DRC-2014-006723 - 0901a068804b9d95

11/17/2014 State of Utah Mail - FW Revision
Russell Topham <[e-mail]>
FW: Revision
1 message
Kathy Weinel <[e-mail]>
To: Russell Topham <[e-mail]>
DRC-2014-006723
Mon, Nov 17, 2014 at 7 51 AM
Russ,
Attached is the redhne revision of the SOP pursuant to your inspection
Please let me know if you need any other changes.
CF Energy Fuels Resources (USA) Inc
Kathy We<nel
t .103-389-4134 |f 303-389-4125
225 Union Blvd , Suite 600
Lakewood, CO, US, 80228
http .'Vwwvv energy-fuels com
This e-mail is intended for the exclusive use the of person(s) mentioned as the recipient(s). This message and
any attached files with it are confidential and may contain privileged or proprietary information If you are not the
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this message if you are not the intended recipient(s).
From: David Turk
Sent: Thursday, November 13, 2014 1:24 PM
To: Kathy Weinel
Subject: Revision
https//mail google com/mail/u;0/?ui=2&ik=3744873c9a&view=pt&se 1/2
11/17/2014 State of Utah Mail - FW Revision
Here you go.
Energy Fuels Resources (USA) Inc
David Turk
t 435-678-2221 x1 13 | c 435-459-9786 | f 435-678-2224
6425 S Highway 191 PO Box 809
Blanding, UT, US, 84511
"lttp //www energyfuels com
This e-mail is intended for the exclusive use the of person(s) mentioned as the recipient(s). This message and any attached files with it are
confidential and may contain pnvileged or propnetary information If you are not the intended recipient(s) please delete this message and
notify the sender You may not use, distribute pnnt or copy this message if you are not the intended recipient(s)
2 attachments
EFR 11e2 SOPs rev 3.3 clean.doc
94K
EFR 11e2 SOPs rev 3.3 redline.doc
94K
https //mail gcoglecom/mail/u/0/?ui=2&ik=3744873c9a&view=pt&s^
No.: PBL-10
Rev. No.: R-3.23
Date: January 22,
3ft44November 13.
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page I of 13
1.0 Purpose
Energy Fuels Resources (USA) Inc. ("EFR") receives 11 e.(2) byproduct material ("byproduct
material") from uranium in-situ leach operations for disposal under License Condition 10.5. The
following procedure applies to acceptance, handling, and disposal of byproduct material at the White
Mesa Mill (the "Mill").
2.0 Prior to Shipment of Byproduct Material
All byproduct material must be approved for disposal by the Mill Radiation Safety Officer ("RSO"), or
his designee, prior to shipment to the Mill. The byproduct material must conform to Titles 10 and 49
of the U.S. Code of Federal Regulations ("CFR") and the Shipper must certify that the byproduct
material does not contain hazardous waste as defined in the Resource Conservation and Recovery Act
("RCRA").
Information regarding the byproduct material to be disposed of should be received prior to receipt of
the shipment at the Mill, and shall include:
1. The volume of material in cubic feet or yards, or quantity of drums and their size.
2. A description of the material (e.g. sludge, process materials, filter media, pipe, etc.)
3. A description of the shipping container (i.e. end dump trailer, intermodal container, side dump
container, etc.)
4. Results of analysis for U-Nat, Ra-226, Th-230 and Pb-210 on all sludges and soils and other
material that is suited to sample collection. If a representative sample of the material was
taken in connection with a previous shipment of material, then the results of that previous
representative sample may be relied upon, and may be referred to or restated in the
documentation that accompanies the shipment of the material. For byproduct material which
is not suited to sample collection (i.e. metals, process equipment, filter media, pipes, etc.) the
Shipper will determine the range, the average and the total activity, measured in millirem/hour
(mr/hr) at a range of one meter, for each shipment.
5. A copy of the completed shipping manifest that will accompany the shipment and the
anticipated shipping date.
The Environmental Coordinator or their designee will verify, prior to receipt of any shipment of
byproduct material, that the disposal of such byproduct material will not cause the Mill to exceed the
limit of 5,000 cubic yards of byproduct material from a single source, set out in Mill License condition
10.5 A
3.0 Designated Disposal Area
The Environmental Coordinator, or their designee will designate from time to time one or more
designated disposal areas (each a "Designated Disposal Area") being a general area within a tailings
No.: PBL-10
Rev. No.: R-3.23
Date: January 22,
2WNovember 13.
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 2 of 13
cell for the disposal of byproduct material. Each Designated Disposal Area must meet the following
criteria:
1. The Designated Disposal Area must be in an active tailings cell (i.e., a tailings cell that is not
fully covered with interim cover);
2. The Designated Disposal Area must be on a tailings beach area of the cell or on an area of the
cell that is underlain by tailings sands;
3. There must be at least 4 feet of tailings sands under the Designated Disposal Area;
4. The Designated Disposal Area must be located at least 12 feet from the sides or dikes of the
tailings cell;
5. Survey information or other document review will be maintained to confirm that the elevation
of the Designated Disposal Area once filled with byproduct material must not exceed the plane
or grade of the elevation of the uppermost flexible membrane liner of the tailings cell;
6. Detailed engineering drawings must have been prepared and kept on file at the Mill that
demonstrate for each Designated Disposal Area that:
a) There are at least 4 feet of tailings sands under the bottom of the Designated Disposal Area;
and
b) The bottom of the Designated Disposal Area is located at least 12 feet from the sides or dikes
of the tailings cells; and
c) Each disposed ISL byproduct material has been segregated from any mill material and
equipment disposed of in the cells and the ISL byproduct material from each in-situ leach
source will be segregated from the byproduct material from all other in-situ leach sources;
7. ISL wastes will be disposed in cells that have received prior written approval from the Director
for this purpose.
