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HomeMy WebLinkAboutDRC-2013-003019 - 0901a068803b27b9IcJI tVBa. JLH;. SBSA \*\S '^4 IMS** State of Utah GARY R HERBERT Governor GREG BELL Lieutenant Governor Department of Environmental Quality Amanda Smith Executive Director DIVISION OF RADIATION CONTROL Rusty Lundberg Director "DRC-2013-003019" MEMORANDUM TO: THROUGH: FROM: DATE: SUBJECT: FileC-2013-61 Phil Goble, Section Manager Russell J. Topham, P.E. August 9,2013 pat? syw/ze^ Engineering Module 73. Inspection of Disposal of Bulk Byproduct Material August 2, 2013. Radioactive Materials License UT1900479 (License) - Energy Fuels Resources (USA) Inc. (EFR) White Mesa Mill, Blanding, Utah On August 2 2013,1 performed an inspection of in-situ leach (ISL) waste disposal operations at the White Mesa uranium mill on behalf of the Utah Division of Radiation Control (DRC). This inspection responds to a 1 le.(2) Byproduct Receipt Notification from EFR, dated July 17, 2013. EFR is allowed to dispose this byproduct material in Tailings Cell 3 only, which is allowed by License Condition 10.5 of the EFR Radioactive Materials License. On July 17, 2013 DRC received notice that EFR would receive thirteen loads of 1 le.(2) byproduct material, and intended to dispose of that waste in Cell 3 on August 2, 2013. Seven loads were ultimately received prior to the commencement of the burial activity. I checked in at the White Mesa mill at 8:00 a.m. on August 2,2013 and coordinated with mill personnel this and the biannual dam safety inspections. Soon thereafter I met with Mr. Garrin Palmer and David Turk, and planned the inspection activities. Mr. Palmer and I proceeded directly to the field to commence the ISL burial activity. Material disposed consisted of soil, with occasional incidental pieces of metal, wood or other debris. The material disposed represented loads from URI Incorporated in Kingsville, Texas, shipped by Greenfield Logistics, Inc., bearing Shipper Number 13KVD-029, 13KVD-031, and 13KVD-034 through 13KVD-039 (one load had two manifests as it consisted of a truck-and-pup pair.). The bill of lading for each of these loads appears in the attachments to this report. The work crew executed the waste disposal in two excavations that extended into the tailings sands, as evidenced by the spoils adjacent to the excavation, and exposed solution at approximately 24 inches below the rim of the excavation. Given the elevation of the solution, I could not observe the bottom of the excavation. Mr. Palmer surveyed the level at the bottom of the excavations prior to waste placement, employing one of 168 North 1950 West • Salt Lake City, UT Mailing Address. P.O. Box 144850 • Salt Lake City, UT 84114-4850 Telephone (801) 536-4250 • Fax (801) 533-4097 • T D D. (801) 536-4414 www deq Utah gov Pnnted on 100% recycled paper Page 2 the equipment operators as a rodman. Using a front-end loader and a small dozer, crews placed the waste in the excavations and tamped it down to approximately one foot below the top of the excavation. Mr. Palmer then surveyed the elevation of the top of the waste, and the crews filled the excavation to the top with soil. The crew track-walked the capping fill to a point where it exhibited no yielding. EFR appears compliant with Part 10.5.E.(2) of the RML with respect to,the elevation of burial. It appeared that all provisions of the approved disposal SOP were followed during placement and burial of the bulk waste, except as previously noted. Finding: EFR appears to have followed applicable provisions of the RML and of the SOPfor the burial operation I observed. Recommendation: I recommend closing out the inspection of August 2, 2013. Attachments: Photo log, Receipt Notification July 17, 2013, Bill of Lading and Disposal Documentation for each load disposed on August 2, 2013 W0M ENERG YFUELS Energy Fuels Resources (USA) Inc 6425 South Highway 191. PO Box 809 Blandmg. UT. US, 84511 435 678 2221, fax 435 678 2224 www energyfuels com July 17, 2013 VIA Electronic Mail (PDF) and UPS Mr. Rusty Lundberg Division Director of Radiation Control State of Utah Department of Environmental Quality 195 North 1950 West PO Box 144830 Salt Lake City, UT 84114-4820 Dear Mr. Lundberg, Re: 1 le.