DRC-2013-003017 - 0901a068803b27b8

Department of
Environmental Quality
Amanda Smith
Executive Director
State of Utah M DRC-2013-003017' GARY R HERBERT
Governor
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
GREG BELL
Lieutenant Governor
MEMORANDUM
TO:
THROUGH:
FROM:
DATE:
SUBJECT: Engineering Module 73 (Project C-2013-61). Inspection of Disposal of Bulk Byproduct
Material June 6, 2013. Radioactive Materials License UT1900479 (License) - Energy
Fuels Resources (USA) Inc. (EFR) White Mesa Mill, Blanding, Utah
On June 6 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 May 23, 2013 (eDocs #DRC-2013-002345).
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 May 24, 2013 DRC received notice that EFR would receive six loads of 1 le.(2) byproduct material,
and intended to dispose of that waste in Cell 3 on June 6, 2013. Five loads were ultimately received prior to
the commencement of the burial activity.
I checked in at the White Mesa mill at 12:20 p.m. on June 6, 2013 and immediately proceeded to the burial
location escorted by Terry Slade and David Turk. Burial proceeded sequentially in three trenches in
Tailings Cell 3, as follows:
• Two loads of debris from Mestena Uranium LLC, Encino, Texas, including filter pipe and soil.
• One load of soil in "supersacks" from URI (Vasquez), Kingsville, Texas.
• Two loads of construction/demolition debris from Crow Butte Resources, Inc., Crawford,
Documentation from the five loads described above is attached to this Memorandum.
The 1 le.(2) waste disposal operation commenced about 12:30 p.m. in three excavations. The excavation
each extended into the tailings sand, as evidenced by the spoils adjacent to the excavation, and in the case
of the excavations to receive the URI Vasquez and Crow Butte wastes, exposed solution at approximately
30 inches below the rim of the excavation
Nebraska.
168 North 1950 West • Salt Lake City, UT
Mailing Address P O Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax [phone] • T D D [phone]
• www deq Utah gov
Printed on 100% recycled paper
Page 2
Mr. Turk and Mr. Slade surveyed the level at the bottom of the excavations prior to placement of material.
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. Turk and Mr. Slade then surveyed the
elevation of the top of the waste, and the crews filled the excavation to the top with soil. Crews then track-
walked the fill soils to achieve densification.
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.
Finding: EFR appears to have followed applicable provisions of the RML and of the SOP for the burial
operation I observed.
Following observation of the waste burial operation, I requested to see the records of waste receipts since
the mill started receiving ISL waste materials. Attached to this Memorandum is a table, Energy Fuels
Resources (USA) Inc. lie.(2) Receipts for 2013, which details receipts for the year and over the life of the
plant. An inspection of the table reveals that EFR and its predecessors have complied with License
Condition 10.5A which limits receipt from any single ISL generator to 5000 cubic yards.
Finding: EFR has complied with License Condition 10.5A, receiving fewer than 5000 cubic yards of ISL
waste from any individual generator.
On March 18, 2013, the DRC sent to EFR a Request for Information regarding the March 7,2013 ISL
disposal inspection. Because of high moisture content, EFR was unable to compact the waste and cover
soils during the March 7, 2013 inspection. The DRC requested that EFR forward photographic
documentation and a narrative describing the work once crews completed the work. EFR submitted that
evidence on March 20, 2013. The photos have been placed in the Photo Log for the June 6, 2013
inspection, attached to this Memorandum.
Recommendation: Given the evidence presented, the DRC should close out both the March 7, 2013 and
June 6, 2013 ISL inspections.
While onsite, I reviewed EFR's records of receipt of alternate feed. A copy of spreadsheet summaries from
all alternate feed generators is attached to this Memorandum. These receipts reflect work under License
Conditions 10.6 through 10.19. Not all authorized generators have sent material to the White Mesa plant.
The following summarizes what EFR has received, and its status as of June 7, 2013.
Finding: Top dressing soils placed to protect the liner made physical inspection of the Cell 2 liner repair
impossible. However, review offile documentation and photos supports a conclusion that EFR took
appropriate measures to assure a successful repair.