8. Prior written approval must have been obtained from the Director of the Utah Radiation
Control Board (the "Director") for each Designated Disposal Area, under Mill License
condition 10.5C, and evidence of such approval must be on file at the Mill.
9. Byproduct material from each ISL facility is disposed in Designated Disposal Areas specific to
that ISL facility. Designated Disposal Areas include either trench areas or tailings beach areas.
The procedures for placement are not dependant on which area the byproduct material is placed
in. The above procedures are the same for both trench areas and tailings beach areas.
No.: PBL-10
Rev. No.: R-3.23
Date: January 22,
2WNovember 13
2014
ENERGY FUELS RESOURCES (USA) INC
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 3 of 13
4.0 Notification to Director
EFR shall notify the Director in writing at least 7 calendar days prior to the proposed scheduled date
for disposal of any byproduct material. Written evidence of this notification will be kept on file at the
Mill.
5.0 Byproduct Material Receiving
1. When each truck driver enters the restricted area for the first time, the scale house operator
will provide hazard training for the driver. The driver will be provided with the Safety
Training Form (Attachment 1). All drivers will be required to read the Safety Training Form
and sign and date the Safety Training Form indicating that they understand and agree to follow
EFR's safety rules and procedures while on company property. The scale house operator will
sign the Safety Training Form as the instructor for EFR. Completed Safety Training Forms
will be turned in to the Safety Department for future reference.
2. The onsite transportation expert shall inspect all copies of the Shipping Manifest and the
transporter's Bill of Lading to ensure that the shipment is destined for the Mill and confirm
with the Environmental Coordinator, or their designee that the shipment has been approved for
receipt.
3. Record the inbound date and both the truck and trailer numbers on the Scale house Weight
Ticket (SWT).
4. Enter the loaded weight of the truck and trailer on the SWT.
5. The scale house operator will contact the Environmental Department so that the shipment can
be escorted by Environmental personnel to the Designated Disposal Area specified by the
Environmental Coordinator.
Prior to transporting material to the Designated Disposal Area (pending on weather), the driver
will be instructed to open or untarp the load. The Environmental personnel and the
transportation expert will visually inspect, to the degree possible, the byproduct material to
ensure that the material matches the material description on the shipping manifest. Any
discrepancies between the byproduct material received and the manifest information will be
reported to the Environmental Coordinator.
a. Any byproduct material suspected of not conforming to Section 2.0 of this SOP will
not be transported to the disposal site, unless a determination is made by the
Environmental Coordinator that the material in question conforms to Section 2.0 of
this SOP.
b. Barrels containing soil or sludges shall be checked to determine if they are full prior
to transporting them for disposal. Barrels not completely full shall be documented
and shall be filled with tailings or soil prior to disposal. (License Condition 10.5.B).
No.: PBL-10
Rev. No.: R-3.23
Date: January 22,
3Q44November 13.
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 le (2) Byproduct Disposal
Page 4 of 13
c. If weather conditions exist that makes the opening of the conveyance impossible at
the untarping station, the Environmental personnel may take the conveyance to a
suitable location in which to inspect the load. A suitable location will be one where
the load may be viewed where employees are safely out of the way when the
conveyance doors are opened and where if material was to fall out of the
conveyance, that contamination issues will not be incurred. An example area could
the tails impound area near the disposal site.
6.0 Byproduct Material Unloading
1. The Environmental Coordinator will specify the specific location within the broader
Designated Disposal Area for disposal of the shipment. In designating the specific location
within the broader Designated Disposal Area for disposal of the shipment, the Environmental
Coordinator will ensure that all byproduct material will be segregated from any Mill material
and equipment disposed of in the cell pursuant to Mill license condition 10.4, and that the
byproduct material from each ISL source will be segregated from the byproduct material from
all other ISL sources.
2. Environmental personnel will escort the shipment to the designated location in the Designated
Disposal Area for unloading of the byproduct material.
3. Proposed Methods and Procedures to Fully Protect the Liner While Accessing Tailings
Cells for Disposal of ISL Byproduct Material and Mill Equipment
a. The shipment will be transported to the Designated Disposal Area only on established
roadways onto the tailings cells.
b. At no time will a shipment be transported over or in a manner that will damage
unprotected dikes, liners, other structures or settlement monitors associated with any of the
tailings cells.
c. There must be at least 4 feet of tailings sands under the Designated Disposal Area
(documentation of the disposal area must be completed and on file prior to any disposal
activities);
d. The Designated Disposal Area must be located at least 12 feet from the sides or dikes of
the tailings cell (documentation of the disposal area must be completed and on file prior to
any disposal activities);
e. No travel into the disposal area will be allowed unless the disposal cell liner is covered
by at least 18 inches of soil or fill material at the point of access.
4. If the 7 calendar day notice referred to in Section 4.0 above has not been given, or the 7 days
have not lapsed, then the shipment may be, but is not required to be contained in the shipping
container (that is, the container-bin or trailer) on site until the required 7 day notice has been
given and the 7 calendar days have lapsed.
5. If the shipment is determined to be acceptable, the following procedures will be followed:
a) If the 7-day notice has been given under Section 4.0 above and the 7 calendar days have lapsed,
No.: PBL-10
Rev. No.: R-3.23
Date: January 22,
2WNovember 13.