(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 Radiation Control that the White Mesa Uranium Mill will be receiving and disposing of thirteen loads of 1 le.(2) byproduct materials on August 2, 2013. 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 435.678.2221. David Turk Environmental Health & Safety Manager Energy Fuels Resources (USA) Inc. cc: Denver Central Files No.: PBL-10 Rev. No.: R-3.1 Date: June 4,2012 DENISON MINES (USA) CORP. STANDARD OPERATING PROCURES Title: 1 le,(2) byproduct Disposal Page 10 of 12 ATTACHMENT 2 lle.(2) BYPRODUCT MAT^Wlt DISMiSAL DOCUMENTATION FORM Date: Name of employee receiving the load: ^,,vt.^ fteJ*/^/- Generator of the Byproduct Material: utz-c wc^c ^Vile. Was the State of Utah given notice to the receipt/disposal activities associated witii this load? (fe?£r No Who gave and when was the notification given? Description of byproduct material disposal are,a/aptiyities: Has each drum been inspected to identify the presence of any void spaces? j*/A Have all drums with void spaces been filled with tailings sands or soil? fi/s/\. Which tailings ,cell was the material placed in? £-g~U 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? Was the material segregated from any Mill material or equipment disposed of in the cell? Vc-S ' Was the material segregated from byproduct material from other ISL sources disposed pf in fee cell?, Yoy \ —•— • No.: PBL-10 Rev.No.:R-3.1 Date: June 4,2012 DENISON MINES (USA) CORP. STANDARD OPERATING PROCEDURES Title: 1 le.(2) Byproduct Disposal Page 11 of 12 Have the thickness and placement measurements been verified and documented for the disposal area by the engineer, specifically: Was the material placed in a cell approved by the executive Secretary for ISL waste disposal? Yt* Documentation of approval J^eemc & uTiqctV/q Am">f~ Was the ISL material segregated from disposed Mill material and other ISL material? Refer to plat(s) used to confirm. CeJi J- //e.Z W Arc* 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? Has 4 foot of tailings sands been maintained under each disposal area? Vc* Refer to drawings used to confirm Celt 3 6»Aik Dnf,\y4 Is the bottom of each disposal area at least 12 feet from the sides or dikes of the tailings oell? Refer to drawings used to confirm. 6*11 3 Comtk fl/ba*i\*ft Will the elevation of the material exceed the plane or grade of the elevation of the uppermost flexible membrane liner of the cell? M How was this confirmed (e.g., survey or review) Engineer's or RSO's Initials 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? Are additional settlement monitors required to be placed for this generator? MA If required, where were settlement markers were placed? A/A No.: PBL-10 Rev.No.:R-3.1 Date: June 4,2012 DENTSON MINES (USA) CORP. STANDARD OPERATING PROCEDURES Title: 1 le.(2) Byproduct Disposal Page 12 of 12 A/A Radiological receipt survey measurements: Breathing Zone: 1. Was a Breathing Zone Sample collected? Yes or^tfo) 2. If yes, what were the results of the sampling? Was a photograph taken during the unloading activities?/Yes)or No URI URI, INC. STRAIGHT BILL OF LADING FOR BYPRODUCT MATERIAL RM License No. R03653 Shipment No. 13KVD-029 Trailer* GFLU2142 Seal # n/a NAME OF CARRIER: Greenfield Logistics DRIVER: ^ JJi SHIPPER (from) URI, Inc. STREET 641 E. FM 1118 CITY Kingsville STATE Texas ZIP 78363 COUNTRY USA PHONE 361-595-5731 COSIGNEE (to) Energy Fuels- White Mesa DESTINATION STREET 6425 S. Hwy 191 CITY Blanding STATE UT ZIP 84511 COUNTRY U.S.A. PHONE 435-678-2221 CONTENTS EXCLUSIVE USE SHIPMENT ***These contents are contaminated with natural uranium and its daughters 226Ra and 230Th *** PROPER SHIPPING NAME: RADIOACTIVE MATERIAL L.S.A 1. HAZARD CLASS: J IDENTIFICATION NUMBER: UN 2912 WEIGHT: Tare 44.000 lbs. NET 29.206 lbs. GROSS 73.206 lbs. EMERGENCY CONTACTS 24 HOUR CHEMTREC: 800-424-9300 password: URI URI DISTRICT: 361-331-5585 (Joshua Holland) URI HEADQUARTERS: 214-683-8889 (Mark Pelizza) 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 COMPLIANCE WITH 49 CFR 173.427 (c) Shipper's Signature A ~ 7~Z ~~ I Date CARRIER'S CERTIFICATION Carrier acknowledges receipt of packages and required placards. Carrier certifies emergency response information was made available and has the appropriate emergency response document in the vehicle. Department of Transportation. Driver's Signature Cosignee's Signature / GNEE Date *s RECIEPT of SHIPMENT Date J. No.: PBL-10 Rev. No.:R-3.1 Date: June 4,2012 DENISON MINES (USA) CO%P, STANDARD OPE^TLNfG PROCEDURES Title: 1 ler(2) Byproduct Pisposal , Page 10 of 12 ATTACHMENT 2 lle.