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HomeMy WebLinkAboutDRC-2014-001644 - 0901a06880404099Department of Environmental Quality Amanda Smith Executive Director GARY R HERBERT Governor DIVISION OF RADIATION CONTROL Rusty Lundberg Director Spencer J Cox Lieutenant Governor r MEMORANDUM DRC-2014-001644 TO: File C-2014-72 THROUGH: Phil Goble, Section Manager FROM: Russell J. Topham, P.E. DATE: February 12,2014 SUBJECT: Engineering Module 73. Inspection of Disposal of Bulk Byproduct Material January 28, 2014. Radioactive Materials License UT1900479 (License) - Energy Fuels Resources (USA) Inc. (EFR) White Mesa Mill, Blanding, Utah On January 28, 2014,1 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 January 6, 2014. 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 January 6, 2014 the DRC received notice that EFR would receive twenty-one loads of 1 le.(2) byproduct material, and intended to dispose of that waste in Cell 3 on January 28, 2014. Seven loads were ultimately received prior to the commencement of the burial activity. I checked in at the White Mesa mill at 7:40 a.m. on January 28, 2014 and coordinated with mill personnel this inspection and a number of other pieces of reconnaissance other staff members had requested. Soon thereafter I met with Mr. Garrin Palmer and Mr. David Turk, and planned the inspection activities. Mr. Palmer and I proceeded directly to the field to commence the reconnaissance activities while crews gathered the necessary equipment to the disposal site. At about 8:15 a.m. we commenced the disposal operation. Material disposed consisted of: • Soil, with occasional incidental pieces of metal, wood or other debris from URI Incorporated in Kingsville, Texas, shipped by Environmental Evolutions, bearing Shipper Numbers 13KVD-076 and 13KVD-084, (two loads); ) • Soil, with occasional incidental pieces of metal, wood or other debris from URI Incorporated in Kingsville, Texas, shipped by Greenfield Logistics, bearing Shipper Numbers 13KVD-098, 13KVD-099, 13KVD-101, 14KVD-008 and 14KVD-009, (five loads); 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 Printed on 100% recycled paper Page 2 • Drummed waste from South Texas Mining in Hobson, Texas, shipped by Cosby Trucking, bearing Shipper Number UEC Mount (one load); • Drummed waste and loose debris from South Texas Mining in Benavides, Texas, shipped by Cosby Trucking, bearing Shipper Number UEC LU (one load). The bill of lading for each of these loads appears in the attachments to this report. The work crew executed the waste, disposal in one excavation that extended into the tailings sands. I witnessed opening of the excavation, and saw the tailings sand brought to the surface. Solution was exposed at approximately 12 inches below the rim of the excavation. Given the elevation of the solution, I could not directly observe the bottom of the excavation. Mr. Palmer and Mr. Tanner Holliday surveyed the level at the bottom of the excavation prior to waste placement. 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) ofthe RML with respect to the elevation of burial. It appeared that all provisions of the approved disposal SOP were followed during placement and burial ofthe bulk waste. Finding: EFR appears to have followed applicable provisions of the RML and ofthe SOP for the burial operation I observed. Recommendation: I recommend closing out the inspection of January 28, 20J 4. Attachments: Photo log, Receipt Notification January 6, 2014, Bill of Lading and Disposal Documentation for each load disposed on January 28, 2014 -ft-*3/ Photo 1 1 le (2) matenal deposited on the temporary cover near the disposal site Photo taken January 28,2014 Photo 3 Measuring elevations at top and bottom of excavation Photo taken January 28,2014 aws:*-. - , KV'- —-"T _ > 9 » ' - -L •< r"fik Photo 2 Preparing the excavation to receive the byproduct material Photo taken January 28, 2014 f Photo 4 Placing byproduct material in the excavation Photo taken January 28,2014 V \J i £2 Photo 5 Hauling in cover soil Photo taken January 28,2014. Photo 7 Covering the excavation Photo taken January 28,2014 Si •*.3 Photo 6 Hauling in cover soil Photo taken January 28,2014 .is* 2« KM5 IS* 3S r«3s 3*{ 3& 2f5 in lit am "** 23*1 ------ • ~ Photo 8 Grooming Photo taken and I compactmg the cover January 28,2014 Energy Fuels Resources (USA) Inc. 6425 South Highway 191, PO Box 809 Blanding, UT. US, 84511 435 678 2221, fax 435 678 2224 vvww.energyfuels.com January 6,2014 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: 11 e.