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 11 e.(2) Byproduct Disposal
Page 5 of 13
the byproduct material will then be unloaded in the designated area. If such notice has not been
given or if such 7 day period has not lapsed, then the byproduct material will be unloaded in an
area of the tailings cell that is not covered with interim cover and from which the material can
be removed if necessary. Once the required notice has been given and the required 7 days have
lapsed, the byproduct material will then be placed into the designated area.
b) If the material is in a self-unloading container, the driver will be instructed to unload ensuring
all personnel are clear of the trailer and the immediate area. Byproduct material will be
dumped from the transport in a safe manner to minimize dust. If the material requires
unloading by a fork truck, a ramp will be installed and unloading will proceed.
c) After unloading, the Environmental personnel will visually inspect the unloaded byproduct
material to ensure that there is no newly discovered material which does not match the material
description on the shipping manifest. Any discrepancies between the byproduct material
received and the manifest information will be reported to the Environmental Coordinator. Any
byproduct material suspected of not meeting the requirements set forth in Section 2.0 of this
SOP will be kept segregated from other waste material until a determination is made of its
acceptability for disposal.
d) After unloading, a photo of the unloaded material will be taken which is attached to the
shipping documentation for verification of shipment contents.
e) The location of the shipment of the byproduct material will be documented on the plat of each
Designated Disposal Area illustrating the disposal area within the Designated Disposal Area
where the byproduct material will be disposed of.
f) Beta-gamma measurements will be taken at several locations around the unloaded material.
This information will be recorded on the Radiation Department's copy of the shipment
documentation. The measurement range in mrem/hr at 2 meters, and the average measurement,
measured in mrem/hr at 2 meters, shall be recorded.
g) Measurements using a photoionization detection meter ("PID") will be taken at several
locations around the unloaded material to ensure that there are no organics present. The
information will be recorded on the Environmental Department's copy of the shipment
documentation. If organics are detected, the Environmental Coordinator must be advised, and
no compaction or covering activities relating to the shipment shall occur until specifically
instructed by the Environmental Coordinator. The Environmental Coordinator and Safety
Coordinator will determine if any additional safety precautions are required to be taken by
workers or otherwise as a result of the detection of the organics, and will implement any such
precautions. The Environmental Coordinator will also contact EFR corporate regulatory
personnel and the shipper to verify that the detected organics are lle.(2) byproduct material
from the shipper's ISL facility. Once the Environmental Coordinator has verified that the
organics are byproduct material compaction and covering activities will proceed.
h) A breathing zone sample will be taken periodically during unloading and cover activities. If
the gross alpha exceeds 25% of the applicable DAC, then the RSO will be notified, and all
other unloading activities of byproduct material from that particular ISL site will require the
No.: PBL-IO
Rev. No.: R-3.23
Date: January 22,
2Q4^November 13.
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 6 of 13
use of respiratory protection, until further notice by the RSO.
i) After unloading the byproduct material, replace the tarp or close the trailer, unless the trailer is
being decontaminated for unrestricted release.
j) Direct the driver back to the scales for an empty weight.
k) The scale house operator will record the empty weight on the appropriate SWT.
1) Shipment and disposal activities will be documented as described in Section 10, below.
7.0 Covering of Byproduct Material
1. After the byproduct material has been accepted by the Environmental Coordinator, or their
designee, the byproduct material will be spread within the designated area within the
Designated Disposal Area to facilitate compaction and covering.
2. The byproduct material will be compacted with at least four passes of the construction
equipment prior to placing an additional layer.
3. Free volumes in the byproduct material will be minimized by filling, sectioning, or crushing.
Random fill or tailings sands will be used to fill voids in and around the byproduct material.
4. All contaminated equipment shall be dismantled, crushed, or sectioned to minimize void
spaces. Barrels containing waste other than soil or sludges shall be emptied into the disposal
area and the barrels crushed. Barrels containing soil or sludges shall be verified to be full prior
to disposal. Barrels not completely full shall be filled with tailings or soil.
5. A one foot thick, or thicker, cover comprised of native soil will be placed over the byproduct
material working area. The fill and cover material will be compacted with at least one pass of
the construction equipment.
6. The Environmental Coordinator or their designee will inspect the placement of the byproduct
material prior to covering to physically verify that the procedures in this Section 7.0 have been
adequately performed.
8.0 Decontamination and Release of Trailers and Trucks
All trailers and trucks will be decontaminated after unloading prior to leaving the Mill. Shippers
or transporters will notify EFR whether a specific trailer is to be released for restricted or unrestricted
use. Any trailers that are to be released for restricted use will be decontaminated according to the
requirements contained in DOT Part 49 CFR 173.441(b) and 173.443. Any trailers that are to be
released for unrestricted use will be decontaminated according to the requirements found in Table 1 of
the Nuclear Regulatory Commission's (NRC's) Policy and Guidance Directive FC-85-23, "Guidelines
No.: PBL-10
Rev. No.: R-3.23
Dale: January 22,
204^November 13.
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 7 of 13
for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination
of Licenses for Byproduct, Source, or Special Nuclear Material" issued May 1987. Trailers requiring
repair will be decontaminated for unrestricted release, to facilitate repairs by the transporter at the
transporter's own site. Trailers may be repaired without undergoing full decontamination if repaired
within the restricted area of the Mill.
For the appropriate decontamination procedures, refer to the following Standard Operating Procedures
for the appropriate conveyance:
End Dump Trailer SOP PBL-9
Intermodal Container SOP PBL-2
Standard Container Trailer SOP-PBL-2
9.0 Hazard Identification and Safety
1. Required Personal Protective Equipment (PPE)
In all areas of the Mill covered by this procedure, hard hats, safety glasses and steel-toed shoes
are required at a minimum. These must be worn in the restricted area of the Mill. Prior to
disposal, the RSO will determine what level of respiratory protection, if any, will be required.
2. Industrial Hazards and Safety
c) Use caution when the trailers are backing to the unloading area.
d) Ensure that all personnel within 50 feet of the area where an end dump trailer is about to dump
its load are aware that unloading is about to commence. Move at least 25 feet away from the
rear of the trailer during the initial unloading operation.
e) Drivers must use caution during the unloading process and be aware of any overhead hazards.
0 Do not place any part of your body inside the trailer when the trailer is being tipped and the
tailgate is open. Only work around the tailgate after it has been properly blocked open.
g) Use caution when entering or exiting equipment. Be sure to use the ladders and hand rails. Do
not jump off the equipment.
h) Always use a ladder when entering and/or exiting the interior of a trailer.