Finding: Inspection of the Cell 4A repair site revealed no visual signs of defects in the repair. Review of
file documentation and photos supports a conclusion that EFR took appropriate measures to assure a
successful repair.
Finding: Emerging rill erosion noted on the exterior embankments to Cells 4A and 4B in the December 20,
2012 DMT inspection has been corrected.
Finding: The December 20, 2012 DMT inspection identified movement monitors in the center of the
perimeter road atop the exterior embankment to Cell 4A. EFR has not yet moved the monitors to a location
Page 3
less vulnerable to disturbance. However, the optimum time to relocate the movement monitors will not
come until the annual monitor survey in May, 2013.
I have attached a photo log documenting parts of the burial operation.
Attachments: 11 e.(2) Byproduct Receipt Notification Dated May 23, 2013
Bill of Lading and Disposal Documentation for ISL Buried June 6, 2013
Photo log for June 6, 2013 and Compaction of Cover for March 7, 2013 Disposal Activities
Summary of Total and Year To Date ISL Receipts By Generator
ENERGY FUELS
Energy Fuels Resources (USA) Inc.
6425 South Highway 191, PO Box 809
Blanding, UT. US, 84511
— -435-678^22lT-fax [phone]
www.energyfuels.com
VIA Electronic Mail (PDF) and UPS
May 23, 2013
II DRC-2013-00234^^^
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: 11 e.(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 six loads of 1 le.(2) byproduct materials on June 6, 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
Generator of Byproduct material: Mestena
Controled Elevation used (Cell 3)
Initial shot for trench
Top of trench 5611.61
Bottom of trench 5605.72
Initial shot used for material
Top of material in trench 5607.06
7.62
9.05
14.94
7.62
13.6
Area Elevation Transit Shot
Top of cell 3 Liner 5608.5
1.44 Feet below liner
No.: PBL-10
Rev.No.:R-3,l,
Date: June 4,201:2
DENISON MINES PSA) CQ>£P,,
STAND^ ^ElU$l|rC} EROQEpURES
Tiflet. 1 leil)&^r9d)jet:Dispp^al
Page 10 of 12
. ATTACHMENT 2
Ue.(2) BYPRODUCT MATlMtLiaff FORM
Date:
(- 'VI—" j • • •
Name nf ftmplnypft r^p.t^ing thft lnad- frtrf"-- P^^en • . \ , , -. ,
Generator of the Byproduct Material: AA^SV^^ L ^
Was the State of Utah ^yen noftce to the receipt/dispp^
No " ' "'^ * > f " ' '**' ' " ^ • . "" ' ' ' ..." ,
Whp gave and when was,the notification given? 5 f .
Description of byproduptrm£tejial d^6stal.£vr^a^tiYi!^:
Has each drum been inspected to identify the presence of any void s|lacevs? .A/Ar—" ; , , ~
Have all drums with void spaces been filled witji taijings sands or:jpl?, J/A •
Which taUjnjp cell wjas the majterial placed in? ^^-H ^ ; / -—-———-
Was the material placed on a tailings teach area of the cell or on an area of the cell tJjiat was , underlain
by tailings sands?
Was the material segregated from any Mill material or equipment disf)07slpd of in fee c^ell?,
y^_$ — •—~—.
Was the material segregated from byproduct material from other JSL sources S^p^joflg^Qell?,^
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
Was the ISL material segregated from disposed Mill material and other
ISL material? • , - ,
Refer to plat(s) used to confirm.
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?
Refer to drawings used to confirm
Is the bottom of each disposal area at least 12 feet from the sides or
dikes of the tailings oell?_j;
Refer to drawings used to confirm..
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?
Was the shipment properly covered?
Are additional settlement monitors required to be placed for this generator?
A/A
If required, where were settlement markers were placed?
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
Radiological receipt survey measurements: ^ > ^_>_,
Breathing Zone:
1. Was a Breathing Zone Sample collected? Yes or J_Q)
2. If yes, what were the results of the sampling?
Was a photograph taken during the unloading activities?/Ye>W No
BILL-OF-LADING
SHIPMENT ID#150 SHIPMENT DATE: Mav 31.2013
SHIPPER (From):
MESTENA URANIUM LLC
CONSIGNEE (To):
Energy Fuels Resources (USA) Inc.