(2) BYPRODUCT MATEKEAL tilSMSAL DOCUMENTATION FORM Date: _3j^2_Ll3__ Name of employee receiving the load: £~ P^l***^«- Generator of the Byproduct Material: \L\^Sti\< Was the State of Utah given notice to the receipt/disposal activities associated with this loa4?(X£s)or No Who gave and when was the notification given? Cw.A TL>,>v:v T,dy J\ lotT B ——————————————— ' f- Description of byproduct material disposal area/aptiYities: kfrh • • - r-, r- : pl^Vrr-r f^A. p It^JL t~g- _ , " '—'TTT-I •• Has each drum been inspected to identify liie presence of any void spaces? —: Have all drums with void spaces been filled with tailings sands or soil? ^/J* Which tailings cell was the material placed in? C LI ."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? Was the material segregated from any Mill material or equipment disposed of in the cell? Yes ' Was the material segregated from byproduct material from other ISL sources disposed. of in the cell? —^ : _ —— No.: PBL-10 Rev. No.: R-3.1 Date: June 4,2012 DENISON MINES (USA) CORP. STANDARD OPERATING PROCEDURES Title: 1 le.(2) Byproduct Disposal Page 11 of 12 Have the thickness and placement measurements been verified and documented for the disposal area by the engineer, specifically: Was the material placed in a cell approved by the executive Secretary for ISL waste disposal? Documentation of approval livr^ *f £AT rt0o<t7<9 An^f Was the ISL material segregated from disposed Mill material and other ISL material? Refer to plat(s) used to confirm. Ct/t .3 ///. Z 0,^*74*. ( 4r*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? Has 4 foot of tailings sands been maintained under each disposal area? fey Refer to drawings used to confkm_jW/£ 6*n<sk /)m~Ayt Is the bottom of each disposal area at least 12 feet from the sides or dikes of the tailings oell? -^r Refer to drawings used to confirm. 3 /)s*.i*s/w& 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) Engineer's or RSO's Initials 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? ±SS Was the shipment properly covered? iAl Are additional settlement monitors required to be placed for this generator? AlA If required, where were settlement markers were placed? A/A No.: PBL-10 Rev.No.:R-3.1 Date: June 4,2012 DENISON MINES (USA) CORP. STANDARD OPERATING PROCEDURES Title: 1 le.(2) Byproduct Disposal Page 12 of 12 ASM Radiological receipt survey measurements: Breathing Zone: 1. Was a Breathing Zone Sample collected? Yes or(£?o J 2. If yes, what were the results of the sampling? Was a photograph taken during the unloading activities? /Tesjor No URI URL INC. STRAIGHT BILL OF LADING FOR BYPRODUCT MATERIAL RM License No. R03653 Shipment No 13KVD-031 Traifer#GFLU001187 Date: 7/15/2013 Seal # n/a NAME OF CARRIER: Greenfield Logistics DRIVER: X H&ki Gicx^f^r SHIPPER (from) URI, Inc. STREET 641 E. FM 1118 CITY KingsvMle STATE Texas ZIP 78363 COUNTRY USA PHONE 361-595-5731 COSIGNEE (to) Energy Fuels- White Mesa Mill DESTINATION STREET 6425 S. Hwy 191 CITY Blanding STATE UT ZIP 84511 COUNTRY U.S.A. PHONE 435-678-2221 CONTENTS EXCLUSIVE USE SHIPMENT These contents are contaminated with natural uranium and its daughters 226Ra and 230Th PROPER SHIPPING NAME' RADIOACTIVE MATERIAL LS.A 1. HAZARD CLASS 7 IDENTIFICATION NUMBER. UN 2912 WEIGHT: Tare 44.000 lbs. NET 29.844 lbs. GROSS 73.844 lbs. EMERGENCY CONTACTS 24 HOUR CHEMTREC: 800-424-9300 password: URt URI DISTRICT: 361-331-5585 (Joshua Holland) URI HEADQUARTERS: 214-683-8889 (Mark Petizza) SHIPPER'S CERTIFICATION This is to certify that the above materials are properly classified, described, packaged, marked, placarded and labeled, and are in proper condrtion for transportation according to the applicable regulations of the Department of Transportation. THIS VEHICLE IS CONSIDERED A PACKAGE IN COMPLIANCE WITH 49 CFR 173.427 (c) Shipper's Signature 7/ Date 7/15/2013 CARRIER'S CERTIFICATION Carrier acknowledges receipt of packages and