3. Mobile Equipment
a) Only trained and authorized persons may operate mobile equipment.
b) All mobile equipment shall be inspected by the operator and any safety defects corrected before
the equipment is used. If safe to do so, the equipment may be driven to the shop for repairs.
Otherwise, the equipment must be towed or repaired at the location.
No.: PBL-10
Rev. No.: R-3.23
Date: January 22,
2WNovember 13.
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: I le (2) Byproduct Disposal
Page 8 of 13
c) Audible backup alarms shall be in operating condition.
d) Walk around any piece of equipment before starting or moving it. Make certain no one is in a
dangerous position and there are no obvious defects or hazards.
e) Use caution when entering or exiting equipment. Be sure to use the ladders and hand rails. Do
not jump off the equipment.
f) Seat belts shall be used at all times when equipment is in motion.
g) Equipment shall be operated at a reasonable speed consistent with road and weather conditions,
subject to a maximum speed limit of 15 mph.
h) Keep the cabs of equipment clean. Loose items that could jam controls or create other hazards
are not allowed.
i) Report all accidents to your supervisor regardless of how minor they are. If property damage
or personal injury is involved, do not move the equipment until your supervisor has released it.
j) All gasoline engines must be shut off when refueling.
k) Keep equipment clear of edges, drop offs, and unstable banks. Maintain adequate berms where
required.
10.0 Documentation
1. a) Documentation of Shipments
For each shipment of byproduct material the following records will be maintained in the Mill's
Environmental Department files:
• Shipper's Manifest and Bill of Lading.
• Laboratory/activity analysis of the byproduct material performed by the Shipper.
• Completed SWT.
• 7-day notice to Director.
• Photo of the byproduct material.
• Byproduct material radiological scan information.
• Breathing zone monitoring data, if applicable.
• Equipment release forms.
All documents and photographs should be dated and the Shipper's Manifest and or Bill of* {FormattedTindent: First line: o"
Lading number indicated on the document
b) Documentation of Disposal
No.: PBL-10
Rev. No.: R-3.23
Date: January 22,
2frBNovember 13.
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 9 of 13
Byproduct material disposal will be documented on the Disposal Documentation Form
provided in Attachment 2. Attachment 2 may be accompanied by photographs, a written
description or both. Attachment 2 or other written description will include:
• How the material was placed in the tailing cells;
• If void spaces in the drums/barrels containing soil or sludge were filled with tailings
sands;
• How the area was compacted;
• Document that materials placed on tailings are no more than 4 feet thick and
subsequent lifts no more than 2 feet thick (this information will be obtained for each
ISL disposal area and maintained by the engineering department);
• Document that there are 4 feet of tailings under the bottom of each disposal area and
the bottom of each disposal area is located at least 12 feet from the sides or dikes of
the tailings area this information will be obtained for each ISL disposal area and
maintained by the engineering department);
• Document that the elevation of the material will not exceed the plane or grade of the
elevation of the uppermost flexible membrane liner of the cell.
• Confirmation that the shipment was properly covered; and
• Where settlement markers were placed. The Mill will maintain a plat of each
Designated Disposal Area, which illustrates the location of each shipment of
byproduct material.
The Mill will maintain on file a copy of the Director's written approval of each Designated
Disposal Area.
-An annual summary of the amounts of byproduct material disposed of in each calendar year
shall be sent to the Director on or before November 1 of the calendar year. (License Condition
10.5F). [summary due same year]
11.0 Training
An annual basis, all onsite personnel that are involved in the receiving or disposing of-
this material shall be trained in the activities associated with this procedure. This training shall
be documented and maintained on file.
Formatted: Indent: Left: 0.5", No bullets or
numbering
Formatted: Outline numbered + Level: 1 +
Numbering Style: 1, 2, 3,... + Start at: 1 +
Alignment: Left + Aligned at: 0" + Tab after:
0.5" + Indent at: 0.5"
Formatted: Indent: Left: 0.5",
numbering
No bullets or
Formatted: No bullets or numbering
Formatted: Justified, Indent: Left: 2", First
line: 0.5"
No.: PBL-10
Rev. No:: R-3.23
Date: January 22,
26+3November 13.
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 11 e.(2) Byproduct Disposal
Page 10 of 13
ATTACHMENT 1
SAFETY TRAINING FOR DELIVERY PERSONNEL
Welcome to Energy Fuels Resources (USA) Inc.'s, White Mesa Mill. In order to assure your safety
while on our property, we would like to acquaint you with the safety rules and procedures, which you
will be required to follow while on our property.
1.0 General Safety
1. Approved hard hats and safety glasses are required at all times except when inside the cab of
your truck.
2. This is a smoke free facility. No smoking is allowed on the property. Eating anything,
drinking, chewing candy, gum or tobacco is also not allowed in the Mill Restricted Area due
to radiation hazards.
3. Maintain a safe speed at all times when driving in the Mill Restricted Area. The maximum
speed limit is posted at 15 mph Energy Fuels Resources (USA) Inc.'s equipment has the right
of way on the ore pad and Mill roadways.
4. Be aware of the possibility of a truck turning over while dumping. Ensure that the truck is on
level ground and brakes are set prior to dumping.
5. Check for potential overhead hazards prior to dumping.
6. If material is hung up in the trailer bed, it is not permissible to work in the bed while it is in the
dump position. If it is necessary to get in the bed of the trailer to free a hang up, the bed must
be lowered.
7. Be aware of slippery conditions on the ore pad during periods of inclement weather.
8. Be aware of the potential for ice build-up on and around the decontamination pad during
periods of cold weather.
9. Use caution when entering or exiting equipment.
2.0 Radiation Safety
1. All drivers are required to scan for alpha radiation prior to leaving the Mill Restricted Area.
2. All equipment, i.e. trucks and trailers, will be scanned for radiation prior to leaving the Mill's
Restricted Area.