6425 South Highway 191
Blanding, UT 84511
ADDRESS:
755 Co. Rd.315Encino, TX 78353
ADDRESS:
P. O. Box 809, Blanding UT 84511
SHIPPER LICENSE NO.: RO5360 SHIPPER USDOT NO.: CONSIGNEE
LICENSE NO.:
UT-1900479
CONSIGNEE TELEPHONE NO.;
[phone]
SHIPPER LICENSE NO.: SHIPPER TELEPHONE
NO.:361-561-4780
CARRIER NAME AND ADDRESS:
Greenfield Logistics, LLC
CARRIER USDOT
NO.
CARRIER HAZMAT REG. NO.
Trailer #£fl77£ff Container* GFLU 001007 Seal# 0000373 Seal* 0000374
HM DESCRIPTION OF MATERIAL AND PACKAGING VOLUME
Cubic feet
or
QUANTITY
CLASSIFICATION
lpkg.
RQ
UN2913, Radioactive Material, Surface Contaminated
Objects (SCO-1), non-fissile,, Class 7
Dry 11 (E)2 By-Product material.
Activity: 2.6 E8 Bq (0.007 CD
EMERGENCY CONTACT:
JJ. Cisneros: 1-361-877-2128
28,000 lbs.
(gross)
Surface contaminated objects
(SCO-1)
Exclusive use shipment
Placards applied
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: //jf'/1_A^^J^ Date: JtYf
Generator of Byproduct material: Mestena
Controied Elevation used (Cell 3)
Initial shot for trench
Top of trench 5611.61
Bottom of trench 5605.72
Initial shot used for material
Top of material in trench 5607.06
7.62
9.05
14.94
7.62
13.6
Area Elevation Transit Shot
Top of cell 3 Liner 5608.5
1.44 Feet below liner
No.: PBL-10
Rev. No.: R-3.1 ,
Date: June 4,2012
DENISON MINE§WSA) CORP. , ,
STANDARD bPE^ill5jfG PftoqEbu^ES
Title: lle,(2) Byproduct Disposal
Page 10 of 12
ATTACHMENT 2
llei(21M£EQEL^^
Date: ^3-13
Namft nf ftfnplnypft r^raiying the, load: /r^-l^ Pad^ey v
Generator of the Byproduct Material: M*xf e,*/^ . __ 4
Was the State of Utah given notice to the receipt/disppsal activities, associate^Jba4?CXss^r
No ' ' V" ' ' " ~
Who gave and when wasthe notification given? s
k>A,r\A. T^r^t Jthslrt _ , =———, . . ... ^ .. - ,:
Description of byproduct material disposal area/activities:
Has 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? Afk
Which tailings pell w#s the majteriaj.placed in? 3—\—~——:——.——
Was the material placed on a tailings teach 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 qf in the Qell? ,
2k : . • • '•> •
Was the material segregated from byproduct material from other ISL sources &sp>ose4qf 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
Was the ISL material segregated from disposed Mill material and other
ISL material?
Refer to plat(s) used to confirm.
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?
Refer to drawings used to confirm
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.
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?
-ly
Was the shipment properly covered?
Are additional settlement monitors required to be placed for this generator?
A/A
If required, where were settlement markers were placed?
4/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* . n
Breathing Zone:
1. Was a Breathing Zone Sample collected? Yes o^No
2. If yes, what were the results of the sampling?
Was a photograph taken during the unloading activities? /Yespr No
BILL-OF-LADING
SHIPMENT ID# 151 SHIPMENT DATE: Mav 31.2013
SHIPPER (From):
MESTENA URANIUM LLC
CONSIGNEE (To):
Energy Fuels Resources (USA) Inc.
6425 South Highway 191
Blanding, UT 84511
ADDRESS:
755 Co. Rd.315 Encino, TX 78353
ADDRESS:
P. 0. Box 809, Blanding UT 84511
SHIPPER LICENSE NO.: RO5360 SHIPPER USDOT NO.: CONSIGNEE
LICENSE NO.:
UT-1900479
CONSIGNEE TELEPHONE NO.