required placards. Carrier certifies emergency response information was made available and has the appropriate emergency response document rn the vehicle. Department of Transportation Driver's Signature Date CONSIGNEE'S RECIEPT of SHIPMENT Cosignee's Signature Date No.: PBL-10 Rev. No.:R-3.1 Date: June 4,2012 DENISON MINES (USA) CORP. STANDARD OPERATING PROCEDURES Title: 1 le,(2) Byproduct Disposal Page 10 of 12 ATTACHMENT 2 lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM Date: -7 1 ±1 \\Z Name of employee receiving the load: T^.r^y £IAJ>£- Generator of the Byproduct Material: t^r, yil^t Was the State of Utah given notice to the receipt/disposal activities associated with this load^Yesbr No Who gave and when was the notification given? Description of byproduct material disposal area/activities: —SJ^C—pU^ fas r^^A. ^> i f- 4—-Vg Has each drum been inspected to identify the presence of any void spaces? AJA - Have all drums with void spaces been filled with tailings sands or soil?, /(/A . Which tailings cell was the material placed in? Lr \\ T 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 segregated 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? Yx£ '. No.: PBL-10 Rev.No.:R-3.1 Date: June 4,2012 DENISON MINES (USA) CORP. , STANDARD OPERATING PROCEDURES Title: 1 le.(2) Byproduct Disposal Page 11 of 12 Have the thickness and placement measurements been verified and documented for the disposal area by the engineer, specifically: Was the material placed in a cell approved by the executive Secretary for ISL waste disposal? jej Documentation of approval # «r/tGo*f?H #«*tf~ Was the ISL material segregated from disposed Mill material and other ISL material? Y« Refer to plat(s) used to confirm. Ctt/ J /fe.Z l?tty*&l_Arct* 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? Has 4 foot of tailings sands been maintained under each disposal area? Ife< Refer to drawings used to confirm C*M 3 C**<st J)rg,**fo^j Is the bottom of each disposal area at least 12 feet from the sides or dikes of the tailings oell? Refer to drawings used to confirm. C*/l 3 Of*~-irtjj Will the elevation of the material exceed the plane or grade of the elevation of the uppermost flexible membrane liner of the cell? confirmed How was this (e.g., survey or review) Engineer's or RSO's Initials 4L 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? Yes Was the shipment properly covered? Y^i Are additional settlement monitors required to be placed for this generator? dzA If required, where were settlement markers were placed? /I/A- logical eyme P ents Br Zone Br, If Zo yes ne Sa *hat Were the coil* Stilts Ye ofth or sampi as a Phot °graph take the unload activiti es? es No URi URI, INC. STRAIGHT BILL OF LADING FOR BYPRODUCT MATERIAL RM License No. R03653 Shipment No. 13KVD-034 Trailer #GFLU001088 Date: 7/19/2013 Seal # n/a NAME OF CARRIER: Greenfield Logistics DRIVER: k^~7eM SHIPPER (from) URI, Inc. STREET 641 E. FM1118 CITY Kingsville STATE Texas ZIP 78363 COUNTRY USA PHONE 361-596-5731 COSIGNEE (to) Energy Fuels- White Mesa DESTINATION STREET 6425 S. Hwy 191 CITY Blanding STATE UT ZIP 84511 COUNTRY U.S.A. PHONE 435-678-2221 CONTENTS EXCLUSIVE USE SHIPMENT fc**These contents are contaminated with natural uranium and its daughters ^Ra and ^h *** PROPER SHIPPING NAME: RADIOACTIVE MATERIAL L.S.A 1. HAZARD CLASS' 7 IDENTIFICATION NUMBER: UN 2912 WEIGHT: Tare 44.000 lbs. NET 31.361 lbs. GROSS 75.361 lbs. EMERGENCY CONTACTS 24 HOUR CHEMTREC: 800-424-9300 password: URI URI DISTRICT: 361-331-5585 (Joshua Holland) URI HEADQUARTERS: 214-683-8889 (Mark Pelizza) 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 COMPLIANCE WITH 49 CFR 173.427 (c) Shipper's Signature Date 7/19/2013 CARRIER'S CERTIFICATION Carrier acknowledges receipt of packages and required placards. Carrier certifies emergency response information was made available and has the appropriate emergency response document in the vehicle. Department of Transportation. Driver's Signature 72 Date CONSIGNEE'S RECIEPT of SHIPMENT Cosignee's Signature ft Date ~7~ 77-15 No.: PBL-10 Rev. No.:R-3.1 Date: June 4,2012 DENISON.MDSfES (USA) CORP. STANDARD OPERATING PROCEDURES Title: 1 le.(2) Byproduct Disposal Page 10 of 12 ATTACHMENT 2 lle.