(2) Byproduct Receipt Notification Pursuant to Radioactive Materials License (RML) UT1900479 condition I0.5.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 twenty one loads of 1 le.(2) byproduct materials by January 28,2014. 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. Regards, David Turk Environmental Health & Safety Manager Energy Fuels Resources (USA) Inc. cc: Denver Central Files ' No.: PBL-10 Rev. No.: R-3.1 *>ate: 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: 1/27/Zo\<\ Name of employee receiving the load: ^C^.^ ftJ Generator of the Byproduct Material: o\LJL K\^^Ui[[c Was the State of Utah given notice to the receipt/disposal activities associated with this load?/tfes\or No Who gave and when was the notification given? b^A- T^K[ \U/i<J Description of byproduct material disposal area/activities: Has each drum been inspected to identify the presence of any void spaces? /t/>4 - Have all drums with void spaces been filled with tailings sands or soil? _ A/A Which tailings cell was the material placed in? n 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? £=C Was the material segregated from byproduct material from other ISL sources disposed of in the cell? -£u (3 £uD - o7£ 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: o Was the material placed in a cell approved by the executive Secretary for ISL waste disposal? /f s Documentation of approval L;ce~*. #<JTV7f f Was the ISL material segregated from disposed Mill material and other ISL material? Refer to plat(s) used to confirm. Cell 3 Ouposaf 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? Yej Refer to drawings used to confirm &ff 3 Dr^r^_ Is the bottom of each disposal area at least 12 feet from the sides or dikes of the tailings cell? fe Refer to drawings used to confirm. Of I 3 fas)" t0*<t^>yj 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) Survey / 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 east 4 times prior to placement of subsequent lifts? Were void spaces filled with tailings? Was the shipment properly covered? Yc.St See od>ni jt^, Are additional settlement monitors required to be placed for this generator? A/Ar ) ; 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 A/A Radiological receipt survey measurements: Breathing Zone: 1. Was a Breathing Zone Sample collected? Yes or< 2. If yes, what were the results of the sampling? Was a photograph taken during the unloading activities?£^es))r No uw URI, INC. STRAIGHT BILL OF LADING FOR BYPRODUCT MATERIAL RM License No. R03653 Shipment No. 13KVD-076 Trailer #279284 Date:y^ ZQ/y Xea\#n/a NAME OF CARRIER: Environmental Evolutions DRIVER: X (U/ftJv 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 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 45.000 lbs. NET 31.083 lbs. GROSS 76.083 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 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 Date CONSIGNEE'S RECIEPT of SHIPMENT Cosignee's Signature Date 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 5605.56 5598.92 5605.76 Top of cell 3 Liner 5608.5 Feet below liner 2.74 : •-'..-v! i MM Uf '-K. hr,; !-3 f ''^ / ' M^ I - i Ni ^"U MIT ];i *M ! 1 • i; • M i i "' ?MMM 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: \Uolw Name of employee receiving the load: /r^rr?^ P^i^cr Generator of the Byproduct Material: t>ZTL \L\u^si>*\ic- Was the State of Utah given notice to the receipt/disposal activities associated with this load^/Yesjpr No Wlio 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? /L».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? —^ 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: o Was the material placed in a cell approved by the executive Secretary for ISL waste disposal? Documentation of approval A/'^e^j^ & tjr/w*7<f A***^ Was the ISL material segregated from disposed Mill material and other ISL material? &r Refer to plat(s) used to confirm. Ce/f 3 Z~ 0,*/&&a / 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? YeS Refer to drawings used to confirm 3 C^&r^h- /%a^>>>^s' Is the bottom of each disposal area at least 12 feet from the sides or dikes of the tailings cell? & Refer to drawings used to confirm, fe// 3 Cos&*- Jja^/yf Will the elevation of the material exceed the plane or grade of the elevation of the uppermost flexible membrane liner of the cell? A/a review) How was this confirmed (e.g., survey or Engineer's or RSO's Initials j2l 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 DENISON MINES (USA) CORP. STANDARD OPERATING PROCEDURES Title: 1 le.