Driver (Printed) Scale House Operator
Driver (Signature) Date
No.: PBL-10
Rev. No.: R-3.23
Date. January 22,
2Q4Wovember 13.
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 11 of 13
ATTACHMENT 2
1 le.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date:
Name of employee receiving the load:
Generator of the Byproduct Material: _
Shipper's Manifest or Bill of Lading number:
Was the State of Utah given notice to the receipt/disposal activities associated with this load? Yes or
No
Who gave and when was the notification given?
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?
Which tailings cell was the material placed in?
Was the material placed on a tailings beach area of the cell or on an area of the cell that was underlain
by tailings sands?
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-3.23
Date: January 22,
20J4November 13.
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 12 of 13
Manifest or BOL #:
Have the thickness and placement measurements been verified and documented for the disposal area
by the engineer, specifically:
Engineer's or
Environmental
Coordinator's
Initials
Was the material placed in a cell approved by the executive Secretary
for ISL waste disposal?
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 cell?
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 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?
No.: PBL-10
Rev. No.: R-3.23
Date: January 22,
2WNovember 13.
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 11 e.(2) Byproduct Disposal
Page 13 of 13
IV anifest or BOL #:
Are additional settlement monitors required to be placed for this generator?
If required, where were settlement markers were placed?
Radiological receipt survey measurements:
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? Yes or No
No.: PBL-10
Rev. No.: R-3.3
Date: November 13,
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 1 of 13
1.0 Purpose
Energy Fuels Resources (USA) Inc. ("EFR") receives lie.(2) byproduct material ('"byproduct
materiar) from uranium in-situ leach operations for disposal under License Condition 10.5. The
following procedure applies to acceptance, handling, and disposal of byproduct material at the White
Mesa Mill (the "Mill").
2.0 Prior to Shipment of Byproduct Material
All byproduct material must be approved for disposal by the Mill Radiation Safety Officer ("RSO"), or
his designee, prior to shipment to the Mill. The byproduct material must conform to Titles 10 and 49
of the U.S. Code of Federal Regulations ("CFR") and the Shipper must certify that the byproduct
material does not contain hazardous waste as defined in the Resource Conservation and Recovery Act
("RCRA").
Information regarding the byproduct material to be disposed of should be received prior to receipt of
the shipment at the Mill, and shall include:
1. The volume of material in cubic feet or yards, or quantity of drums and their size.
2. A description of the material (e.g. sludge, process materials, filter media, pipe, etc.)
3. A description of the shipping container (i.e. end dump trailer, intermodal container, side dump
container, etc.)
4. Results of analysis for U-Nat, Ra-226, Th-230 and Pb-210 on all sludges and soils and other
material that is suited to sample collection. If a representative sample of the material was
taken in connection with a previous shipment of material, then the results of that previous
representative sample may be relied upon, and may be referred to or restated in the
documentation that accompanies the shipment of the material. For byproduct material which
is not suited to sample collection (i.e. metals, process equipment, filter media, pipes, etc.) the
Shipper will determine the range, the average and the total activity, measured in millirem/hour
(mr/hr) at a range of one meter, for each shipment.
5. A copy of the completed shipping manifest that will accompany the shipment and the
anticipated shipping date.
The Environmental Coordinator or their designee will verify, prior to receipt of any shipment of
byproduct material, that the disposal of such byproduct material will not cause the Mill to exceed the
limit of 5,000 cubic yards of byproduct material from a single source, set out in Mill License condition
10.5A
3.0 Designated Disposal Area
The Environmental Coordinator, or their designee will designate from time to time one or more
designated disposal areas (each a "Designated Disposal Area") being a general area within a tailings
No.: PBL-10
Rev. No.: R-3.3
Date: November 13,
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 2 of 13
cell for the disposal of byproduct material. Each Designated Disposal Area must meet the following
criteria:
1. The Designated Disposal Area must be in an active tailings cell (i.e., a tailings cell that is not
fully covered with interim cover);
2. The Designated Disposal Area must be on a tailings beach area of the cell or on an area of the
cell that is underlain by tailings sands;
3. There must be at least 4 feet of tailings sands under the Designated Disposal Area;
4. The Designated Disposal Area must be located at least 12 feet from the sides or dikes of the
tailings cell;
5. Survey information or other document review will be maintained to confirm that the elevation
of the Designated Disposal Area once filled with byproduct material must not exceed the plane
or grade of the elevation of the uppermost flexible membrane liner of the tailings cell;
6. Detailed engineering drawings must have been prepared and kept on file at the Mill that
demonstrate for each Designated Disposal Area that:
a) There are at least 4 feet of tailings sands under the bottom of the Designated Disposal Area;
and
b) The bottom of the Designated Disposal Area is located at least 12 feet from the sides or dikes
of the tailings cells; and
c) Each disposed ISL byproduct material has been segregated from any mill material and
equipment disposed of in the cells and the ISL byproduct material from each in-situ leach
source will be segregated from the byproduct material from all other in-situ leach sources;
7. ISL wastes will be disposed in cells that have received prior written approval from the Director
for this purpose.
8. Prior written approval must have been obtained from the Director of the Utah Radiation
Control Board (the "Director") for each Designated Disposal Area, under Mill License
condition 10.5C, and evidence of such approval must be on file at the Mill.
9. Byproduct material from each ISL facility is disposed in Designated Disposal Areas specific to
that ISL facility. Designated Disposal Areas include either trench areas or tailings beach areas.
The procedures for placement are not dependant on which area the byproduct material is placed
in. The above procedures are the same for both trench areas and tailings beach areas.
No.: PBL-10
Rev. No.: R-3.3
Date: November 13,
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 11 e.(2) Byproduct Disposal
Page 3 of 13
4.0 Notification to Director
EFR shall notify the Director in writing at least 7 calendar days prior to the proposed scheduled date
for disposal of any byproduct material. Written evidence of this notification will be kept on file at the
Mill.