[phone]
SHIPPER LICENSE NO.: SHIPPER TELEPHONE
NO.:361-56M780
CARRIER NAME AND ADDRESS:
Greenfield Logistics, LLC
CARRIER USDOT
NO.
CARRIER HAZMAT REG. NO.
Trailer* frflflfV Container* GFLU001092 Seal* 0000375 Seal* 0000376
HM DESCRIPTION OF MATERIAL AND PACKAGING VOLUME
Cubic feet
or
QUANTITY
CLASSIFICATION
lpkg.
RQ
UN2913, Radioactive Material, Surface Contaminated
Objects (SCO-1), non-fissile,, Class 7
Dry 11 (E).2 By-Product material.
Activity: (0.007Ci)
EMERGENCY CONTACT:
JLJ. Cisneros: 1-361-877-2128
28,000 lbs.
(gross)
Suriace contaminated objects
(SCO-1)
Exclusive use shipment
Placards applied
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:
Driver's Signature:
Date: ~*Q&r3f
Date: JT'/3
Generator of Byproduct material: URI Vasquez
Controled Elevation used (Cell 3) 5613.04
Area Elevation Transit Shot
Initial shot for trench
Top of trench
Bottom of trench
Initial shot used for material
TOP of material in trench
5609.72
5602.8
5607.22
7.62
10.94
17.86
7.62
13.44
Top of cell 3 Liner 5608.5
Feet below liner 1.28
No.: PBL-10
Rev. No.:R-3.1
Date: June 4,2012
DENISON MINE§ (USA) CORP.
STANDARD OPE^TWti PROCEDURES
Title: 1 le.(i) Byjpro4uct Disposal
Page 10 of 12
ATTACHMENT 2
lle.(2) BYPRODUCT MATEffiALfilSffQML DOCUMENTATION FORM
Date: io\^\i'}
Name of employee receiving the load: ^^rT5 Skde J^S-^S
frenerator of the. TtyproHnrt Material: UgJT- —
Was the State of Utah given notice to the receipt/disposal activities associated with this load?®^ or
No
Who gave and when was lhe notification given?
~T^u>'*AT»sk- ffoh- ; _—'. ;. , , , ,—• :
Description of byproduct material disposal area/activities :
Has each drum been inspected to identify the presence of any void spaces? M>
Have all drums with void spaces been filled with tailings sands or soil? Hft .
Which tailings pell was the material placed in? Cc^lL ~j> .
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?
. w —
Was the material segregated from byproduct material from other ISL sources slisjjosed of in the cell?,
W • — '" " "
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
Was the ISL material segregated from disposed Mill material and other
ISL material?
Refer to plat(s) used to confirm.
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?
Refer to drawings used to confirm
Engineer's or
RSO's Initials
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.
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?
Are additional settlement monitors required to be placed for this generator?
If required, where were settlement markers were placed?
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
Radiological receipt survey measurements:
t-r c^jL- fvn fiTD ^fTs.
Breathing Zone:
1. Was a Breathing Zone Sample collected? Yesor/Ng
2. If yes, what were the results of the sampling?
Was a photograph taken during the unloading activitiesXYe3x)r No
URi URI, INC. STRAIGHT BILL OF LADING FOR
BYPRODUCT MATERIAL
RM License No. L03653 Shipment No. 13VAS-001 Trailer*
Date: 6/04/2013 Seal # n/a
NAME OF CARRIER: Environmental Evolutions DRIVER:
SHIPPER (from) URI, Inc.
STREET 641 E. FM1118
CITY Kingsville STATE Texas ZIP 78363
COUNTRY USA PHONE [phone]
COSIGNEE (to) Energy Fuels- White Mesa Mill
DESTINATION STREET 6425 S. Hwy 191
CITY 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 ^Ra and 230Th ***
PROPER SHIPPING NAME: RADIOACTIVE MATERIAL LS.A 1.