(2) Byproduct Disposal Page 12 of 12 A/fc Radiological receipt survey measurements: Breathing Zone: 1. Was a Breathing Zone Sample collected? Yes oi 2. If yes, what were the results of the sampling? Was a photograph taken during the unloading activitiesVies)or No 1 URI URI, INC. STRAIGHT BILL OF LADING FOR BYPRODUCT MATERIAL RM License No. R03653 Shipment No. 13KVD-084 DateX /-/y ^/*/ Trailer #274389 Seal # n/a NAME OF CARRIER: Environmental Evolutions DRIVER: 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 *30Th PROPER SHIPPING NAME: RADIOACTIVE MATERIAL LS.A 1. HAZARD CLASS: _7 IDENTIFICATION NUMBER: UN 2912 WEIGHT: Tare 45.000 lbs. NET 30.615 lbs. GROSS 75.615 lbs. 230i 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 Signaturi X Date \Kt 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. ON Driver's Signature Date i s RECIEPT of SHIPMENT Cosignee's Signature signature Date 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 TOD of material in trench 5605.56 5598.92 5605.76 Top of cell 3 Liner 5608.5 Feet below liner 2.74 I-I, 5 », ,-'1 o } INOU I i AbO? 11*:-' I r ;^" I ( ' ','/'••} Li'i !!' ( I (. ' j , 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: i/i/tom Name of employee receiving the load: r>-^ PeA^es- Generator of the Byproduct Material: pfcj kL;^c»;ll<- Was the State of Utah given notice to the receipt/disposal activities associated with this loadyieaor No Who gave and when was the notification given? 1V^> A Tt^r i (<li*•! Description of byproduct material disposal area/activities: Has each drum been inspected to identify the presence of any void spaces? A/J- - Have all drums with void spaces been rilled with tailings sands or soil? ASA . Which tailings cell was the material placed in? Cr A I 3 Was the material placed on a tailings beach area of the cell or on an area of the cell that was underlain by tailings sands? Was the material segregated from any Mill material or equipment disposed of in the cell? Zci Was the material segregated from byproduct material from other ISL sources disposed of in the cell? &i 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: 3 Was the material placed in a cell approved by the executive Secretary for ISL waste disposal? #3 Documentation of approval l*c*n#: ji uTfrPoifYq yfW*^ Was the ISL material segregated from disposed Mill material and other ISL material? jfe Refer to plat(s) used to confirm. OH 3 'Ar*«~ 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? re Refer to drawings used to confirm QH 3 Co^- jQro^^s Is the bottom of each disposal area at least 12 feet from the sides or dikes of the tailings cell? Refer to drawings used to confirm, f til 3 Co>#t /)/*^>>>q3 Will the elevation of the material exceed the plane or grade of the elevation of the uppermost flexible membrane liner of the cell? SS 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: Lg> y^tLl Hr Breathing Zone: 1. Was a Breathing Zone Sample collected? Yes oi 2. If yes, what were the results of the sampling? Was a photograph taken during the unloading activities?(jfe§jar No URI URI, INC. STRAIGHT BILL OF LADING FOR BYPRODUCT MATERIAL RM License No. R03653 Shipment No. 13KVD-098 Date: X j /; Trailer* GFLU000288 fr/*W Seal # n/a NAME OF CARRIER: Greenfield Logistics DRIVER: X, 7c*vy Q*.^»U*=> 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 *** IDENTIFICATION NUMBER: UN 2912 PROPER SHIPPING NAME: RADIOACTIVE MATERIAL, low specific activity (LSA-l). HAZARD CLASS: J FORM: Solid Oxide ACTIVITY: 0.0008 TBQ SPECIAL INSTRUCTIONS: Do not remove contents without authorization WEIGHT: Tare 44.000 lbs. NET 33.178 lbs. GROSS 77.178 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 matenals are properly classified, described, packaged, marked, placarded and labeled, and are in proper condition for transportation according to the applicable regulations ofthe Department of Transportation. THIS VEHICLE IS CONSIDERED A PACKAGE IN CQMPLIANCBWITH 49 CFR 173.427 (c) Shipper's Signature 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. Camer