5.0 Byproduct Material Receiving
1. When each truck driver enters the restricted area for the first time, the scale house operator
will provide hazard training for the driver. The driver will be provided with the Safety
Training Form (Attachment 1). All drivers will be required to read the Safety Training Form
and sign and date the Safety Training Form indicating that they understand and agree to follow
EFR's safety rules and procedures while on company property. The scale house operator will
sign the Safety Training Form as the instructor for EFR. Completed Safety Training Forms
will be turned in to the Safety Department for future reference.
2. The onsite transportation expert shall inspect all copies of the Shipping Manifest and the
transporter's Bill of Lading to ensure that the shipment is destined for the Mill and confirm
with the Environmental Coordinator, or their designee that the shipment has been approved for
receipt.
3. Record the inbound date and both the truck and trailer numbers on the Scale house Weight
Ticket (SWT).
4. Enter the loaded weight of the truck and trailer on the SWT.
5. The scale house operator will contact the Environmental Department so that the shipment can
be escorted by Environmental personnel to the Designated Disposal Area specified by the
Environmental Coordinator.
6. Prior to transporting material to the Designated Disposal Area (pending on weather), the driver
will be instructed to open or untarp the load. The Environmental personnel and the
transportation expert will visually inspect, to the degree possible, the byproduct material to
ensure that the material matches the material description on the shipping manifest. Any
discrepancies between the byproduct material received and the manifest information will be
reported to the Environmental Coordinator.
a. Any byproduct material suspected of not conforming to Section 2.0 ofthis SOP will
not be transported to the disposal site, unless a determination is made by the
Environmental Coordinator that the material in question conforms to Section 2.0 of
this SOP.
b. Barrels containing soil or sludges shall be checked to determine if they are full prior
to transporting them for disposal. Barrels not completely full shall be documented
and shall be filled with tailings or soil prior to disposal. (License Condition 10.5.B).
No.: PBL-10
Rev. No.: R-3.3
Date: November 13,
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 4 of 13
c. If weather conditions exist that makes the opening of the conveyance impossible at
the untarping station, the Environmental personnel may take the conveyance to a
suitable location in which to inspect the load. A suitable location will be one where
the load may be viewed where employees are safely out of the way when the
conveyance doors are opened and where if material was to fall out of the
conveyance, that contamination issues will not be incurred. An example area could
the tails impound area near the disposal site.
6.0 Byproduct Material Unloading
1. The Environmental Coordinator will specify the specific location within the broader
Designated Disposal Area for disposal of the shipment. In designating the specific location
within the broader Designated Disposal Area for disposal of the shipment, the Environmental
Coordinator will ensure that all byproduct material will be segregated from any Mill material
and equipment disposed of in the cell pursuant to Mill license condition 10.4, and that the
byproduct material from each ISL source will be segregated from the byproduct material from
all other ISL sources.
2. Environmental personnel will escort the shipment to the designated location in the Designated
Disposal Area for unloading of the byproduct material.
3. Proposed Methods and Procedures to Fully Protect the Liner While Accessing Tailings
Cells for Disposal of ISL Byproduct Material and Mill Equipment
a. The shipment will be transported to the Designated Disposal Area only on established
roadways onto the tailings cells.
b. At no time will a shipment be transported over or in a manner that will damage
unprotected dikes, liners, other structures or settlement monitors associated with any of the
tailings cells.
c. There must be at least 4 feet of tailings sands under the Designated Disposal Area
(documentation of the disposal area must be completed and on file prior to any disposal
activities);
d. The Designated Disposal Area must be located at least 12 feet from the sides or dikes of
the tailings cell (documentation of the disposal area must be completed and on file prior to
any disposal activities);
e. No travel into the disposal area will be allowed unless the disposal cell liner is covered
by at least 18 inches of soil or fill material at the point of access.
4. If the 7 calendar day notice referred to in Section 4.0 above has not been given, or the 7 days
have not lapsed, then the shipment may be, but is not required to be contained in the shipping
container (that is, the container-bin or trailer) on site until the required 7 day notice has been
given and the 7 calendar days have lapsed.
5. If the shipment is determined to be acceptable, the following procedures will be followed:
a) If the 7-day notice has been given under Section 4.0 above and the 7 calendar days have lapsed.
No.: PBL-10
Rev. No.: R-3.3
Date: November 13,
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 5 of 13
the byproduct material will then be unloaded in the designated area. If such notice has not been
given or if such 7 day period has not lapsed, then the byproduct material will be unloaded in an
area of the tailings cell that is not covered with interim cover and from which the material can
be removed if necessary. Once the required notice has been given and the required 7 days have
lapsed, the byproduct material will then be placed into the designated area.
b) If the material is in a self-unloading container, the driver will be instructed to unload ensuring
all personnel are clear of the trailer and the immediate area. Byproduct material will be
dumped from the transport in a safe manner to minimize dust. If the material requires
unloading by a fork truck, a ramp will be installed and unloading will proceed.
c) After unloading, the Environmental personnel will visually inspect the unloaded byproduct
material to ensure that there is no newly discovered material which does not match the material
description on the shipping manifest. Any discrepancies between the byproduct material
received and the manifest information will be reported to the Environmental Coordinator. Any
byproduct material suspected of not meeting the requirements set forth in Section 2.0 of this
SOP will be kept segregated from other waste material until a determination is made of its
acceptability for disposal.
d) After unloading, a photo of the unloaded material will be taken which is attached to the
shipping documentation for verification of shipment contents.
e) The location of the shipment of the byproduct material will be documented on the plat of each
Designated Disposal Area illustrating the disposal area within the Designated Disposal Area
where the byproduct material will be disposed of.