(2) BYPRODUCT MATERIAL ftiSMSAL DOCUMENTATION FORM Date: -7(17(1^ Name of employee receiving the load: PA^cr Generator of the Byproduct Material: UETI iA.:^o»lld. Was the State of Utah given notice to the receipt/disposal activities associated with this load9£YesV Who gaye and when was the notification given? Description of byproduct material disposal area/activities: b>rv ; '" ;r " - ' —Sir • fWtr?S r~^X ^UfT-g, ' . , - Has each drum been inspected to identify the presence of any void spaces? A Have all drums with void spaces been filled with tailings sands or soil? MA . Which tailmgs cell was the material placed in? CcAi T . Was the material placed on a tailings beach area of the cell of on an area of the cell that was underlain by tailings sands? Was the material segregated 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?, No.: PBL-10 Rev. No.: R-3.1 Date: June 4,2012 DENISON MINES (USA) CORP. STANDARD OPERATING PROCEDURES Title: 1 le.(2) Byproduct Disposal Page 11 of 12 Have the thickness and placement measurements been verified and documented for the disposal area by the engineer, specifically: Engineer's or RSO's Initials Was the material placed in a cell approved by the executive Secretary for ISL waste disposal? Documentation of approval l*ce«& #JuT IW74 f Was the ISL material segregated from disposed Mill material and other ISL material? _K£ Refer to plat(s) used to confirm. Cell 3 l/e. Z 0/^%&<l 4r<« Was the maximum lift thickness above tailings less man 4 feet thick? 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? fcj Refer to drawings used to confirm fltfl 3 Cmt Onf'/itts Is the bottom of each disposal area at least 12 feet from the sides or dikes of the tailings oell? Ye3 Refer to drawings used to confirm, foil 3 Co»*l. 0r««swjf Will the elevation of the material exceed the plane or grade of the elevation of the uppermost flexible membrane liner of the cell? this How was 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? *CA Are additional settlement monitors required to be placed for this generator? tVfc . , If required, where were settlement markers were placed? /y/A No.: PBL-10 Rev. No.: R-3.1 Date: June 4,2012 DENISON MINES (USA) CORP. STANDARD OPERATING PROCEDURES Title: 1 le.(2) Byproduct Disposal Page 12 of 12 A/A Radiological receipt survey measurements: Breathing Zone: 1. Was a Breathing Zone Sample collected? Yesoi^C; 2. If yes, what were the results of the sampling? Was a photograph taken during the unloading activities? /Yesjor No URI URI, INC. STRAIGHT BILL OF LADING FOR BYPRODUCT MATERIAL RM License No. R03653 Shipment No. 13KVD-035 Trailer* GFLU001099 Date: 7/24/2013 Seal # n/a NAME OF CARRIER: Greenfield Logistics DRIVER: Tifty fj^y^J^ SHIPPER (from) URI, Inc. STREET 641 E. FM1118 CITY Kingsville STATE Texas ZIP 78363 COUNTRY USA PHONE 361-595-5731 COSIGNEE (to) Energy Fuels- White Mesa DESTINATION STREET 6425 S. Hwy 191 CITY Blanding STATE UT ZIP 84511 COUNTRY U.S.A. PHONE 435-678-2221 CONTENTS EXCLUSIVE USE SHIPMENT These contents are contaminated with natural uranium and its daughters 226Ra and 230Th PROPER SHIPPING NAME: RADIOACTIVE MATERIAL LS.A 1. HAZARD CLASS" 7 IDENTIFICATION NUMBER: UN 2912 WEIGHT: Tare 44.000 lbs. NET 31.975 lbs. GROSS 75.975 lbs. EMERGENCY CONTACTS 24 HOUR CHEMTREC: 800-424-9300 password: URI URI DISTRICT: 361-331-5585 (Joshua Holland) URI HEADQUARTERS: 214-683-8889 (Mark Pelizza) 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 COMPLIANCE WITH 49 CFR 173.427 (c) Shipper's Signature Date 7/24/2013 ~7f 9 CARRIER'S CERTIFICATION Carrier acknowledge^eceipt of packages and required placards. Carrier certifies emergency response information was made available and has the appropriate emergency response document in the vehicle. Department of Transportation. Driver's Signature Date CONSIGNEE'S REC1EPT of SHIPMENT Cosignee's Signature Date l\Zl fax No.: PBL-10 Rev. No.:R-3.1 Date: June 4,2012 DENISON MINES (USA) CORP. STANDARD OPERATING PROCEDURES Title: 1 le.(2) Byproduct Disposal Page 10 of 12 ATTACHMENT 2 lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM Date: Name of employee receiving the load: A^*,^ PA I^V^/- Generator of the Byproduct Material: /J?fL H V^.^SLTU^ Was the State of Utah given notice to the receipt/disposal activities associated with this load?