Signature 1 Date Received Date Relinquished Camer Signature 2 Date Received Date Relinquished Camer Signature 3 Date Received Date Relinquished CONSIGNEE'S RECIEPT of SHIPMENT Cosignee's Signature laiuie t CnyA^- Date 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 5605.56 5598.92 5605.76 5.62 13.1 19.74 5.62 12.9 Top of cell 3 Liner Feet below liner 5608.5 2.74 '\\ '/On/ •< V | I'JO/'/M/ \A') \ 1 ' • ! :i • '1;' S 1-r > i, > i <••!,>:(( No.: PBL-10 <$v. No.: R-3.1 ^ate: 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: )fe/w<{ Name of employee receiving the load: 6arr7A». *?fcl*Hc r Generator of the Byproduct Material: Utl» k,^»v'JltL Was the State of Utah given notice to the receipt/disposal activities associated with this load?<OCss>or No Who gave and when was the notification given? ~D*o?l Twit-. \\tJi*»n Description of byproduct material disposal area/activities: inscription or oypro Set »yU4» /pUj*3 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? N A . Which tailings cell was the material placed in? Ct.i\3 Was the material placed on a tailings beach area of the cell or on an area of the cell that was underlain by tailings sands? 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? )U 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 3 Have the thickness and placement measurements been verified and documented for the disposal area by the engineer, specifically: o Was the material placed in a cell approved by the executive Secretary for ISL waste disposal? Documentation of approval t-'*e«ic $ </r>7^frV/7 A<~+i Was the ISL material segregated from disposed Mill material and other ISL material? Refer to plat(s) used to confirm. *€*-tl 3 2 ftr^**?*/ Ar<t 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? fc* Refer to drawings used to confirm & H 3 So*st' Ora-^i^ Is the bottom of each disposal area at least 12 feet from the sides or dikes of the tailings cell?, Refer to drawings used to conrirm.__£>//_ J /W*/ j)r*~<nqj_ 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? V^3L Set. aJaautz. 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 «fSI£^ 2. If yes, what were the results of the sampling? Was a photograph taken during the unloading activities?f3esx)r No uw URI, INC. STRAIGHT BILL OF LADING FOR BYPRODUCT MATERIAL RM License No. R03653 Shipment No. 13KVD-099 Trailer #GFLU001197 Date n/a NAME OF CARRIER: Greenfield Logistics DRIVER: \! Lt)(L\ Omtft^o/*& SHIPPER (from) URI, Inc. STREET 641 E. FM1118 CITY Kingsville STATE Texas ZIP 78363 COUNTRY USA PHONE 361-595-6731 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 j EXCLUSIVE USE SHIPMENT ***These contents are contaminated with natural uranium and its daughters 226Ra and 230Th *** I IDENTIFICATION NUMBER: UN 2912 ' PROPER SHIPPING NAME: RADIOACTIVE MATERIAL, low specific activity (LSA-0. HAZARD CLASS: J FORM: Solid Oxide ACTIVITY: 0.0008 TBg SPECIAL INSTRUCTIONS: Do not remove contents without authorization WEIGHT: Tare 44.000 lbs. NET 29.243 lbs. GROSS 73.243 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 COMRUANQg WITH 49 CFR 173.427 (c) Shipper's Signature CARRIER'S CERTIFICATION Carrier acknowledges receipt of oarages and required placards. Carrier certifies emergency response information was made available and has the appropnaty^erqej*cv^sponse document in the vehicle. Department of Transportation. Carrier Signature 1 Camer Signature 2 Date Received ate Received Date Relinquished Date Relinquished Carrier Signature 3 Date Received Date Relinquished CONSIGNEE'S RECIEPT of SHIPMENT Cosignee's Signature G, Date hi 1 • ", I'JU I lit,' ! tv'p • i ': A, ; I' h I. KV,0 lii'M i'J'j-ff,^' 'jj j r </OMi ,/ / 'f„ / i ; (/J i /, -HA M / ; 'A('V.U/f j *o 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 5605.56 5598.92 5605.76 Top of cell 3 Liner 5608.5 Feet below liner 2.74 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: 6crt-;^ Generator of the Byproduct Material: OXLZ~ \^l^so7^c Was the State of Utah given notice to the receipt/disposal activities associated with this loadjTYe^ or 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? /SA - Have all drums with void spaces been filled with tailings sands or soil? //A . Which tailings cell was the material placed in? CpJ. 1 3 Was the material placed on a tailings beach area of the cell or on an area of the cell that was underlain by tailings sands? 