0 Beta-gamma measurements will be taken at several locations around the unloaded material.
This information will be recorded on the Radiation Department's copy of the shipment
documentation. The measurement range in mrem/hr at 2 meters, and the average measurement,
measured in mrem/hr at 2 meters, shall be recorded.
g) Measurements using a photoionization detection meter ("PID") will be taken at several
locations around the unloaded material to ensure that there are no organics present. The
information will be recorded on the Environmental Department's copy of the shipment
documentation. If organics are detected, the Environmental Coordinator must be advised, and
no compaction or covering activities relating to the shipment shall occur until specifically
instructed by the Environmental Coordinator. The Environmental Coordinator and Safety
Coordinator will determine if any additional safety precautions are required to be taken by
workers or otherwise as a result of the detection of the organics, and will implement any such
precautions. The Environmental Coordinator will also contact EFR corporate regulatory
personnel and the shipper to verify that the detected organics are 1 le.(2) byproduct material
from the shipper's ISL facility. Once the Environmental Coordinator has verified that the
organics are byproduct material compaction and covering activities will proceed.
h) A breathing zone sample will be taken periodically during unloading and cover activities. If
the gross alpha exceeds 25% of the applicable DAC, then the RSO will be notified, and all
other unloading activities of byproduct material from that particular ISL site will require the
No.: PBL-10
Rev. No.: R-3.3
Date: November 13,
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 6 of 13
use of respiratory protection, until further notice by the RSO.
i) After unloading the byproduct material, replace the tarp or close the trailer, unless the trailer is
being decontaminated for unrestricted release.
j) Direct the driver back to the scales for an empty weight.
k) The scale house operator will record the empty weight on the appropriate SWT.
1) Shipment and disposal activities will be documented as described in Section 10, below.
7.0 Covering of Byproduct Material
1. After the byproduct material has been accepted by the Environmental Coordinator, or their
designee, the byproduct material will be spread within the designated area within the
Designated Disposal Area to facilitate compaction and covering.
2. The byproduct material will be compacted with at least four passes of the construction
equipment prior to placing an additional layer.
3. Free volumes in the byproduct material will be minimized by filling, sectioning, or crushing.
Random fill or tailings sands will be used to fill voids in and around the byproduct material.
4. All contaminated equipment shall be dismantled, crushed, or sectioned to minimize void
spaces. Barrels containing waste other than soil or sludges shall be emptied into the disposal
area and the barrels crushed. Barrels containing soil or sludges shall be verified to be full prior
to disposal. Barrels not completely full shall be filled with tailings or soil.
5. A one foot thick, or thicker, cover comprised of native soil will be placed over the byproduct
material working area. The fill and cover material will be compacted with at least one pass of
the construction equipment.
6. The Environmental Coordinator or their designee will inspect the placement of the byproduct
material prior to covering to physically verify that the procedures in this Section 7.0 have been
adequately performed.
8.0 Decontamination and Release of Trailers and Trucks
All trailers and trucks will be decontaminated after unloading prior to leaving the Mill. Shippers
or transporters will notify EFR whether a specific trailer is to be released for restricted or unrestricted
use. Any trailers that are to be released for restricted use will be decontaminated according to the
requirements contained in DOT Part 49 CFR 173.441(b) and 173.443. Any trailers that are to be
released for unrestricted use will be decontaminated according to the requirements found in Table 1 of
the Nuclear Regulatory Commission's (NRC's) Policy and Guidance Directive FC-85-23, "Guidelines
No.: PBL-10
Rev. No.: R-3.3
Date: November 13,
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: I le (2) Byproduct Disposal
Page 7 of 13
for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination
of Licenses for Byproduct, Source, or Special Nuclear Material'" issued May 1987. Trailers requiring
repair will be decontaminated for unrestricted release, to facilitate repairs by the transporter at the
transporter's own site. Trailers may be repaired without undergoing full decontamination if repaired
within the restricted area of the Mill.
For the appropriate decontamination procedures, refer to the following Standard Operating Procedures
for the appropriate conveyance:
End Dump Trailer SOP PBL-9
Intermodal Container SOP PBL-2
Standard Container Trailer SOP-PBL-2
9.0 Hazard Identification and Safety
1. Required Personal Protective Equipment (PPE)
In all areas of the Mill covered by this procedure, hard hats, safety glasses and steel-toed shoes
are required at a minimum. These must be worn in the restricted area of the Mill. Prior to
disposal, the RSO will determine what level of respiratory protection, if any, will be required.
2. Industrial Hazards and Safety
c) Use caution when the trailers are backing to the unloading area.
d) Ensure that all personnel within 50 feet of the area where an end dump trailer is about to dump
its load are aware that unloading is about to commence. Move at least 25 feet away from the
rear of the trailer during the initial unloading operation.
e) Drivers must use caution during the unloading process and be aware of any overhead hazards.
f) Do not place any part of your body inside the trailer when the trailer is being tipped and the
tailgate is open. Only work around the tailgate after it has been properly blocked open.
g) Use caution when entering or exiting equipment. Be sure to use the ladders and hand rails. Do
not jump off the equipment.
h) Always use a ladder when entering and/or exiting the interior of a trailer.
3. Mobile Equipment
a) Only trained and authorized persons may operate mobile equipment.
b) All mobile equipment shall be inspected by the operator and any safety defects corrected before
the equipment is used. If safe to do so, the equipment may be driven to the shop for repairs.
Otherwise, the equipment must be towed or repaired at the location.
No.- PBL-IO
Rev. No.: R-3.3
Date: November 13,
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 8 of 13
c) Audible backup alarms shall be in operating condition.
d) Walk around any piece of equipment before starting or moving it. Make certain no one is in a
dangerous position and there are no obvious defects or hazards.
e) Use caution when entering or exiting equipment. Be sure to use the ladders and hand rails. Do
not jump off the equipment.