£?e| or No Who gave and when was the notification given? Description of byproduct material disposal area/activities: See- pU^4-o pUAlc Has each drum been inspected to identify the presence of any void spaces? A/A Have all drums with void spaces been filled with tailings sands or soil? A/A Which tailings cell was the material placed in? /Ifcll % c 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 segregated from any Mill material or equipment disposed of in the cell? 1o> Was the material segregated from byproduct material from other ISL sources disposed of in the cell? rV> No.: PBL-10 Rev. No.:R-3.1 Date: June 4,2012 DENISON MINES (USA) CQRP. STANDARD OPERATING PROCEDURES Title: 1 le.(2) Byproduct Disposal Page 11 of 12 Have the thickness and placement measurements been verified and documented for the disposal area by the engineer, specifically: Was the material placed in a cell approved by the executive Secretary for ISL waste disposal? «# Documentation of approval Li*t»4t #HT fWf?9 A**tf Was the ISL material segregated from disposed Mill material and other ISL material? Refer to plat(s) used to confirm. &//3 fft* I Aqaejo/ 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? Has 4 foot of tailings sands been maintained under each disposal area? Yef Refer to drawings used to confirm 6eff 3 £6**f. rfs>**sthff Is the bottom of each disposal area at least 12 feet from the sides or dikes of the tailings oell?. Refer to drawings used to confirm, telf 3 h Or+*sfajt? 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) Engineer's or RSO's Initials 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? Were void spaces filled with tailings? Was the shipment properly covered? 1^1 Are additional settlement monitors required to be placed for this generator? A/A . If required, where were settlement markers were placed? A/A No.: PBL-10 Rev. No.: R-3.1 Date: June 4,2012 DENISON MINES (USA) CORP. STANDARD OPERATING PROCEDURES Title: lie (2) Byproduct Disposal Page 12 of 12 //A Radiological receipt survey measurements: ./L T*n> Breathing Zone: 1. Was a Breathing Zone Sample collected? Yes or^Nlc) 2. If yes, what were the results of the sampling? Was a photograph taken during the unloading activities? / Yesor No URI URI, INC. STRAIGHT BILL OF LADING FOR BYPRODUCT MATERIAL RM License No. R03653 Shipment No. 13KVD-036 Trailer* GFLU2119 Date: 7/19/2013 Seal # n/a NAME OF CARRIER: Greenfield Logistics DRIVER: V ^TZscLd Gnajt&Q SHIPPER (from) URI, Inc. STREET 641 E. FM 1118 CITY Kingsville STATE Texas ZIP 78363 COUNTRY USA PHONE 361-595-5731 COSIGNEE (to) Energy Fuels- White Mesa DESTINATION STREET 6425 S. Hwy 191 CITY Blanding STATE UT ZIP 84511 COUNTRY U.S.A. PHONE 435-678-2221 CONTENTS EXCLUSIVE USE SHIPMENT These contents are contaminated with natural uranium and its daughters Ra and "uTh PROPER SHIPPING NAME: RADIOACTIVE MATERIAL L.S.A 1. HAZARD CLASS: _7 IDENTIFICATION NUMBER: UN 2912 WEIGHT: Tare 44.000 lbs. NET 30.009 lbs. GROSS 74.009 lbs. EMERGENCY CONTACTS 24 HOUR CHEMTREC: 800-424-9300 password: URI URI DISTRICT: 361-331-5585 (Joshua Holland) URI HEADQUARTERS: 214-683-8889 (Mark Pelizza) 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 COMPLIANCE WITH 49 CFR 173.427 (c) Shipper's Signature Date 7/19/2013 ARRIER's CERTIFICATION Carrier acknowledges receipt of packages and required placards. Carrier certifies emergency response information was made available and has the appropriate emergency response document in the vehicle. Department of Transportation. Driver's Signature Date CONSIGNEE'S RECIEPT of SHIPMENT Cosignee's Signature Date "7 No.: PBL-10 Rev. No.: R-3.1 Date: June 4,2012 DENISON MINES (USA) CORP. STANDARD OPERATING PROCEDURES Title: 1 le,(2) byproduct Disposal Page 10 of 12 ATTACHMENT 2 Ue.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM Date: l\ Name of employee receiving the load: ^r»:«. PcJr^es- Generator of the Byproduct Material: unrt u^c^ilr Was the State of Utah given notice to the receipt/disposal activities associated with this load? (Tfespr No - • Who gave and when was the notification given? Description of byproduct material disposal area/activities: Has each drum been inspected to identify the presence of any void spaces? A/A Have all drums with void spaces been filled with tailings sands or soil? _ A/A Which tailings cell was the material placed in? T 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? A^ft~Vfcr-«*A iAi to thrift-A ^ Was the material segregated 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?, AZA " ~~~ No.: PBL-10 Rev.No.:R-3.1 Date: June 4,2012 DENISON MINES (USA) CORP. STANDARD OPERATING PROCEDURES Title: 11 e.