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: o Was the material placed in a cell approved by the executive Secretary for ISL waste disposal? Documentation of approval #UT 1900*17? /U^y~ Was the ISL material segregated from disposed Mill material and other ISL material? Y*3 Refer to plat(s) used to confirm. &/f 3 Z Dtzpe**//Irr* Lgg> 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? Y<S Refer to drawings used to confirm Ce*t 3 Cor^- 0m STVJ Is the bottom of each disposal area at least 12 feet from the sides or dikes of the tailings cell? Y'5 Refer to drawings used to confirm. ^V// 3 Ce**}. (0™^.^^ 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 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? t±i Was the shipment properly covered? Set. eJpoug. 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 A/A- Page 12 of 12 Radiological receipt survey measurements: PT D-^ Breathing Zone: 1. Was a Breathing Zone Sample collected? Yes or^NO 2. If yes, what were the results of the sampling? Was a photograph taken during the unloading activities?^e|>or No URI URI, INC. STRAIGHT BILL OF LADING FOR BYPRODUCT MATERIAL RM License No. R03653 Shipment No. 13KVD-101 Trailer #GFLU001324 Date:^ /' /Q~3L0/*/ Seal NAME OF CARRIER: Greenfield Logistics DRIVER: &£ f buvyC^Jtt 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. HvVy 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 ^Th IDENTIFICATION NUMBER: UN 2912 PROPER SHIPPING NAME: RADIOACTIVE MATERIAL, low specific activity (LSA-l). HAZARD CLASS: J_ FORM: Solid Oxide ACTIVITY: 0.0008 TBo SPECIAL INSTRUCTIONS: Do not remove contents without authorization . WEIGHT: Tare 44.000 lbs. NET 31.490 lbs. GROSS 75.490 lbs. EMERGENCY CONTACTS 24 HOUR CHEMTREC: 800-424-9300 password: URI URI DISTRICT: 361-331-5585 (Joshua Holland) IIPI MFAHOI IARTFRR- 914-683-8889 (Mark Pelizza^ I CARRIER'S CERTIFICATION Carrier acknowledges receipt of padj&ges available and has the appropriatg^gmergency. fired placards Carrier certifies emergency response information was made ise document in the vehicle. Department of Transportation. Carrier Signature 1 ^ Date Received Date Relinquished Carrier Signature 2 Date Received Date Relinquished Carrier Signature 3 Date Received Date Relinquished CONSIGNEE'S RECIEPT of SHIPMENT Cosignee's Signature Date I 14- 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 Too of material in trench 5605.56 5598.92 5605.76 5.62 13.1 19.74 5.62 12.9 Top of cell 3 Liner Feet below liner 5608.5 2.74 \ > 1 1'.' ' i }i > -. ! r <•> r' > • tit.' ! M 'f .f F H u " ''I 4^6? i ii i 5 1 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 r Date: \\zn\%o\»\ Name of employee receiving the load: /Cc^ri w_ RsJ +**zr Generator of the Byproduct Material: tJtz.Ii fci^s^Mk Was the State of Utah given notice to the receipt/disposal activities associated with this load? (^por No Who gave and when was the notification given? Description of byproduct material disposal area/activities: Eo*>gL Has each drum been inspected to identify the presence of any void spaces? ASA Have all drums with void spaces been filled with tailings sands or soil? S^A Which tailings cell was the material placed in? dL-cA\ 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? Was the material segregated from byproduct material from other ISL sources disposed of in the cell? Li ) 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 Ltcenc & uTi 100*71 Was the ISL material segregated from disposed Mill material and other ISL material? SeJ Refer to plat(s) used to confirm. 3 iU-Z Aspe&i Jjrt-^ 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? /tf Refer to drawings used to confirm *>// -3 Is the bottom of each disposal area at least 12 feet from the sides or dikes of the tailings cell? V^y Refer to drawings used to confirm. Cr// j So-ik flm^^js 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? Yes Was the shipment properly covered? Are additional settlement monitors required to be placed for this generator? ,/f/A 1_ ) 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 A/A Radiological receipt survey measurements: Breathing Zone: 1. Was a Breathing Zone Sample collected? Yes (rif Nj 2. If yes, what were the results of the sampling? Was a photograph taken during the unloading activities?Qfesj>r No URI URI, INC. STRAIGHT BILL OF LADING FOR BYPRODUCT MATERIAL RM License No. R03653 Shipment No. 14KVD-008 Trailer #GFLU001202 Date5<^ | Seal # n/a NAME OF CARRIER: Greenfield Logistics DRIVER: )C 0#Mto€afy? 