segregated from any Mill material or equipment disposed of in the cell?
YeJ
Was the material segregated from byproduct material from other ISL sources disposed of in the cell?
No.: PBL-1 0
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 #: Z0 IC v - 001
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? Ks
Documentation of approval 2&e,/ itr / ti, 7
Was the ISL material segregated from disposed Mill material and other
ISL material? Yej
Refer to la s used to confirm. e 1/ 3 4 (lb" Was the maximum lift thickness above tailings less than 4 feet
thick? Ye / ,
Was the maximum lift thickness of subsequent lifts less than 2 feet
thick? fril
Has 4 foot of tailings sands been maintained under each disposal
area? ref
Refer to drawings used to confirm nit 3
Is the bottom of each disposal area at least 1 2 feet from Te sides or
dikes of the tailings cell?
Refer to drawin s used to confirm. II 3 ni. 0•1-,,
Will the elevation of the material exceed the plane or grade of the
elevation of the uppermost flexible membrane liner of the cell?
4/0
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? tQp_irt!-f-- 4 ••1,-.4.4
Were void spaces filled with tailings?
Was the shipment properly covered?
k •
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
Manifest or BOL #: -Oa!
Are additional settlement monitors required to he placed for this generator? NA-
If required, where were the settlement markers placed?
Radiological receipt survey measurements:
Breathing Zone:
1. Was a Breathing Zone Sample collected? Yes or
2. If yes, what were the results of the sampling?
Was a photograph taken during the unloading activities?/Yešor No
STRAIGHT BILL OF LADING FOR BYPRODUCT
MATERIAL URI, INC.
RM License No. R03653 Shipment No. 20KVD-001
Date: 8/10/2020
Trailer #
Seal # n/a
NAME OF CARRIER:Cosby Trucking DRIVER:
SHIPPER (from) URI, Inc.
STREET 641 E. FM 1118
crry Kingsville STATE Texas ZIP 78363
COUNTRY USA PHONE [phone]
COSIGNEE (to) Energy Fuels- White Mesa Mill
DESTINATION STREET 6425 S. Hwy 191
crry Blanding STATE UT ZIP 84511
COUNTRY U.S.A. PHONE [phone]
CONTENTS
EXCLUSIVE USE SHIPMENT
***These contents are contaminated with natural uranium and its daughters 2261:ta and 230Th ***
IDENTIFICATION NUMBER: UN 2912
PROPER SHIPPING NAME: RADIOACTIVE MATERIAL, low specific activitv (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 lbs.
EMERGENCY CONTACTS 24 HOUR
CHEMTREC: 800-424-9300 password: URI
URI DISTRICT: 361-331-5585 (Joshua Holland)
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 PACKAGE IN COMP IANCE WITH 49 CFR 173.427-(c) Shipper's Signature r Date
8 4 a CARRIER's CERTIFICATION
Carrier acknowledges re t of packages and required placards. Carrier certifies emergency response information was made available and has t pp op iate em e cy resp se document in the vehicle. Department of Transportation. Carrier Signature e -- Date Received
8 0 4520
Date Relinquished
Carrier Signature 2 ate eceived Date Relinquished
Carrier Signature 3 Date Received Date Relinquished
CONSIGNEE's RECIEPT of SHIPMENT Cosig ee's Signature Date
Energy Fuels Resources (USA) Corp.
White Mesa Mill
6425 S. Highway 191
Blanding UT 84511
** Reprinted by 4 at 08/12/20 08:02:05 **
Transaction No.
55673
Date Time Scale
In: 08/12/2020 07:29 1
Out: 08/12/2020 08:00 1
Vehicle ID: 815 COSBY TRUCKING
Trailer ID: Gross: 56540 lb (M)
Account ID: UR1-KVD URI-KINGSVILLE DOME Tare: 32900 lb
Order ID: Net: 23640 lb
Owner ID:
Material ID: 11(e)2 Mat 11(e)2 Material Receipt
Destin. ID: BLANDING
Comments: TRL45 BOL#20KVD-001
Operator: 4 Charge by Weight
Signature:
Controled Elevation used (Cell 3)
BOL #
Area
5613.04
20KVD-001/20KVD-002
Elevation Transit Shot
Initial shot for trench 5.7
Top of trench 5608.54 10.2
Bottom of trench 5604.26 14.48
Initial shot used for material 5.7
Top of material in trench 5606.94 11.8
Top of cell 3 Liner 5608.5
Feet below liner 1.56
No.: PBL-10
Rev. No.: R-3.4
I Date: February 1,
2018
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 1 c.(2) Byproduct Disposal
—1 Page 11 of 13