(2) Byproduct Disposal Page 11 of 12 Have the thickness and placement measurements been verified and documented for the disposal area by the engineer, specifically: Was the material placed in a cell approved by the executive Secretary for ISL waste disposal? iti Documentation of approval Jjte&e & uf /W7y Awf Was the ISL material segregated from disposed Mill material and other ISL material? Yes Refer to plat(s) used to confirm. 3 //>. Z fryfoaj 4^*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? Has 4 foot of tailings sands been maintained under each disposal area? fa Refer to drawings used to confirm 6tfl 3 Or*. vfijiS Is the bottom of each disposal area at least 12 feet from the sides or dikes of the tailings oell? Yrj Refer to drawings used to confirm. £t//3 AMI* O^a^i^ Will the elevation of the material exceed the plane or grade of the elevation of the uppermost flexible membrane liner of the cell? A/o review) How was this confirmed (e.g., survey or Engineer's or RSO's Initials 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? y^j Was the shipment properly covered? Are additional settlement monitors required to be placed for this generator? If required, where were settlement markers were placed? A/A No.: PBL-10 Rev. No.: R-3.1 Date: June 4,2012 DENTSON MINES (USA) CORP. STANDARD OPERATING PROCEDURES Title: 11 e.(2) Byproduct Disposal Page 12 of 12 A/ A Radiological receipt survey measurements: Breathing Zone: 1. Was a Breathing Zone Sample collected? Yesoi^NoJ) 2. If yes, what were the results of the sampling? Was a photograph taken during the unloading activitiesyYesp: No URI URI, INC. STRAIGHT BILL OF LADING FOR BYPRODUCT MATERIAL RM License No. R03653 Shipment No. 13KVD-037 Trailer* GFLU0011551 Date: 7/24/2013 Seal # n/a NAME OF CARRIER: Greenfield Logistics DRIVER: ^7^4di GCL^L SHIPPER (from) URI, Inc. STREET 641 E. FM 1118 CITY Kingsville STATE Texas ZIP 78363 COUNTRY USA PHONE 361-595-5731 COSIGNEE (to) Energy Fuels- White Mesa Mill DESTINATION STREET 6425 S. Hwy 191 CITY Blanding STATE UT ZIP 84511 COUNTRY U.S.A. PHONE 435-678-2221 CONTENTS EXCLUSIVE USE SHIPMENT These contents are contaminated with natural uranium and its daughters 226Ra and 230Th PROPER SHIPPING NAME: RADIOACTIVE MATERIAL L.S.A 1. HAZARD CLASS" 7 IDENTIFICATION NUMBER: UN 2912 WEIGHT: Tare 44.000 lbs. NET 30.749 lbs. GROSS 74.749 lbs. EMERGENCY CONTACTS 24 HOUR CHEMTREC: 800-424-9300 password: URI URI DISTRICT: 361-331-5585 (Joshua Holland) URI HEADQUARTERS: 214-683-8889 (Mark Pelizza) 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 COMPLIANCE WITH 49 CFR 173.427 (c) Shipper's Signature Date 7/24/2013 CARRIER'S CERTIFICATION Carrier acknowledges receipt of packages and required placards. Carrier certifies emergency response information was made available and has the appropriate emergency response document in the vehicle. Department of Transportation. Dnver's Signature Date i . CONSIGNEE'S RECIEPT of SHIPMENT Cosignee's Signature Date No.: PBL-10 Rev. No.: R-3.1 Date: June 4.2012 DENISON MINES (USA) CORP. STANDARD OPERATING PROCEDURES Title: 1 le.(2) Byproduct Disposal Page 10 of 12 ATTACHMENT 2 lle.(2) BYPRODUCT MATERIAL filSP^SAL DOCUMENTATION FORM Date; tf/t/i*, Name of employee receiving the load: DM\JlZ^k Generator of the Byproduct Material: DfZJ- k\^>»lttc Was the State of Utah given notice to the receipt/disposal activities associated with this load?CYesJ)r No * Who gave and when was the notification given? MM 43- Descriptioi* of byproduct material disposal area/aptivitjes: Has each drum been inspected to identify the presence of any void spaces? Hh~ Have all drums with void spaces been filled with tailings sands or soil? Which tailings cell was the material placed in? Colli? Was the material placed on a tailings oeach area of the cell of on an area of the cell that was underlain by tailings sands? Was the material segregated from any Mill material or equipment disposed of in the cell? iiA Was the material segregated from byproduct material from other ISL sources disposed of in the cell? No.: PBL-10 Rev.No.:R-3.1 Date: June 4,2012 DENISON MINES (USA) CORP. STANDARD OPERATING PROCEDURES Title: lle.