HAZARD CLASS: _7
IDENTIFIpATION NUMBER: UN 2912
WEIGHT: NET £Sy CO/O lbs GROSS 7Pf o*Q lbs
EMERGENCY CONTACTS 24 HOUR ,
CHEMTREC: 800-424-9300 P^^fT^ j ^>>,rxg*r
URI DISTRICT: 361-675-0941 to**1" W'*™
URI HEADQUARTERS: 214-683-8889
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 ISTOOMSIDERED A PACKAGE IN COMPLIANCE WITH 49 CFR 173.427 (c)
Shipper's Signature Date 06/04/2013
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. i ransponauon. A
Driver's SignatureA^ j/
^.-^N^G^EE'g RECIEPT of SHIPMENT
Date 06/04/2013
Cosignee's Signature I
Generator of Byproduct material: Crow Butte
Controled Elevation used (Cell 3) 5613.04
Area Elevation Transit Shot
Initial shot for trench
Top of trench
Bottom of trench
Initial shot used for material
Top of material in trench
5608.2
5603.06
5606.32
7.62
12.46
17.6
7.62
14.34
Top of cell 3 Liner
Feet below liner
5608.5
2.18
No.: PBL-10
Rev.No.:R-3.1
Date: June 4,2012
DENISONMLNES (USA) qOJRP;
STANDARD OPERATING PROCEDURES
title: 11^,(2) ftypupTjiubt Etisjioggl
Page 10 of 12
ATTACHMENTS
1U.(2) BYPRODUCT MATEI-^ FORM
Date; s(-C>l\l
Name of employee receiving the load: (Vl«^-f-
Generator of the ByproductMaterial: ^r^o goHg^ g.<_*_«jr6^
Was the State of Utah giyen notice to the receipt/disposal activities associated witb this load? <^es)br
No ' ' " " r" . ,
Who gave and when was the notification given?
&<wVA Tw>r\c
t M^^j £?t jV ^ — -—n
Description of byproduct rhaterial (li^posal area/activities:
Ve>f -*^r P^il »P fr»jUt ^ r^ir*^l &ar(Lt •; _ ^ .
pL.affaj; -ffAxU ; : , :_y - -;— :
Has each drum been inspected to identify the presence of any void spaces? jA/A
Have all drums with void spaces been filled with tailings sands pr soil? _
Which tailings pell v^as the material placed in? _
Was the material placed on a tailings beach area of the cell of on an area of the ceil 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 &sppse4of inthe 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
Was the ISL material segregated from disposed Mill material and other
ISL material?
Refer to plat(s) used to confirm.
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?
Refer to drawings used to confirm
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.
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?
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: 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 o^o^
2. If yes, what were the results of the sampling?
Was a photograph taken during the unloading activities7^YesJs>r No
Paoe 1 of 1
STRAIGHT BILL OF LADING
ORIGINAL—NOT NEGOTIABLE
Greenfield Logistics. LLC
Date
(Name of Carrier) (SCAC)
on Collect on Delivery shipments, the letters COD must appear before consignee's name or as otherwise provided in Item 430, Sec. 1.
To: Consignee Denison Mines Corp (USA)
Street 6425 S. Hwy 191
City Blanding State UT Zip Code 84511
From: Shipper Crow Butte Resources. Inc.
Street: 86 Crow Butte Rd.
City Crawford State NE Zip Code 69339
24 hr. Emergency Contact Tel. No: [phone]
Route: Vehicle:
Nmber
No. of units &
container type HM Basic Description
Proper Shipping Name, Hazard Class,
Identification Number (UN or NA), Packing Group, per 172.101.172.202,172.203
Total Quantity
(Weight, Volume,
Gallons, etc.)
Weight
(Subject to
Correction)
RATE Charges
(For Carrier
Use Only)
1 roll off XX UN2912, RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY
(LSA-1), HAZARD CLASS 7
30 cubic yards
PHYSICAL FORM: Solid byproduct material
CHEMICAL FORM: NATURAL URANIUM OXIDE U04-2H20
LABELS APPUED: N/A
TRANSPORT INDEX: N/A
ACTIVITY OF SHIPMENT: _8.47x107_Bq
THIS VEHICLE IS ASSIGNED FOR EXCLUSIVE USE OF CAMECO
RESOURCES UNDER PROVISIONS OF 49 CFR 173.427 (a)(vi)
DO NOT LOAD OTHER FREIGHT IN THIS VEHICLE, TRANSFER EN
ROUTE, OR BREAK SEAL
PLACARDS: RADIOACTIVE 7
PLACARDS TENDERED: NO
CBR SHIPMENT #:
Note-fl) Where the rate » dependant on value, shippers are required to state specifically
on writing the agreed or declared value cf the property, as fellows. The agreed or declared
value of the property is hereby specifically stated by the shipper to be not
exceeding per
(2) Where the applicable tariff previsions specify a limitation of the earner's liability absent
a release or a value declaration by the shipper and the shipper does not release the
earner's liability or declare a value, the earner's liability shall be limited to the extent
provided by such provisions. See NMFL Rem 172
(3) Commodities requiring special or additional care or attention in handling or stowing
must be so marked and packaged as to ensure safe transportation See Section 2(e) of
item 360, Bills of Lading, Freight Bills, and Statements of Charges and Section 1(a) of the
Contract terms and conditions tor a list of such articles.