0 Seat belts shall be used at all times when equipment is in motion.
g) Equipment shall be operated at a reasonable speed consistent with road and weather conditions,
subject to a maximum speed limit of 15 mph.
h) Keep the cabs of equipment clean. Loose items that could jam controls or create other hazards
are not allowed.
i) Report all accidents to your supervisor regardless of how minor they are. If property damage
or personal injury is involved, do not move the equipment until your supervisor has released it.
j) All gasoline engines must be shut off when refueling.
k) Keep equipment clear of edges, drop offs, and unstable banks. Maintain adequate berms where
required.
10.0 Documentation
1. a) Documentation of Shipments
For each shipment of byproduct material the following records will be maintained in the Mill's
Environmental Department files:
• Shipper's Manifest and Bill of Lading.
• Laboratory/activity analysis of the byproduct material performed by the Shipper.
• Completed SWT.
• 7-day notice to Director.
• Photo of the byproduct material.
• Byproduct material radiological scan information.
• Breathing zone monitoring data, if applicable.
• Equipment release forms.
All documents and photographs should be dated and the Shipper's Manifest and or Bill of
Lading number indicated on the document.
No.: PBL-10
Rev. No.: R-3.3
Date: November 13,
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 11 e.(2) Byproduct Disposal
Page 9 of 13
b) Documentation of Disposal
Byproduct material disposal will be documented on the Disposal Documentation Form
provided in Attachment 2. Attachment 2 may be accompanied by photographs, a written
description or both. Attachment 2 or other written description will include:
• How the material was placed in the tailing cells;
• If void spaces in the drums/barrels containing soil or sludge were filled with tailings
sands;
• How the area was compacted;
• Document that materials placed on tailings are no more than 4 feet thick and
subsequent lifts no more than 2 feet thick (this information will be obtained for each
ISL disposal area and maintained by the engineering department);
• Document that there are 4 feet of tailings under the bottom of each disposal area and
the bottom of each disposal area is located at least 12 feet from the sides or dikes of
the tailings area this information will be obtained for each ISL disposal area and
maintained by the engineering department);
• Document that the elevation of the material will not exceed the plane or grade of the
elevation of the uppermost flexible membrane liner of the cell.
• Confirmation that the shipment was properly covered; and
• Where settlement markers were placed. The Mill will maintain a plat of each
Designated Disposal Area, which illustrates the location of each shipment of
byproduct material.
2. The Mill will maintain on file a copy of the Director's written approval of each Designated
Disposal Area.
An annual summary of the amounts of byproduct material disposed of in each calendar year
shall be sent to the Director on or before November 1 of the calendar year. (License Condition
10.5F). [summary due same year]
11.0 Training
An annual basis, all onsite personnel that are involved in the receiving or disposing of this
material shall be trained in the activities associated with this procedure. This training shall be
documented and maintained on file.
No.: PBL-10
Rev. No.: R-3.3
Date: November 13,
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 11 e.(2) Byproduct Disposal
Page 10 of 13
ATTACHMENT 1
SAFETY TRAINING FOR DELIVERY PERSONNEL
Welcome to Energy Fuels Resources (USA) Inc.'s, White Mesa Mill. In order to assure your safety
while on our property, we would like to acquaint you with the safety rules and procedures, which you
will be required to follow while on our property.
1.0 General Safety
1. Approved hard hats and safety glasses are required at all times except when inside the cab of
your truck.
2. This is a smoke free facility. No smoking is allowed on the property. Eating anything,
drinking, chewing candy, gum or tobacco is also not allowed in the Mill Restricted Area due
to radiation hazards.
3. Maintain a safe speed at all times when driving in the Mill Restricted Area. The maximum
speed limit is posted at 15 mph Energy Fuels Resources (USA) Inc.'s equipment has the right
of way on the ore pad and Mill roadways.
4. Be aware of the possibility of a truck turning over while dumping. Ensure that the truck is on
level ground and brakes are set prior to dumping.
5. Check for potential overhead hazards prior to dumping.
6. If material is hung up in the trailer bed, it is not permissible to work in the bed while it is in the
dump position. If it is necessary to get in the bed of the trailer to free a hang up, the bed must
be lowered.
7. Be aware of slippery conditions on the ore pad during periods of inclement weather.
8. Be aware of the potential for ice build-up on and around the decontamination pad during
periods of cold weather.
9. Use caution when entering or exiting equipment.
2.0 Radiation Safety
1. All drivers are required to scan for alpha radiation prior to leaving the Mill Restricted Area.
2. All equipment, i.e. trucks and trailers, will be scanned for radiation prior to leaving the Mill's
Restricted Area.
Driver (Printed) Scale House Operator
Driver (Signature) Date
No.: PBL-10
Rev. No.: R-3.3
Date: November 13,
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: I le.(2) Byproduct Disposal
Page 1 1 of 13
ATTACHMENT 2
11e.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date:
Name of employee receiving the load:
Generator of the Byproduct Material:
Shipper's Manifest or Bill of Lading number:
Was the State of Utah given notice to the receipt/disposal activities associated with this load? Yes or
No
Who gave and when was the notification given?
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?
Which tailings cell was the material placed in?
Was the material placed on a tailings beach area of the cell or on an area of the cell that was underlain
by tailings sands?
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-3.3
Date: November 13,
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 11 e.(2) Byproduct Disposal
Page 12 of 13
Manifest or BOL #:
Have the thickness and placement measurements been verified and documented for the disposal area
by the engineer, specifically:
Engineer's or
Environmental
Coordinator's
Initials
Was the material placed in a cell approved by the executive Secretary
for ISL waste disposal?
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 cell?
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?
No.: PBL-10
Rev. No.: R-3.3
Date: November 13,
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 13 of 13
Manifest or BOL #:
Are additional settlement monitors required to be placed for this generator?
If required, where were settlement markers were placed?
Radiological receipt survey measurements:
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? Yes or No