(2) Byproduct Disposal Page 11 of 12 Have the thickness and placement measurements been verified and documented for the disposal area by the engineer, specifically: Engineer's or RSO's Initials Was the material placed in a cell approved by the executive Secretary for ISL waste disposal? Vts Documentation of approval Lfctnst 4l ur/Wf71 A^mf Was the ISL material segregated from disposed Mill material and other ISL material? Refer to plat(s) used to confirm. Celt 3 0ttyc*«f Ar*h Was the maximum lift thickness above tailings less than 4 feet thick? g 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? V*/ Refer to drawings used to confirm Ct/t 3 C*n*}. Dra^^J Is the bottom of each disposal area at least 12 feet from the sides or dikes of the tailings oell? Yej Refer to drawings used to confirm. \Ce/f 3 &»t.fk Dr+^^i Will the elevation of the material exceed the plane or grade of the elevation of the uppermost flexible membrane liner of the cell? A4_ 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? to Are additional settlement monitors required to be placed for this generator? ^ If required, where were settlement markers were placed? A/A No.: PBL-10 Rev. No.: R-3.1 Date: June 4,2012 DENTSON MINES (USA) CORP. STANDARD OPERATING PROCEDURES Title: 1 le.(2) Byproduct Disposal A/A Page 12 of 12 f Radiological receipt survey measurements: L ?XT> Breathing Zone: 1. Was a Breathing Zone Sample collected? Yesoi(No) 2. If yes, what were the results of the sampling? Was a photograph taken during the unloading activities? Q^es or No , ••*~s ' URI URI, INC. STRAIGHT BILL OF LADING FOR BYPRODUCT MATERIAL Shipment No. 13KVD-038&39 Trailer #C Of lU 1 I ' f RM License No. R03653 Date: 7/31/2013 Seal # n/a NAME OF CARRIER: Greenfield Logistics DRIVER>C M 61* SHIPPER (from) URI, Inc. STREET 641 E. FM 1118 CITY Kingsville STATE Texas ZIP 78363 COUNTRY USA PHONE 361-595-5731 COSIGNEE (to) Energy Fuels- White Mesa Mill DESTINATION STREET 6425 S. Hwy 191 CITY Blanding STATE UT ZIP 84511 COUNTRY U.S.A. PHONE 435-678-2221 CONTENTS EXCLUSIVE USE SHIPMENT These contents are contaminated with natural uranium and its daughters 226Ra and 230Th PROPER SHIPPING NAME: RADIOACTIVE MATERIAL L.S.A 1. HAZARD CLASS* 7 IDENTIFICATION NUMBER: UN 2912 WEIGHT: Tare 44.000 lbs. NET lbs. GROSS lbs. EMERGENCY CONTACTS 24 HOUR CHEMTREC: 800-424-9300 password: URI URI DISTRICT: 361-331-5585 (Joshua Holland) URI HEADQUARTERS: 214-683-8889 (Mark Pelizza) 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 COMPLIANCE WITH 49 CFR 173.427 (c) Shipper's Signature Date 7/31/2013 CARRIER'S CERTIFICATION Carrier acknowledges was made available Transportation. £ipt of packages and required placards. Carrier certifies emergency response information has the appropriate emergency response document in the vehicle. Department of Driver's Signature Date CONSIGNEE'S RECIEPT of SHIPMENT Cosignee's Signature Date Photo 1. One of two excavations to receive 1 le.(2) material for burial. Photo taken 8:58 a.m. August 2, 2013. Photo 2. One of two excavations to receive 11 e.(2) material for burial. Photo taken 8:59 a.m. August 2, 2013. P EST 3* m •v. X. Photo 3. Introducing the 1 le.(2) material into the excavation. Photo taken 8:57 a.m. August 2, 2013. Photo 4. Introducing the 11 e.(2) material into the excavation. Photo taken 9:00 a.m. August 2, 2013. Photo 5. Placing cover soil over waste. Photo taken 9:23 a.m. August 2, 2013. ../r.-./.'-x'il.v Photo 7. Cover soil placed and densified by track-walking. View is from northeast. Photo taken 9:40 a.m. August 2,2013. Photo 6. Cover soil placed and densified by track-walking. View is from southeast. Photo taken 9:34 a.m. August 2,2013. : • Photo 8. Documentary view of worksite. Primary burial took place in an excavation to the left of and behind the visible spoils pile. The second excavation, which received veiy little waste, was to the right of the spoils pile.. Photo taken 9:47 a.m. August 2, 2013.