I hereby declare that the contents of this
consignment are fully and accurately
descnbed above by the proper shipping name
and are classified, packaged, marked, and
labeteaV/placard, and are in all respects in
proper condition for transport according to
applicable international and national
governmental regulations.
ON BEHALF OF SHIPPER
Signature
Subject to Section 7 of the ccodBorts If thfo shipment IB to be daflwd to tht cortsigoee wrttout recounc on the consignor, the oonstonor *h>I don the fofcwfcifl list anient* The csnfer etal not msto defray of thb aliment wfthoul payment
of freight and d other tawfuTchwDAt.
(S^rature of Consignor)
COO FEE.
PREPAID •
COLLECT 0 $
TOTAL
CHARGES $
FREIGHT CHARGES
FREIGHT PREPAID Check box charges except when box «l • ara to be •UA IS checked odect
RECEIVED, subject to the classifications and tariffs in effect on the date of issue of this Bill of Lading, the property descnbed above in apparent good order, except as noted (contents and condition of contents of packages unknown), marked, consigned,
and destined as indicated above which said carrier (the word carrier being understood throughout this contract as meaning any person or corporation In possession of this property under the contract) agrees to carry to its usual place of delivery at said
destination. If on its route, otherwise to deliver to another earner on the route to said destination ft is mutually agreed as to each carrier of all or any of, said piopertyciver all or any portion of said route to destination and as to each party at any time
Interested in all or any said property, that every service to be performed hereunder shall be subject to all the bill of lading terms and conditions in the governing classification on the date of the shipment
Shipper hereby certifies that he is familiar with all the lading terms and conditions in the governing classification and the said terms and conditions are hereby agreed to by the shipper and accepted for himself and his assigns
SHIPPER: Crow Butte Resources, Inc. CARRIER: jjreenfield Logistics, LLC
~7M PER: PER:
DATE: DATE:
Generator of Byproduct material: Crow Butte
Controled Elevation used (Cell 3) 5613.04
Area Elevation Transit Shot
Initial shot for trench
Top of trench
Bottom of trench
Initial shot used for material
Top of material in trench
5608.2
5603.06
5606.32
7.62
12.46
17.6
7.62
14.34
Top of cell 3 Liner 5608.5
Feet below liner 2.18
No.: PBL-10
Rev. No.: R-3.1
Date: June 4,2012
DENI30N.MINES PSA) CORP,
STANDARD OPERATII^G PRQdfpURES
Title: 1 le,(2) j|yproriuct pispogai
Page 10 of 12
ATTACBLMENT2
lle.(2) BYPRODUCT MATEB^ FORM
Date: fi/ftt/j^
Name of employee receiving the load: QCAJ^S-
Generator of the Byproduct Material: C-r*->
Was the State of Utah given notice to the receipt/disposal activities associated with this load"? (ies)or
No • ...... " " :''"'r' "•' t \
Who gave and when was the notification given? i
h*.,i.A T^rt.
Peseriptipn of byproduct rr^aterial disposal area/aptiyitie§:
Has each drum been inspected to identify the presence of ajny void spaces? A/P\
Have all drums with void spaces been filled with tailings sands pr sf oil? A/A
Which tailings ppll w,as the majterial j)la,ced in? L\.eJ\ 3> ,
Was the material placed on a tailings beach area of the cell of on an area of the cell fjjat 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 m tke cell?.
