DRC-2019-008741 - 0901a06880adc2fe

, ,.: A -.-
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 D - 2019 -00374-1
MEMORANDUM
TO: Project File C-2019-39
772-2-AZ 1 THROUGH: Phil Goble, Uranium Mill Section Manager pP 6
FROM: Heather Mickelson, PE, PG It7Thiejayq,,_)
DATE: July 22, 2019
SUBJECT: July 18, 2019 Inspection of disposal of lle.(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 8, Condition 10.5: "In ac.cordance 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 9,1
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
1 This defmition amends the language given in Section 1le.(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
defmition. 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
processes.
Third Quarter 2019 ISL Decommissioning Debris Disposal Inspection Report
July 22, 2019
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 one (1) load of
lle.(2) byproduct material on July 18, 2019 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 July 10, 2019.
Operating Procedures and Records
This inspection was specific to the Licensee's implementation of Standard Operating Procedure SOP
PBL-10, which governs disposal of lle.(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. In addition to inspecting/observing the
July 18th disposal, records for the materials received on June 7, 2019 (Smith-Ranch Cameco), June 17,
2019 (Mestena/Alta Mesa), and June 19, 2019 (Strata Energy) were reviewed to verify their
completeness. 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 1le.(2) byproduct material generator.
11e.(2) Byproduct Material Disposal Activities and Description
Prior to July 18, 2019, the disposal pit location were determined, located by survey, and excavated. The
bottom of the excavation extended into the tailings sand. The lle.(2) byproduct material was placed
near the burial pits and processed for burial (Photo 1).
During the July 18, 2019 inspection, the Division observed the final disposal activities. Prior to
placement, the excavation depth was surveyed (Photo 2). Once the lle.(2) byproduct material was in
the excavation, the top of the material was surveyed. Clean cover was then placed over the lle.(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.
One (1) load of 1le.(2) byproduct material was from Mestena/Alta Mesa, which is located near Encino,
Texas. The material from this load consisted of sediment and black plastic (Photo 1).
Close Out Meeting
A close out meeting to discuss observations during the inspection included Heather Mickelson, Phil
Goble, Tanner Holiday, Terry Slade (Site Radiation Safety Officer), and Dean Lyman.
Third Quarter 2019 ISL Decommissioning Debris Disposal Inspection Report
July 22, 2019
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. Only sediment and black plastic were included in this
load and it compacted easily with the wheel loader.
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 11e.(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."
Third Quarter 2019 ISL Decommissioning Debris Disposal Inspection Report
July 22, 2019
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 subthit 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 1le.(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 July
10, 2019, which is greater than 7 days in advance of burial that occurred on July 18, 2019. 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 lle.(2) byproduct material generated as decommissioning debris
from ISL uranium recovery facilities.
Attachments: 11e.(2) Byproduct Receipt Notification dated July 5, 2019
Document packet for Mestena/Alta Mesa 1le.(2) byproduct material bearing Bill of Lading # 174
Photo 1. Mestena/Alta Mesa lle.(2) byproduc material to be buried. Photo taken on Photo 2. EFR measuring the top elevation of the Mestena/Alta Mesa buried 1le.(2)
July 18, 2019. byproduct material. Photo taken on July 18, 2019.
Photo 3. Compacting the Mestena/Alta Mesa 1le.(2) byproduct material and clean Photo 4. Final cover of the compacted clean cover over the buried Mestena/Alta Mesa
cover. Photo taken on July 18, 2019.. 1le.(2) byproduct material. Photo taken on July 18, 2019.
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
DRC-2019-006562_
July 5, 2019
VIA Electronic Mail (PDF) and UPS
Mr. Ty Howard
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
Div of Management
and Rad.ation Control
JUL 10 2019
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 additional loads by July 18th, 2019.
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: Februazy 1,
2018
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 11 of 13

ATTACHMENT 2
flea) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date: 7 I s'h
Name of employee receiving the load:
6•L_rr, I
Generator of the Byproduct Material: /4 (.4
Shipper's Manifest or Bill of Lading number: I 7 Li
Was the State of Utah given nStisaki.thorooedispbsaefivities associated with this load? Yes or
No
Who gave and when was the notification given?
1_,511
Description of byproduct material disposal area/activities:
Se- c_ f 1,i e
Has each drum been inspected to identify the presence of any void spaces? Am_
Have all drums with void spaces been filled with tailings sands or soil? NA-
Which tailings cell was the material placed in? 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?
4-14, CA-)
Was the material segregated from any Mill matenal or equipment disposed of in the cell?
Yc. 3
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: 1 le.(2) Bypioduct Disposal Page 12 of 13

Manifest or BOL #: LI,
Have the thickness and placement measurements been verified and documcnted 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? tfic
Documentatio nt_g_i_m_fval e j tir go hos.
Was the ISL material segregated from disposed Mill material and other
ISL material? Yei
Refer to I s used to cp_g_l
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? Ye $
Has 4 foot of tailings sands been maintained under each disposal
area? re5
Refer to drawings used to confirm C. 3 e.t.d. Dew •.-.`e
Is the bottom of each disposal area at least 12 feet from e sides or
dikes of the tailings cell? )/t j
Refer to drawings used to confirin. c, // 3 c.o.d. Oft-. •U
Will the elevation of the material exceed the plane or grade of the
elevation of the uppermost flexible membrane liner of the cell?
/14
0 How was this confirmed (e. g., survey or review)
.cti elohtly
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 r- Lti le, t c_iyi 1 'El/A•CS
Were void spaces filled with tailings?
VI 8
Was the shipmait properly covered?
YtS ft c ,