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 *** IDENTIFICATION NUMBER: UN 2912 PROPER SHIPPING NAME: RADIOACTIVE MATERIAL, low specific activity (LSA-I). HAZARD CLASS: J FORM: Solid Oxide ACTIVITY: 0.0008 TBo SPECIAL INSTRUCTIONS: Do not remove contents without authorization WEIGHT: Tare 44.000 lbs. NET 32.200 lbs. GROSS 76.200 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 COMPJdANCE/wlTH 49 CFR 173.427 (c) Shipper's Signature CARRIER'S CERTIFICATION Carrier acknowledges receipt of pad^eVandprequired placards. Carrier certifies emergency response information was made emdficy/resp available and has the appropria esponse document in the vehicle. Department of Transportation Camer Signature Date Receive Date Received Date Relinquished Carrier Signature 2 Date Relinquished Camer Signature 3 Date Received Date Relinquished Cosignee 's Signature* lj CONSIGNEE'S RECIEPT of SHIPMENT Date I 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 5605.56 5598.92 5605.76 Top of cell 3 Liner 5608.5 Feet below liner 2.74 r,s- " lJ)': m,-r ^c I1'.1 ; r 1 HC' i { ! r TJi .if-i'i i 1 C I'l/. 1- 1 ) . (.) f > MM IT. r [ «t! io-n n , 1 'k ' > ! <i'C 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: i Izg/goH Name of employee receiving the load: fiiLu^r- Generator of the Byproduct Material: oftr tdy^guMk. Was the State of Utah given notice to the receipt/disposal activities associated with this loadTCje^or No Who gave and when was the notification given? 11 d/goH Description of byproduct material disposal area/activities: AE>A.<L MO,W;A,( 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? f^e. 11 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? t±L Was the material segregated from byproduct material from other ISL sources disposed of in the cell? I* 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: o Was the material placed in a cell approved by the executive Secretary for ISL waste disposal? ^ Documentation of approval L<e<tft 4 (<iT A^mS Was the ISL material segregated from disposed Mill material and other ISL material? Refer to plat(s) used to confirm. Cett 3 J/e,2 Q.^ao**/ 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? Y<y Refer to drawings used to confirm 3 /V^A flrtt^iyz Is the bottom of each disposal area at least 12 feet from tne sides or dikes of the tailings cell? &y Refer to drawings used to confirm. Ce // 3 Cotvt- Pr«^. hp' Will the elevation of the material exceed the plane or grade of the elevation of the uppermost flexible membrane liner of the cell? A/& How was this confirmed (e.g., survey or review) Engineer's or RSO's Initials <2L 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? o 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 o^o) 2. If yes, what were the results of the sampling? Was a photograph taken during the unloading activities? Qfes ofr No 4 URI URI, INC. STRAIGHT BILL OF LADING FOR BYPRODUCT MATERIAL RM License No. R03653 Shipment No. 14KVD-009 Trailer* GFLU2191 Seal # n/a NAME OF CARRIER: Greenfield Logistics DRIVER: L*>&t IXivtfMntftZ' SHIPPER (from) URI, Inc. STREET 641 E. FM 1118 CfTY 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 IDENTIFICATION NUMBER: UN 2912 PROPER SHIPPING NAME: RADIOACTIVE MATERIAL, low specific activity (LSA-h. HAZARD CLASS: _7 FORM: Solid Oxide ACTIVITY: 0.0008 TBg SPECIAL INSTRUCTIONS: Do not remove contents without authorization WEIGHT: Tare 44.000 lbs. NET 31.000 lbs. GROSS 75.000 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 COMBLlANCg WITH 49 CFR 173.427 (c) ges er Shipper's Signature CARRIER'S CERTIFICATION and required placards. Carrier certifies emergency response information was made 'sponse document in the vehicle. Department of Transportation, Carrier acknowledges receipt of available and has the appropriat Carrier Signature 1 Carrier Signature 2 2 ' Ve* Date Received Date Received Date Relinquished Date Relinquished Camer Signature 3 Date Received Date Relinquished CONSIGNEE'S RECIEPT of SHIPMENT Cosignee's Signature Signature / Date 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 Too of material in trench 5605.56 5598.92 5605.76 5.62 13.1 19.74 5.62 12.9 Top of cell 3 Liner Feet below liner 5608.5 2.74 i 4. i SO <• I i. Mi'. ' / i / 'M i ).<i .OHO f HO 4 / '\ I /'•:<"' 'C i 4 ^