No.: PBL-10
Rev.No.:R-3.1
Date: June 4, 2012
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1 ie.(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
Was the ISL material segregated from disposed Mill material and other
ISL material?
Refer to plat(s) used to confirm.
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?
Refer to drawings used to confirm
Is the bottom of each disposal area at least 12 feet from the sides or
dikes of the tailings oell?_j;
Refer to drawings used to confirm.
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?
Was the shipment properly covered?
Ik
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: 1 le.(2) Byproduct Disposal
Page 12 of 12
ALLY.
Radiological receipt survey measurements:
-U4 t^/fV
Breathing Zone:
1. Was a Breathing Zone Sample collected? Yes orjfio)
2. If yes, what were the results of the sampling?
Was a photograph taken during the unloading activities?/!esW No
Page 1 of 1
STRAIGHT BILL OF LADING
ORIGINAL-NOT NEGOTIABLE
Greenfield Logistics. LLC
Date
(Name of Carrier) (SCAC)
on Collect on Delivery shipments, the letters COD must appear before consignee's name or as otherwise
provided in Item 430, Sec 1
To: Consignee Denison Mines Corp (USA)
Street 6425 S. Hwy 191
Citv Blanding State UT Zip Code 84511
From: Shipper Crow Butte Resources. Inc.
Street: 86 Crow Butte Rd.
City Crawford State NE Zip Code 69339
24 hr. Emergency Contact Tel. No: (3081665-1393
Route Vehicle
Nmber
No. of units &
container type HM Basic Description
Proper Shipping Name, Hazard Class,
Idenrtrffcation Number (UN or NA), Packing Group, per 172101,172 202,172 203
Total Quantity
(Weight, Volume,
Gallons, etc)
Weight
(Subject to
Correction)
RATE Charges
(For Camer
Use Only)
1 roll off XX UN2912, RADIOACTIVE MATERIAL, LOW SPECIFIC ACTIVITY
(LSA-1), HAZARD CLASS 7
30 cubic yards
PHYSICAL FORM: Solid byproduct material
CHEMICAL FORM: NATURAL URANIUM OXIDE U04-2H20
LABELS APPUED: N/A
TRANSPORT INDEX: N/A
ACTIVITY OF SHIPMENT: _8.47x107_Bq
THIS VEHICLE IS ASSIGNED FOR EXCLUSIVE USE OF CAMECO
RESOURCES UNDER PROVISIONS OF 49 CFR 173.427 (a)(vi)
DO NOT LOAD OTHER FREIGHT IN THIS VEHICLE, TRANSFER EN
ROUTE, OR BREAK SEAL
PLACARDS: RADIOACTIVE 7
PLACARDS TENDERED:/YESy NO
CBR SHIPMENT #:
Note-(1) Where the rate « dependant on value, shippers are required to state specifically on writing the agreed or declared value of the property, as follows. The agreed or declared
value of the property is hereby specifically stated by the shipper to be not
exceeding per
(2) Where the applicable tariff provisions specify a limitation of the earner's lability absent
a release or a value declaration by the shipper and the shipper does not release the earner's liability or declare a value, the carrier's liability shall be limited to the extent provided by such provisions. See NMFL item 172
(3) Commodities requiring special or additional care or attention in handling or stowing
must be so marked and packaged as to ensure safe transportation See Section 2(e) of item 360, Bills of Lading, Freight Bills, and Statements of Charges and Section 1 (a) of the Contract terms and conditions for a list of such articles.
I hereby declare that the contents of this
consignment are fully and accurately
descnbed above by the proper shipping name and are classified, packaged, marked, and labetedZ/placard, and are in all respects in
proper condition for transport according to
applicable international and national governmental regulations
ON BEHALF OF SHIPPER
Signature
COO Amt$
Subject to Section 7 of the eontatan If IM* Oil—at b to be Mmrad to the consignee wfthout recourse on the consignor, the eorafpw cfitf don nto IUBOVAIQ itvtenivnt' The canter daO not irate deftwy of IM> shipment uihout payment of freight md tl other tiwM charge*.
(Styulure of ContlQnor)
COD FEE
PREPAID •
COLLECT • $
TOTAL
CHARGES $
FREIGHT CHARGES FREIGHT PREPAID Check box If crarge* except when box at 0 en to be right ts chocked coflect
RECEIVED, subject to the classifications and tariffs in effect on the date of issue of this Bill of Lading, the property descnbed above in apparent good order, except as noted (contents and condition of contents of packages unknown), marked, consigned,
and destined as indicated above which said earner (the word earner being understood throughout this contract as meaning any person or corporation in possession of this property under the contract) agrees to carry to its usual place of delivery at said destination, if on its route, otherwise to deliver to another camer on the route to said destination It is mutually agreed as to each earner of all or any of, said property over all or any portion of said route to destination and as to each party at any bme interested in all or any said property, that every service to be performed hereunder shall be subject to all the bill of lading terms and conditions in the governing classification on the date of the shipment
Shipper hereby certifies that he is familiar with all the lading terms and conditions in the governing classification and the said terms and conditions are hereby agreed to by the shipper and accepted for himself and his assigns.
SHIPPER: Crow Butte Resources, Inc. CARRIER: (Gr^enfl^lJagistlbs, LLC
Ms
PER. PER:
DATE: DATE:
t
V
0}
ft
f c
CO
o
CM
c
CD
n n
fi ' \ '
i I .•Vv.. w
* if \
•V M l, 31 » J I J
3-i
• -LP . an
CO
o
CM
c
ZJ —3
CO
mm
;7
4' 3 to
V
-
j -
A*
Lt—
co
Bl
CD
I. r »
3 >.
9
SO V.
^3
• t
*53
t:
Jv.r,
• I
If
V . -1
CD
AS
1
A. '
co
o
CM CD C
war
an*
u4
• m vm:
cev,
K'-.t
4
if
co
o
CM d) C ~D —3
CD
1,
m M -
P^^^fc^v^f
Sty.... g-i-f^
WM i /
1 v.7
co
o
CM
CD
c D —)
CD
mi; ; .v
co
o
CM
0)
c
-5
CD
If $£l
- * mm
• V
CO
o
CN
o
CM
PIP $
i' 1
KfjMW *
Iltl§l
r 2 •1
mm
w 4 -
•H
o
.©
<u
fN
Wi a> o
JN
o
s
to
s-
•I -8 1 6
S 511
Pd
cu O
CD
P^
fl o
<4H
CD O C/3
o
rj
CD -j-j
D u >< ^
o3 O
-a 2
> ©
8 9 CD S
* (2
03 EH CD a
a
3
CQ
o
U
CD _>
•
<
o o
d
CN CN
0>
d
o ©
d
CN
O CN
CD > • ^ -4—I
CD
<
IT)
VO
CN O
o
cn
r>
d
CN o cn
o o
o ©
d r>
B 55 § CD
1 s s
fl i—i
00 -J HH
CD I—J
T3
1
CD > • rt •i—
o
<
o ©
o o
o o
o o
CD
1
CQ
o z
o Q CD I u
CD >
• rt
-t->
CD
<
OO
cn
CN o
CN
ON
V"!
NO O
o o
d r>
IT)
cn
•rj
CN
1 f
a CD 00 o rt
o
Q Xj
CD cj
B e
CD >
• rt
•4->
o
CD >
CD
<
CD >
"+-> CD
CD > • —•i -*-> CD
<
O
in
in
in
m
o o
©
in
CN CN CN
ov
od oo
in
o
vq
cn
ON
O
O
o o
CN
r>
CN
ON OO <<fr
o o o o
o o
in
o o
o
oo
o o
oo
© o
CD >
• rt
-4—>
CD
<
VO
CN
in
ON cn
vo
in
o o
r> o
in
o
vq
ON
ON
CN
CD
O
<
o
in
r>
cn oo
in
o o
d cn
o
r>
on 03 X CD H x:
-rt1
o
00
U
5
00
fl
T3
o3
• rt
"o a
i
u
5
o3 fl o3
00
I
PH
03
—1
u
5
C3 •*->
O
>
CZ) 00
fl
2
5
CD CD
cd
oo
p—I
CD
o
a
N CD fl cr ^
03
> -c? i «
• PH
g *
•—1 00
^ HH HH
PH* 5