ATTACHMENT 2
ilea) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date: Witt/ 20
Narne of employee receiving the load: p
L-••••
Generator of the Bypiuduct Material: _Li IZÏ tic
Shipper's Manifest or Bill of Lading number: z r.:Al foo
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?
ff]jJ 7L.
Description of byproduct material disposal area/activities:
4-4e,
Has each drum been inspected to identify the presence of any void spaces?
Have all dnuns with void spaces been filled with tailings sands or soil?
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?
A0.4. Fj... e A- eh, ilLA-1,1 4.'" L4)&4 Ay
Was the material segregated from any Mill material or equipment disposed of in the cell?
yc
Was the material segregated from byproduct material from other ISL sources disposed of in the cell?
Yr-)
I No.: PIIL-10
Rev. No.: R-3.4
Date: February 1,
2018
ENERGY FUELS RESOURCES (USA) INC,
STANDARD OPERATING PROCEDURES
Title: ile.(2) Byproduct Disposal
Page 12 of 13
N
Manifest or BOL #: 00 IGAID —00
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 ce I approved by the executive Secretary
for 1SL waste disposal? 1,/t4 Documentation of 9proval 4.- .4 If r/fÐP,./1
Was the ISL material segregated from disposed Mill material and other
ISL material? li es _ ,a7 Refer to at s used to confirm. Cc/ c.Z, .0,, 'Ps/ 4reo
Was the maximum lift thickness above tailings less than 4 feet
.,...ticicLis.i..._ Was the maximum lift thickness of subsequent lifts less than 2 feet
thick? yr 5- _
Has 4 foot of tailings sands been maintained under each disposal
area? )4,5
Refer to drawings used to confirm_ Ge /f 5 e.....4 Pr.—, if'5
Is the bottom of each disposal area at least 12 feet from the sides or
dikes of the tailings cell? Ye 5
Refer to drawings used to confirm. ./ 3 net. .0"4.--,:,
Will the elevation of the material exceed the plane or gra e of the
elevation of the uppermost flexible membrane liner of the cell?
Ale
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?
Ar t. t, t4,1;04 4. CP f).‘Cf c Lok-3 _.-.0A. 4.. 1,0 )3,-- t L A [ 4 f ,t."4.:_c ei- 1:Vi, .
Were void spaces filled with tailings?
Ye,_)
Was the shipment properly covered?
VC.

ENERGY FUELS RESOURa ES (USA) INC. STANDARD OPERATING PROCEDURES
Title: 11e.(2) Byproduct Disposal

No.: PBL-10
Rev. No.: R-3.4
I
Date: February 1, 2018
Page 13 of 13

Manifest or BOL #: Zo 14.v- -o c),Z.
Are additional settlement monitors required to be placed for this generator?
If required, where were the settlement markers placed?
iv A
Radiological receipt survey measurements:
.¡S r .4iZ/h.r I -
Breathing Zone:
1. Was a Breathing Zone Sample collected? Yes or&
2. If yes, what were the results of the sampling?
Was a photograph taken during the unloading activities. No
Controled Elevation used (Cell 3)
BOL #
Area
5613.04
20KVD-001/20KVD-002
Elevation Transit Shot
Initial shot for trench 5.7
Top of trench 5608.54 10.2
Bottom of trench 5604.26 14.48
Initial shot used for material 5.7
Top of material in trench 5606.94 11.8
Top of cell 3 Liner 5608.5
Feet below liner 1.56
Energy Fuels Resources (USA) Corp.
White Mesa Mill Transaction Np. 6425 S. Highway 191 55697 Blanding UT 84511
In:
Out:
Date Time Scale
0.
08/19/2020 08:08 1
Vehicle ID: 815 .COSBY TRUCKING ** Manual Weight **
Trailer ID: Gross: 52160 lb (K)
Account ID: URI7JM. URI-KINGSVILLE DOM.g.„. Tare: 328P24..ab (K)
Order ID: Net: 19280 lb
Owner ID:
Material ID: 11(e)2 Mat 11(e)2 Material Receipt
Destin. ID: BLANDING
•••••af.% te-211Seg
Comments: TRL#5 BOL#20KVD-02
Operator: 4 Chaive by Weight

Signature:

URI, INC. STRAIGHT BILL OF LADING FOR BYPRODUCT
MATERIAL
RM License No. R03653 Shipment No. 20KVD-002 Trailer #
Date: 8/17/2020 Seal # n/a
NAME OF CARRIER: Cosby Trucking
SHIPPER (from) URI, Inc.
STREET 641 E. FM 1118
crry Kingsville STATE Texas _ zip 78363
COUNTRY USA PHONE [phone]
COSIGNEE (to) Energy Fuels- White Mesa Mill
DESTINATION STREET 6425 S. Hwy 191
crry Blanding STATE UT ZIP 84511
COUNTRY U.S.A. PHONE [phone]
CONTENTS
EXCLUSIVE USE SHIPMENT
***These contents are contaminated with natural uranium and its daughters 226Ra and 233Th ***
IDENTIFICATION NUMBER: UN 2912
PROPER SHIPPING NAME: RADIOACTIVE MATERIAL. low specific activity (LSA-I).
HAZARD CLASS: 7 FORM: Solid
SPECIAL INSTRUCTIONS: Do not remove
Oxide ACTIVITY: 0.0008 TBq
contents without authorization
WEIGHT: Tare lbs. NET lbs. GROSS lbs.
VOLUME: 25 vd3
EMERGENCY CONTACTS 24 HOUR
CHEMTREC: 800-424-9300 password: URI
URI DISTRICT: 361-331-5585 (Joshua Holland)
SHIPPER's CERTIFICATION
This is to certify that the above maierials 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 PACKAGE IN COMP IANCE WITH 49 CFR 173.427 (c)
Shipper's Signature Date
CARRIER's CERTIFICATION
Carrier acknowledges receipt •of packages and required placards. Carrier certifies ernergency response information was made
avail* d has the a •roptite en2ergericy response document in the vehicle. De artment of Trans ortation.
Carrier Signe ure 1 Date Received
/ -, 40..4.4..
Date Relinquished
Carn ignature 2 Date Received Date Relinquished
Carrier Signature 3 Date Received Date Relinquished
CONSIGNEE's RECIEPT of SHIPMENT
Cosnee's Signature i Date / < glist/ZO