No.: PBL-10
Rev. No.: R-3.4
Date: February 1,
2018
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 e.(2) Byproduct Disposal Page 13 of 13

Manifest or BOL #: 1 -7 Li
Are additional settlement monitors required to be placed for this generator?
AiA
If required, where were the settlement markers placed?
Radiological receipt survey measurements: 0 - 0
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 die unloading activities? Qr No
Generator of Byproduct material:
Controled Elevation used (Cell 3)
Area
Mestena
5613.04
Elevation Transit Shot
Initial shot for trench 4.2
Top of trench 5609.44 7.8
Bottom of trench 5604.04 13.2
Initial shot used for material 4.2
Top of material in trench 5606.44 10.8
Top of cell 3 Liner 5608.5
Feet below liner 2.06
rig
12c tick AA,,
71 er it/
SHIPMENT ID# 174
BILL OF LADING
ŠH1PMENT DATE: 41.3 /1

SHIPPER (From):
EFR ALTA MESA LLC - v I _
CONSIGNEE (To):
Energy Fuels Resources (USA) Inc.
6425 South Ifighway 191
Blanding, UT 84511
ADDRESS: 755 Co. Rd. 315 Encino, TX 78353
ADDRESS:
P. O. Box 809, Blanding UT 84511
SHIPPER LICENSE NO.: R05360 SHIPPER USDOT NO.: CONSIGNEE UCENSE NO.:
UT- 1900479
CONSIGNEE TELEPHONE NO.: [phone]
SHIPPER LICENSE NO. : SHIPPER TELEPHONE
NO4361-568-3549
CARRIER NAME AND ADDRESS:
Greenfield Logistics, LLC
CARRIER USDOT CARRIER HAZMAT REG. NO.:
Trailer I/ Container/1 GFLU01206 Seal ft 418 Seal if 419
DESCRIPIION OF MATERIAL AND PACKAGING " VOLUME
Cubic feet or QUANTITY
CLASSIFICATION
1 pkg.
lzQ
UN2913, Radioactive Material, Surface Containinated Objects (SCO-1) and soil, non-fissile, , Class 7
Dry 11 (E).2 By-Product material. Natural uranium and daughters.
Activity: 2.0 E6 Bq (5.4 E-5 Ci)
36,000 lbs. (net)
Surface Contaminated Objects
(SCO) waste material and soil
Exclusive use shipment
Placards applied
EMERGENCY CONTACT:
P. Lathiger: 1-361411(t-0158
CERTIFICATION: These is to certify that the above named articles are properly classified, described, packaged, marked and labeled, and are in proper condition for transportation,
according to the applicable regulations of the Department of Transportation.
Shippers Signature: C) Date: i 9
Driver's Signature: Date: 07/0/243(
UNITED STATES OF AMERICA
DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
HAZARDOUS MATERIALS
CER11FICATE OF REGISTRATION
FOR REGISTRATION YEAR(S) 2019-2020
Registrant: EFR ALTA MESA LLC
ATTN: peter luthiger
755 CR 315 ENCINO, TX 78353
This certifies that the registrant is registered with the U.S. Department of Transportation as required by
49 CFR Part 107, Subpart G.
This certificate is issued under the authority of 49 U.S.C. 5108. It is unlawful to alter or falsify this
document.
Reg. No: 061419550207B Effective: July 1, 2019 Expires: June 30, 2020
HM Company ID: 180805
Record Keeping Requirements for the Registration Program
The following rnust be maintained at the principal place of businesifor a period of three years from the
date of issuance of this Certificate of Registration:
(1) A copy of the registation statement filed with PHMSA; and
(2) This Certificate of Registration
Each person subject to the registration tequirement must furnish that person's Certificate of Registration
(or a copy) and all other records and information pertaining to the information contained in the
registration statement to an authorized representative or special agent of the U. S. Department of
Transportation upon request.
Each motor carrier (private or for-hire) and each vessel operator subject to the registration requirement
must keep a copy of the current Certificate of Registration or another document bearing the registration
number identified as the "U.S. DOT Hazmat Reg. No." in each truck and truck tractor or vessel (trailers
and semi-trailers not included) used to transport hazardous materials subject to the registration
requirement. The Certificate of Registration or document bearing the registration number must be made
available, upon request, to enforcement personnel.
For information, contact the Hazardous Materials Registration Manager, PHH-52, Pipeline and
Hazardous Materials Safety Administration, US. Department of Transportation, 1200 New Jersey
Avenue, SE, Washington, DC 20590, telephone [phone].
Energy Fuels Resources (USA) Corp.
White Mesa Mill Transaction No. 6425 S. Highway 191 54389 Blanding UT 84511
Date Time Scale
In: 07/05/2019 10:08 1
Out: 07/05/2019 10:40 1 Vehicle ID: 1002
Trailer ID:
Account ID: MESTENA AL MESTENA ALTA PROJECT
Order ID:
Owner ID:
Material ID: 11(e)2 Mat 11(e)2 Material Receipt
,Destin. ID: BLANDING,
Gross: 77640 lb (M)
Tare: 44900 lb
Net: 32740 lb
Comments: TRL#TR3 BOL#174 BIN#1206
Operator: 4 Charge by Weight
Signature: