DRC-2014-006881 - 0901a068804bcb32

Department of
Environmental Quality
Amanda Smith
Executive Director
State of Utah
GARY R HERBERT
Governor
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director DRC-2014-006881
Spencer J. Cox
Lieutenant Governor
MEMORANDUM
THROUGH:
TO: File C-2014-72
Phil Goble, Section Manager
FROM: Russell J. Topham, P.E. r DATE: November 17, 2014
SUBJECT: Engineering Module 73. Inspection of Disposal of Bulk Byproduct Material November 13,
2014. Radioactive Materials License UT 1900479 (License) - Energy Fuels Resources
(USA) Inc. (EFR) White Mesa Mill, Blanding, Utah
On November 13, 2014, I performed an inspection of files related to 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 involved reviewing files for the 2014 calendar year to date. 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.
The current document governing the disposal of ISL materials is Standard Operating Procedure PBL-10,
Revision 3.2, dated January 22, 2013 (the SOP; Attachment 1 to this Memorandum). This SOP sets forth
requirements for the field crews to follow, including required record keeping, inspection and radiological
survey standards, and burial procedures.
I examined fourteen of the eighty-four record packets assembled for the year to date. The following
observations were shared during an exit interview with Dave Turk and Dan Hilsten:
1. Each packet 1 inspected contained all required documents, and all were legible.
2. SOP PBL-10. Attachment 2, provides opportunity for the field crew to document the handling of
each load, and the adherence to correct procedure. All blanks on the documents were filled out,
providing evidence that field crews know the procedures to follow during disposal.
3. Prior to departing the DRC offices for this inspection, I verified that the corporate office had, and
expected field crews to use, the correct version of the SOP. Upon commencing the inspection, I
verified that the procedure book at the mill contained Revision 3.2 of the SOP. All 84 packets
used Revision 3.1 of Attachment 2 to the SOP, which is not the current revision. Dave Turk
committed that the correct revision would be used going forward.
4. Revision 3.2 to the SOP introduced a requirement to place the unique shipper number for each load
168 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax [phone] • T D D. [phone]
www.deq. utah.gov
Printed on 100% recycled paper
Project C-2014-72
Memorandum RE: Inspection of November 13, 2014
Page 2
of ISL on the copy of Attachment 2 filled out for that load. Letters from the DRC dated January
14, 2013 (to David Frydenlund), March 18, 2013 (to Jo Ann Tischler) and April 5, 2013 (to Jo Ann
Tischler) document the discussion and approval of Revision 3.2 (Attachment 2 to this
Memorandum contains these letters.). Revision 3.2 included a blank on the form to prompt
inclusion of the shipper number. The DRC intended this requirement to facilitate reassembling
document packets should the papers within the packet become separated. Inasmuch as the field
crews used an old revision of the form, most of the packets did not have the shipper number
entered on Attachment 2. Attachments 3 and 4 to this Memorandum are an example of a packet
without the shipper number on the cover page and one including the shipper number.
5. During the inspection, a split packet was discovered (Shipper #6/14-21 from Smith Ranch). Two
of the documents that belonged in the packet had come loose from the staple. Observing this
condition, I reiterated encouragement given on other occasions to hand-write the shipper number
on each page of each document in each packet. Dave Turk volunteered to amend the SOP to make
this suggestion a requirement for the field crews, and to move the blank field on Attachment 2 to
the SOP to the header so it appears on all pages of the Attachment.
6. The licensee is controlling placement of ISL waste in such a way as to not comingle materials from
different generators. Attachment 5 to this Memorandum is a photo of the map in use to identify
burial locations by generator.
7. Training records indicate that drivers have received annual training regarding the mill's
procedures, but that mill staff has not reviewed this procedure since 2011. Dave Turk committed
to institute an annual refresher for this procedure.
On November 17, 2014. I received via email a proposed revision to the SOP (included as Attachment 6 to
this Memorandum). This revision strengthened the language requiring placement of the shipper number on
all documentation associated with each load of ISL waste, placed a blank on each page of Attachment 2 to
the SOP for placement of the shipper number, and added a requirement for annual training of personnel
handling the receipt and disposal of the material.
Recommendations -1 recommend approving SOP PBL-10, Revision 3.3, and closing out the file inspection.
Attachments: 1. SOP PBL-10, Revision 3.2
2 Correspondence from the DRC regarding Revision 3.2 to Procedure PBL-10
3 Copy of packet for Shipment 154
4 Copy of packet for Shipment 155
5 Photo of burial location map
6. SOP PBL-10, Revision 3.3
Project C-2014-72
Memorandum RE: Inspection of November 13, 2014
Attachment 1
Standard Operating Procedure PBL-10, Revision 3.2
No.: PBL-10
Rev. No.: R-3.2
Date: January 22,
2013
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 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
10.5A
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-3.2
Date: January 22,
2013
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: lle.(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-3.2
Date: January 22,
2013
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 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-3.2
Date: January 22,
2013
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: lle.(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-3.2
Date: January 22,
2013
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.
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-10
Rev. No.: R-3.2
Date: January 22,
2013
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-3.2
Date: January 22,
2013
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 11 e.(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:
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.
End Dump Trailer
Intermodal Container
Standard Container Trailer
SOP PBL-9
SOP PBL-2
SOP-PBL-2
No.: PBL-10
Rev. No.: R-3.2
Date: January 22,
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 8 of 13
2013
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.
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:
No.: PBL-10
Rev. No.: R-3.2
Date: January 22,
2013
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 11 e.(2) Byproduct Disposal
Page 9 of 13
• 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.
3 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]
No.: PBL-10
Rev. No.: R-3.2
Date: January 22,
2013
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-3.2
Date: January 22,
2013
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 11 of 13
ATTACHMENT 2
lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date:
Name of employee receiving the load:
Generator of the Byproduct Material:
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?
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?
Are additional settlement monitors required to be placed for this generator?
No.: PBL-10
Rev. No.: R-3.2
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 11 e.(2) Byproduct Disposal
Page 13 of 13
Date: January 22,
2013
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
Project C-2014-72
Memorandum RE: Inspection of November 13, 2014
Attachment 2
DRC Correspondence Relating to Standard Operating Procedure PBL-10, Revision 3.2
Department of
Environmental Quality
Amanda Smith
Executive Director
State of Utah DIVISION OF RADIATION CONTROL
GARY R HERBERT
Governor
Rusly Lundberg
Director
GREG BELL
Lieutenant Governor
January 14, 2013
Mr. David C. Frydenlund
Senior Vice President, Regulatory Affairs and General Counsel
Energy Fuels Resources (USA) Inc. (EFR)
225 Union Blvd., Suite 600
Lakewood, CO 80228
Subject: Compliance: Engineering Module 73, Inspection of Disposal of Bulk Byproduct
Material: Radioactive Materials License UT1900479 (RML): DRC Findings,
Closeout of Engineering Module 73, and Request for Information Relative to
Standard Operating Procedure PBL-10
Dear Mr. Frydenlund:
During the year 2012, the Utah Division of Radiation Control (DRC) conducted four inspections
of disposal operations for 1 le.(2) byproduct material. These inspections occurred on April 13,
June 8, September 20 and December 20, 2012. The DRC findings were as follows:
1. EFR has an approved Standard Operating Procedure, No. PBL-10, Revision No. R-3
(SOP), dated November 10, 2011 which sets forth an orderly methodology for achieving
compliance with the conditions of the RML governing receipt and disposal of 1 le.(2)
byproduct material.
2. The inspections performed on the above referenced dates did not reveal incidents of
noncompliance with either the RML or the SOP, with one exception, as noted below.
3. During the December 20, 2012 inspection, EFR received two loads of byproduct material.
Paragraph 5.6 on Page 3 of the SOP requires inspection of the load for conformance with
the description of the shipping papers prior to the load leaving the vicinity of the scale
house and entering the secured area. The load bearing Shipping Number 12/12-16 on the
Bill of Lading was not inspected until it reached the disposal site in Cell 3, within the
secure area. The DRC was provided an explanation that the containers often arrive with
doors frozen shut during the winter, and forcing the doors open is better done just prior to
offloading the material. The inspection at the point of receipt is designed to facilitate
rejection of loads without needing to address decontamination of the transport vehicle
when the material does not match the description on the shipping papers. The DRC does
195 North 1950 West • Salt Lake City, UT
Mailing Address P O Box 144850 • Salt Lake City, UT 84114^1850
Telephone [phone] • Fax [phone] -TDD (801) 536^1414
www deq ulah gov
Primed on 100% recycled paper
David C. Frydenlund
Page 2
January 14, 2013
not take exception to the practice observed, but does have concern that a nonconforming
load may create a compliance dilemma upon rejecting the load.
4. The SOP contains a form, identified as Attachment 2, and appearing on Pages 10 through
12 of the SOP. Field crews use the form to track and document compliance with the SOP,
and thus with the RML, when each load of byproduct material arrives and receives
disposal. EFR can improve this form by including on the form a place to identify the load
to which the form pertains. Should the Bill of Lading and other documents be separated
from the form, returning the form to the correct paperwork packet would prove
problematic.
Inasmuch as EFR has complied with the provisions of the RML, no violations have been detected,
and no open issues remain: therefore, the DRC considers the 2012 Engineering Module 73
closed.
Request for Information
As noted in Bullet Item 3 above, the field practice of transporting incoming loads to the secure
area during extreme cold weather prior to visual inspection against the description on the load
manifest introduces complications should EFR need to reject a load. If EFR intends to continue
this practice, please amend Standard Operating Procedure PBL-10 to include the variation
currently employed under extreme cold conditions. Include in the amendment decontamination
and survey procedures for the exiting load and its transport. Please provide these revisions, or a
statement that EFR will abandon the practice, by February 28, 2013.
If you have any questions on these matters, please contact at Russ Topham at [phone].
Sincerely,
Rusty Lundberg
Director
RL/RJT:rjt
Department of
Environmental Quality
Ainanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
State of Utah
GARY R HERBERT
Governor
GREG BELL
Lieutenant Governor
March 18,2013
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
Jo Ann Tischler
Director, Compliance
Energy Fuels Resources (USA) Inc. (EFR)
225 Union Blvd., Suite 600
Lakewood, CO 80228
^S*Postal Service ,
^CERTIFIED .MAIL RECEIPT
rr ru rr
•
•
•
•
JO
rr
• a
veraae Provided):;^.
a-OFF ICJALUSE
Postage
Certified Fee
Return Recemt Fee
Postmark
RE: compliance; mod 73 RFI / rjt
JO ANN TISCHLER ^/110AXIMr
ENERGY FUELS RESOURCES (USA) INC.
225 UNION BLVD., STE 600
LAKEWOOKCO 80228
• ricvci'sc fof Instructions
Subject: Compliance: Engineering Module 73, Inspection of Disposal of Bulk Byproduct
Material: Radioactive Materials License UT1900479 (RML): DRC Findings and
Request for Information.
Dear Mr. Frydenlund: DRC"20l3-00 1 V i> 9
On March 7, 2013, the Utah Division of Radiation Control (DRC) conducted an inspection of
disposal operations for 1 le.(2) byproduct material. The DRC findings were as follows:
1. EFR has an approved Standard Operating Procedure, No. PBL-10, Revision No. R-3
(SOP), dated November 10, 2011 which sets forth an orderly methodology for achieving
compliance with the conditions of the RML governing receipt and disposal of 1 le.(2)
byproduct material. The DRC has in hand Revision R-3.2, which is currently under
review.
2. The inspections performed on the above referenced dates did not reveal incidents of
noncompliance with either the RML or either revision of the SOP.
3. The disposal operation occurred on the tailings beach near the remaining solution pool. In
this location, no interim cover had been placed. As such, the solution level in the disposal
excavation reached nearly to the beach surface at the rim of the excavation. The waste
materials and cover soils placed in the excavation formed a viscous paste which did not
respond well to compaction. As such, EFR was unable to finish work on the disposal
operation while DRC staff were present.
195 North 1950 West • Salt Lake City, UT
Mailing Address P O Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax [phone] -TDD [phone]
www deq Utah gov
Printed on )00% recycled paper
David C. Frydenlund
Page 2
March 13,2013
4. The SOP contains a form, identified as Attachment 2, and appearing on Pages 10 through
12 of Revision R-3 of the SOP and on Pages 11 through 13 of Revision R-3.2. Revision R-
3.2 contains a line item on the first page of Attachment 2 (page 11) for a unique load
identifier. This responds to a request made in the DRC letter of January 14, 2013.
5. The DRC suggests an additional revision to the SOP to indicate that the unique load
identifier should be hand-written on each page or sheet that makes up the packet
documenting the characteristics and disposal of an individual load. The DRC suggests
selection of phrasing in this revision to avoid making this change a regulatory requirement.
The DRC offers this suggestion as a means to reduce the chance of collation errors should
papers from one or more load documentation packets become separated.
Request for Information
As noted in Bullet Item 3 above, EFR was unable to complete the requirements of the SOP for
compaction of the waste and cover soils because of the high moisture content of the materials in
the excavation while DRC staff were present. The SOP calls for wheel-walking or track-walking a
specific number of passes to densify the materials. The high moisture content not only makes the
materials too soft to work, the moisture also prevents densification. Therefore, field crews
proposed, and the DRC field inspector agreed, to wait until the moisture content of the cover soils
decreased sufficiently to complete the required compaction. As EFR becomes able to perform the
compaction of these soils, please forward a brief narrative and photographs documenting what
took place.
If you have any questions on these matters, please contact at Russ Topham at [phone].
Sincerely,
Rusty Lundbi
Director
cc: EFR White Mesa Mill: David Turk
RL/RJT:rjt
iA A-
v. / * « >>../''
State of Utah
JON M HUNTSMAN, JR
Governor
GARY HERBERT
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Acting Executive Director
DIVISION OF RADIATION CONTROL
Rusly Lundberg
Director
April 5, 2013
Jo Ann Tischler
Director, Compliance
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO 80228
SUBJECT: Compliance: Review of Revision R-3.2 of Standard Operating Procedure PBL-10;
Radioactive Materials License UT 1900479 (RML) and Groundwater Discharge Permit
(GWDP) UG370004, Energy Fuels Resources, Inc. (EFR) White Mesa Mill, Blanding,
Utah: Approval and Closeout
Dear Ms. Tischler:
On February 28, 2013 the Utah Division of Radiation Control (DRC) received proposed revisions
to Standard Operating Procedure PBL-10 (SOP). The SOP bears revision mark R-3.2, and was
submitted in response to a Request for Information from the DRC dated January 14, 2013 (RFI).
As documented in the cover letter accompanying the SOP, communication took place in which
better understanding of some of the issues underlying the RFI was reached. The following
summarizes the key findings of the DRC review of the SOP.
1. EFR has in place sufficient robust protocols to handle rejection of a load of 11 e.(2)
byproduct material at virtually any location within the secured area if it fails to meet the
description on the shipping manifest. The DRC had concerns that a load might be rejected,
but the transport conveyance could not be decontaminated to meet Department of
Transportation (DOT) requirements for release.
2. EFR has amended Attachment 2 to the SOP to include a unique identifier for the material
being documented. This will help facilitate re-collation of document packets for loads of
disposed 1 le.(2) material should the packets become separated. A further improvement
could be made by including that unique identifier on all pages of all documents in the
packet. The DRC suggests including language in the SOP stating that each page of
documentation should bear that unique identifier. Since the DRC does not intend this to be
a compliance point, the DRC will not require a response to this suggestion.
3. The language of the SOP has been amended to allow inspections of incoming loads at the
un-tarping station (preferred practice) or in other areas of the plant (current cold-weather
practice includes inspection at the disposal site). This clarifies the process for DRC
168 North 1950 West • Salt Lake City. UT
Mailing Address PO Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax [phone] -TDD [phone]
M H'W deq Utah guv
Printed on 100% recycled paper
Jo Ann Tischler
April 5, 2013
Page 2
inspectors as well as for plant personnel.
4. Minor textual changes have been made to reflect changes in job titles and responsibilities
at EFR and at the DRC (changing reference from Executive Secretary to Director), and to
acknowledge the recent change of ownership of the plant.
The amendments made to the SOP do not constitute significant changes to protocol. Each of the
changes makes an improvement, clarification, or reference change which will make future use of
the SOP easier and/or more effective. Revision R-3.2 of SOP PBL-10 is hereby approved and
the associated RFI is closed out.
If you have questions about these matters, please contact Russ Topham at [phone].
Sincerely
Rusty Lundberg, Director
RL:RJT:rjt
Project C-2014-72
Memorandum RE: Inspection of November 13, 2014
Attachment 3
Copy of Packet for Load Bearing Shipper # 154
No-.: PBL-10
Rev. No.: R-3.1
Date: June 4, 2012
DENIS ON 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: %l Z6\ H
Name of employee receiving the load: zxrr-\ /i- P<x 1 iA*. cV~
Generator of the Byproduct Material: -^P#*g= £- S t C Afi
Was the State of Utah given notice to the receipt/disposal activities associated with this load^Yes ^r
No
Who gave and when was the notification give^n?
z:/is>H :
Description of byproduct material disposal area/activities:
c
Has each drum been inspected to identify the presence of any void spaces?^. ,V\t\ -
Have all drums with void spaces been filled with tailings sands or soil? / .A' Ar .
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?
c
c
No : PBL-10
Rev. No.: R-3.1
Date: June 4, 2012
DENISON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 11e.(2) Byproduct Disposal
Page 11 of 12
) Have the thickness and placement measurements been verified and documented for the disposal area
by the engineer, specifically:
Was the material placed in a cell approved by the executive Secretary
for ISL waste disposal?
Documentation of approval L*.e<ric £4Ticf00Li7<) A^^f
Was the ISL material segregated from disposed Mill material and other
ISL material?
Refer to plat(s) used to confirm. Cr//3 /^-z
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 C< M J Cc^K Om^r/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 confirm. CtH 3 Co«d- Omisr/ijs
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
ML
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?
u±
Was the shipment properly covered?
Are additional settlement monitors required to be placed for this generator?
/Jh
If required, where were settlement markers were placed?
No.: PBL-10
Rev. No.: R-3.1
Date: June 4, 2012
DENIS ON MINES (USA) CORP.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
A/A-
Radiological receipt survey measurements:
Breathing Zone:
1. Was a Breathing Zone Sample collected? Yes o£^d^>
2. If yes, what were the results of the sampling?
Page 12 of 12
Was a photograph taken during the unloading activitiesl/^fesy/r No
BILL-OF-LADING
SHIPMENT ID# 154 SHIPMENT DATE: February 24, 2014
SHIPPER (From):
MESTENA URANIUM LLC
CONSIGNEE (To):
Energy Fuels Resources (USA) Inc.
6425 South Highway 191
Blanding, UT 84511
ADDRESS:
755 Co. Rd. 315 Encino, TX 78353
ADDRESS:
P. O. Box 809, Blanding UT 84511
SHIPPER LICENSE NO.: RO5360 SHIPPER USDOT NO.: CONSIGNEE
LICENSE NO.:
UT-1900479
CONSIGNEE TELEPHONE NO.
[phone]
SHIPPER LICENSE NO. SHIPPER TELEPHONE
NO.:361-561-4780
CARRIER NAME AND ADDRESS:
Greenfield Logistics, LLC
CARRIER USDOT CARRIER HAZMAT REG. NO.:
Trailer # Contained GFLU 001092 Seal# 0000385 Seal # 0000386
HM DESCRIPTION OF MATERIAL AND PACKAGING VOLUME
Cubic feet
or
QUANTITY
CLASSIFICATION
1 pkg.
RQ
UN2913, Radioactive Material, Surface Contaminated
Objects (SCO-1), non-fissile,, Class 7
Dry 11 (E).2 By-Product material.
Activity: 2.6 E8 Bq (0.007 Ci)
EMERGENCY CONTACT:
P. Luthiger: 1-361-816-0150
28,000 lbs.
(gross)
Surface contaminated objects
(SCO-1)
Exclusive use shipment
Placards applied
CERTIFICATION: These is to certify that the above named articles are properly classified,
described, packaged, marked and labeled, and are in proper condition for transportation,
according to the applicable regulations of the Department of Transportation.
Shippers Signature: Date: ^fcj/V
Driver's Signature: ~\V^r/ ^fj^flf. J^ Date: ^
; iH
Mestena Uranium, LLC
SHIPPER'S
RELEASE AUTHORIZATION FOR BY-PRODUCT MATERIAL
DESTINATION: Energy Fuels Resources (USA) Inc. - White Mesa Mill
6425 S. Hwy 191
Blanding, UT 84511
SHIPMENT NUMBER: 154
NAME OF DRIVER: "7£>/y firyf^/rJf
DESCRIPTION OF MATERIAL: By-product material from an in-situ uranium mining
operation. (Sand, filter cloths, mud)
DRIVER: 2 Signatu
By execution below, it is represented that the byproduct material being transported is properly
classified, described, loaded and labeled; and, that the byproduct material is completely
contained and in proper condition for transportation, according to the applicable regulations for
the state and federal transportation departments.
The shipper certifies the byproduct material is not listed hazardous waste as defined in the
Resource Conservation and Recovery Act, as amended, 40 CFR 261 et. seg. or comparable state
laws. The byproduct material has no been mixed or commingled with hazardous waste as
defined in 40 CFR 261 et. seq.. No processes are operated on the site which are RCRA-listed
processes as defined in 40 CFR 261 et. seq. All of the Byproduct Material is byproduct material
defined under the Atomic Energy Act of 1954 as amended, 42 U.S.C. § 2014(e)(2) and 10
CFR§40.4(a-i).
DATE: T^Ee^m BY:
Sign. ure
MESTENA URANIUM LLC
D.O.T. RADIATION SURVEY RELEASE RECORD
Survey Date Technician
Model
Model
Alpha Survey Instrument
3^ Serial Number 3-);U5 Efficiency D< 2G(,
Gamma Survey Instrument
Serial Number 2,)%/%
SHIPMENT* Q?-\5H Shipment Type \^ yj)*cduj~
Gamma
Contact
(uR/hr)
Gamma
2 meters
(uR/hr)
Alpha
Removable
(cpm/100 cm2)
Comment
Cab of Truck 3 O N/A N/A
Trailer - Rear / 20 ^0 N/A
Trailer - Driver Side '2c-0 N/A
Trailer - Passenger Side He 70 N/A
Trailer - Front too 70 N/A
Trailer - Bottom N/A N/A
Trailer - Left door N/A N/A
Trailer - Right door N/A N/A < /O
Trailer - Handle N/A N/A <L /O
Trailer - Tires N/A N/A
Tractor Cab - Tires N/A N/A
Tractor Cab - Floorboard N/A N/A 5
Placards Installed:
Comments
NO Seals Provided ^3^5 ivx^ ([></•
MESTENA URANIUM LLC
RADIATION SURVEY - D.O.T. PACKAGE
Survey Date y^//^// ^ Technician
Model
Model
Alpha Survey Instrument
Serial Number &}2l5~l Efficiency , 2. Ob
11
Gamma Survey Instrument
Serial Number ^./ff \9 Q
Package S/N &H.[J( COIO^Z, Package Capacity (yd3)
Contact
Gamma
(uR/hr)
Alpha
Removable
(cpm/ cm2)
Comment
Package - Rear Left ZOO Z Package - Rear Right ZOO
Package - Driver Side - Left 51
Package - Driver Side - Right 150
Package - Passenger Side - Left ZOO
Package - Passenger Side - Right 2JDQ
Package - Front - Left 10
Package - Front - Right 7
Package - Bottom - Left
Package - Bottom - Right %00
D.O.T. Markings/Labels Installed on Package: (J^S
Comments ScJ 3ffS ,n ^J/JYJ
NO
OA c fit.
Radiation/Contamination Limits
Gamma (contact reading) - 200 milliRem/hr
Removable (U nat - low toxicity alpha emitter) - 220 dpm/cm2
DEFAK1MEJN1 O* TRANSPORT ATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
©HAZARDOUS MATERIALS
CERTIFICATE OF REGISTRATION
FOR REGISTRATION YEAR(S) 2013-2016
Registrant: MESTENA URANIUM LLC
Attn: MICHAEL MAXSON
500 N SHORELINE STE 700
CORPUS CHRISTI, TX 78401-0326
This certifies that the registrant is registered with the U.S. Department of Transportation as required by
49 CFR Part 107, Subpart G.
This certificate is issued under the authority of 49 U.S.C. 5108. It is unlawful to alter or falsify this
document.
Reg. No: 052413 550 028VX Issued: 05/24/2013 Expires: 06/30/2016
HM Company ID: 106513
Record Keeping Requirements for the Registration Program
The following must be maintained at the principal place of business for a period of three years from the
date of issuance of this Certificate of Registration:
(1) A copy of the registration statement filed with PHMSA; and
(2) This Certificate of Registration
Each person subject to the registration requirement must furnish that person's Certificate of Registration
(or a copy) and all other records and information pertaining to the information contained in the registration
statement to an authorized representative or special agent of the U. S. Department of Transportation upon
request.
Each motor carrier (private or for-hire) and each vessel operator subject to the registration requirement
must keep a copy of the current Certificate of Registration or another document bearing the registration
number identified as the "U.S. DOT Hazmat Reg. No." in each truck and truck tractor or vessel (trailers
and semi-trailers not included) used to transport hazardous materials subject to the registration
requirement. The Certificate of Registration or document bearing the registration number must be made
available, upon request, to enforcement personnel.
For information, contact the Hazardous Materials Registration Manager, PHH-52, Pipeline and Hazardous
Materials Safety Administration, U.S. Department of Transportation, 1200 New Jersey Avenue, SE,
Washington, DC 20590, telephone [phone].
Mestena Uranium LLC
Alta Mesa Project
EMERGENCY PROCEDURES
Guide 162
Radioactive Materials (Low to Moderate Level Radiation)
POTENTIAL HAZARDS
Health • Radiatiojipic2ciiniiamnialx)& tranaportaoxra accidents-Pa rlca^^
• Urvtimigcd packages ire safe. Contents of dztuaged p*±agei may ouic higher ctMxwl radktioa exposure, or both exxemal and intcnwl radiation exposure if contests are released.
• Low radiatian hazard when nmsrial U icude oontttnrr ff material is ceteasedfompockiigcarbalicccuusiiier,
hazard wDI vary from tow to moderate. • Level of hazard wiB depend oo the rype and amount of radioactivity, the kind of mnrrri&l ic ii in, jnd6f lhc
sorfaoeE it i* oo.
• Some notorial may be iclraseri 6mm paefcagos dunce accidwuft of moderate icverity but risks to people arc not
©ML
• Roteued ndloactive mwnth or ajrttHrm'osted objects usually will be visible if pactawjog fiU*. « Some cxclnsive o*e shipments of balk and packaged materials win OCX have RADIOACTrVBTnixsk. Placsrxls.
fflnfMngt ftftd rfwraigif pojv^B prr?vj«V yfrflflff^"^f*
• Some packages may have c RADIOACIIVB^abol aa d a secoodha2atdlabeL The second hazard is usaolly
greater nan dio radiation hazard20 follow this GUIDE as •well as the response GUIDE for ibe second hazard class
label • Same radioactive man-rink cannot be detected by commonly available instrvtneats.
• Runoff from control of cargo fire may cause low-level pollution.
Fire or • Some of rhcac nutrxuds may bats, bat most do ooc igmte readily.
-MnrnlnmmlThnrinmmrfflniffiMiHTii ii ii iiiirifiiiaiiiiiiiiifii * CALL feacttmcy B—ponw TeUpbooe Number oc Shippfne Eapar Brwt. g Shipping Paper not available or na unnr, rcCcr to Mppropiialg triepbone nnmhrr Hitcd at ttw tut of grig section. * Priorities tor raoac,Itfb-sanine, first aid, Sn control and other hazards aca bicker than the priority Ibr measuring
radiation levcfc. • Raitiniinn Authority aum be notified of accident coiafitiona. Radiation Authority if usually responsible for decisions about radiological cootrqnny» and doaore of eciergaocies-
• Ax aa nxuscdisto precautionary BOGBSUXG, ictaate spill or leak aces fox at Ieaa2Sinc^ * Soy vpvrind. • Keep urtgTTfborlTfyt peaoaoel away.
• Detain ot Isolate uainprcd pecwtjB oreqaginptlf, sutpfArrl ta be ccnuanucatgq^deUy dccoataounatiOQ end cleanup until mgructiore are received com Badiirton Authority.
protective • Positive pretaure aelf-ooacaincd breathing apparatus (SCBA) sod atrucbuai Crcfiglitms'ptotecave clothing will
Clothing provide adeq^iarepttxftaioa.
Evacuation Uug* Spffi
• Consider initial downwind evacuation for at least 100 motors (330fbet). Hr» *Maalar^Qpa«ajtyoftIiUiiiatco^
i (1000 feeO in all dtrectJoas.
Fire
ErweRGCNCY RESPONSE
« Reatace of fadtoaetiw cvaterid win
Utg»nn9 • »caney,ftycnootru»a«o0^
• Dittac-control watecracbtcf mspocaL
Spill or •Do»«twft<l«niaPrtticlca|yy • sale * CcnwIatd^spaaTwrnViaacti carta or otbrr tic«<<«nt»nsTnik absoebcru mtrfrinl
•• D3ce tt ccAcdlawEoaid anBb.
• Cover powder epa «n alastic sheet or saipuiimmmtzeapnailins.
First AM *Ued^prot«3nctakxi • Use
4 Do not dejifv caxe aad^
of ifaelsjuy.
idfnT'i* i*" rMi
# OtycairtrVialiiaiiiatiiaiBrVirtaaiWnpttie 4 Aifasuctvatrygetiif biwtnitf ix dSBcub.
«Irjued pcraoiia con^ainifittcd by comsct with released ma tedel arc sot a serious hazarr! rx> ticaMi c&rc pefBoand,
tojulpmedt or fnrililira
prevenc jptead of cofimminwriotL
DRIVER INSTRUCTIONS
Pursuant to 49 CFR 173.427, specific instructions for maintenance of exclusive
use shipment controls shall be provided by the offeror to the carrier. Such
instructions must be included with the shipping paper information.
The following instructions are to be adhered to in the delivery to Dennison Mines
Blanding, Utah Facility:
1.
2.
3.
4.
Directions to Dennison Mines Blanding, Utah facility are enclosed.
Drivers are not to climb onto top of trailer during routine vehicle safety
checks.
Emergency response actions and telephone numbers are included in
the shipping papers.
Contact Mestena Uranium LLC at 361-561-4780 (call collect) if any
suspicious activities or incidents occur during delivery.
St/Prv Route
TRANSPORT ROUTE
Interchange teg Total
TX
KM
AZ
UT
East
North
Worth
Left
North
Bear right
West
Bear left
West
West
Bear right
North
Bear right
West
Bear right
North
West
West
West
North
North
FM755
US-281
US-S9
Ramp
137
Exit 133
1410
Exit 16B
110 (US 87)
110
Exit 145
125
Exit226B
140
Exit 20
US-491
U&64
US-64
US-160
US-191
US-191
+ FM 755 US-281
+ US-28IUS-59 -
+ US-59 Ramp
+ RatnpT37
+ r 37 Exit 133
+ Exit 133 1410
+ l410ExkI6B
+ Exit 16B110
(to TX/NM State Line)
+ 110 Exit 145
+ Exitl45I2S
+ 125 Exit 226B
+ Exir226BI40
+ 140 Exit 20
+ Exit 20 US-491
+ US-491 US-64
(to NM/AZ State Line)
+ US-64 US-160
+ US-160 US-191
(to AZ/UT State Line)
Blanding. UT, 84511
11.5
,101.5
5.8
0.3
76.9
0.6
282
02
563.0
192
1.0
226.4
0.7
137.6
0.2
91.2
21.9
4.1
29.2
5.2
51.1
11.5
113.0
L18.7
119.0
196.0
196.5
224.7
224-9
787.9
807.1
808.1
2034.5
1035-1
1172.8
1173.0
1264.2
1286.1
1290.2
1319.5
1324.6
1375-8
Mestena Uranium, LLC
Main Office
600 N. Shorefine Blvd. Sufte 700
Corpus Chtlfll. O! 76471
<36!) B9*-2m fOK [phone]
Cod (3o1) 816-6724
IsarhastVveiJenciJfCTirurti.corri
v&szmssi,
Ut.
rttino
n. toubty
r
L
JILfl
Mestena Uranium, L.L.C.
Acta Meca ProJ«ct
7fifiCR316
EnclncN IX 76353
[phone] «xf. 215
FCKttM) 56a-3764
Radial isepoiQxjineiiity 20 mala south of Falturriu. or. Hvy 2£|
ftom 2S1, wte FM 755 ivtsi approximately S miles.
The raw! *V't" with FV 430 $oiojf North aarf FM 755 gong Souih.
Ojrtfawmni 755 South, arid fctlow ft as \t IUW. w«t, wfil it imesCE(!. ^ M ,,4
wUowC.R.3IJfar«pproxhu»alcJy3cniIcs •
Turn-wcsi(left) at the large yellow f ate and follow the ro*( lo the plan'
Phase pork near the office end "nign in" ' fiaifcv«f
! !
! 1
1
I
fm ENERGY FUELS
Energy Fuels Resources (USA) Inc.
6425 South Highway 191, PO Box 809
Blanding, UT. US, 84511
435 678 2221, fax [phone]
www.energyfuels.com
February 18, 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: 1 le.(2) Byproduct Receipt Notification
Pursuant to Radioactive Materials License (RML) UT 1900479 condition 10.5.F, Energy Fuels Resources
(USA) Inc. is hereby notifying the Division of Radiation Control that the White Mesa Uranium Mill will be
receiving and disposing of forty loads of 1 le.(2) byproduct materials by April 14, 2014. These loads will be
coming in one per day from the Salt Lake City rail yard and will be the dirt/mud material similar to what has
been received so far this year.
If there are any questions regarding these shipments or the scheduling of the disposal activities feel free to
contact me at the White Mesa Mill at 435.678.2221.
David Turk
Environmental Health & Safety Manager
Energy Fuels Resources (USA) Inc.
cc: Denver Central Files
Generator of Byproduct material: Mestena
Controled Elevation used (Cell 3) 5613.04
Area Elevation Transit Shot
Initial shot for trench
Top of trench 5612.04
Bottom of trench 5605.84
Initial shot used for material
Top of material in trench 5606.96
8
9
15.2
8
14.08
Top of cell 3 Liner
Feet below liner
5608.5
1.54
Project C-2014-72
Memorandum RE: Inspection of November 13, 2014
Attachment 4
Copy of Packet for Load Bearing Shipper # 155
No.: PEL-10
-v. No.: R-3.1
Date: June 4, 2012
DENIS ON 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: fr\ 25,/H
Name of employee receiving the load: T^.n-y sL^L?
Generator of the Byproduct Material: /AcSfc.—
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:
Pi lrc/~ P'pc c^A, ^rre^^L. Sr.c (>\*-t£o a,^c\. f[*-^ic
Has each drum been inspected to identify the presence of any void spaces? AJ A -
Have all drums with void spaces been filled with tailings sands or soil? AS At .
Which tailings cell was the material placed in? U ^
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 OPERATLNG PROCEDURES
Title: 1 le-.(2) Byproduct Disposal
Pace 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? fe
Documentation of approv
Was the ISL material segregated from disposed Mill material and other
ISL material? '/a
Refer to plat(s) used to confirm. £*H3 ilc Z. /2-if?csa(
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? &5
Refer to drawings used to confirm 3 /).'ct^,^£-
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. £cil 3 faflr^^^
Will the elevation of the material exceed the plane or grade of the
elevation of the uppermost flexible membrane liner of the cell?
Me
How , was this confirmed (e.g., survey or review)
iP
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?
Vc>
Was the shipment properly covered?
Are additional settlement monitors required to be placed for this generator?
_/i/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
A/A
Radiological receipt survey measurements:
5,5 ^Rj Ur PXt> - Q
Breathing Zone:
1. Was a Breathing Zone Sample collected? Yes o/No^)
2. If yes, what were the results of the sampling?
Was a photograph taken during the unloading activities?/Yespr No
1
r - ' V -~r - 1
BILL-OF-LADING
SHIPMENT ID# 155 SHIPMENT DATE: June 23, 2014
SHIPPER (From):
MESTENA URANIUM LLC
CONSIGNEE (To):
Energy Fuels Resources (USA) Inc.
6425 South Highway 191
Blanding. UT 84511
ADDRESS:
755 Co. Rd. 315 Kncino, TX 78353
ADDRESS:
P. O. Box 809, Blanding UT 84511
SHIPPER LICENSE NO.: RO5360 SHIPPER USDOT NO.: CONSIGNEE
LICENSE NO.
UT-1900479
CONSIGNEE TELEPHONE NO.
[phone]
SHIPPER LICENSE NO. SHIPPER TELEPHONE
NO.:361-561-4780
CARRIER NAME AND ADDRESS:
Greenfield I .ogistics, LLC
CARRIER USDOT CARRIER HAZMAT REG. NO.:
Trailer # Contained GFLU 001092 Seal# 0000389 Seal # 0000390
HM DESCRIPTION OF MATERIAL AND PACKAGING VOLUME
Cubic feet
or
QUANTITY
CLASSIFICATION
1 pkg.
RQ
UN2913. Radioactive Material. Surface Contaminated
Objects (SCO-1), non-fissile,, Class 7
Dry 11 (E).2 By-Product material.
Activity: 2.0 1-6 Bq (5e-5 Ci)
EMERGENCY CONTACT:
P. Luthiger: 1-361-816-0150
28,000 lbs.
(gross)
Surface contaminated objects
(SCO-1)
Exclusive use shipment
Placards applied
CERTIFICATION: These is to certify that the above named articles are properly classified,
described, packaged, marked and labeled, and are in proper condition for transportation,
according to the applicable regulations of the Department of Transportation.
\
Shippers Signature: H. Date: T^JV/V/1/
Driver's Signature: £k^L fa CLqM -Date:
RecOAijeJ (p-25-/4 AiUJ^
Mestena Uranium, LLC
SHIPPER'S
RELEASE AUTHORIZATION FOR BY-PRODUCT MATERIAL
DESTINATION: Energy Fuels Resources (USA) Inc. - White Mesa Mill
6425 S.Hwy 191
Blanding, UT 84511
SHIPMENT NUMBER: 155
NAME OF DRIVER: "D^,<, %. r\^.M
DESCRIPTION OF MATERIAL: By-product material from an in-situ uranium mining
operation. (Sand, filter cloths, mud)
DRIVER: £Liw/fo (X^lJL
^ Signature /y
By execution below, it is represented that the byproduct material being transported is properly
classified, described, loaded and labeled; and, that the byproduct material is completely
contained and in proper condition for transportation, according to the applicable regulations for
the state and federal transportation departments.
The shipper certifies the byproduct material is not listed hazardous waste as defined in the
Resource Conservation and Recovery Act, as amended, 40 CFR 261 et. seg. or comparable state
laws. The byproduct material has no been mixed or commingled with hazardous waste as
defined in 40 CFR 261 et. seq.. No processes are operated on the site which are RCRA-listed
processes as defined in 40 CFR 261 et. seq. All of the Byproduct Material is byproduct material
defined under the Atomic Energy Act of 1954 as amended, 42 U.S.C. § 2014(e)(2) and 10
CFR§40.4(a-i).
DATE: l^ifhflH BY: 9rLj.lL .
Sjgnature
MESTENA URANIUM LLC
D.O.T. RADIATION SURVEY RELEASE RECORD
Survey Date f --7 Technician
Model
Model
Alpha Survey Instrument
Serial Number -x|2/5'i Efficiency Q , 2.0<b
(1
Gamma Survey Instrument
Serial Number 2.} j> l
SHIPMENT* 1$V~ I STS" Shipment Type %M ^frcj^f-
Gamma
Contact
(uR/hr)
Gamma
2 meters
(uR/hr)
Alpha
Removable
(cpm)
Comment
Cab of Truck 3°. N/A N/A
Trailer - Rear S° N/A
Trailer - Driver Side %0 N/A
Trailer - Passenger Side LLO LLO N/A
Trailer - Front AD 21 N/A
Trailer - Bottom N/A N/A
Trailer - Left door N/A N/A </0
Trailer - Right door N/A N/A
Trailer - Handle N/A N/A
Trailer - Tires N/A N/A
Tractor Cab - Tires N/A N/A
Tractor Cab - Floorboard N/A N/A
Placards Installed:
Comments
: (YESy> NO Seals Provided U ^'f ^skU
MESTENA URANIUM LLC
RADIATION SURVEY - D.O.T. PACKAGE
Survey Date ^ -/fc -/ L( Technician
Alpha Survey Instrument
Model \Xid \2i Serial Number Z'Z I S / Efficiency d. 16 &
Model
Gamma Survey Instrument
Serial Number Z/ ? }%
Package S/N &^~U 00 \ G *\Z^ Package Capacity (yd3) 2-5
Contact
Gamma
(uR/hr)
Alpha
Removable
(cpm)
Comment
Package - Rear Left 7oO 0
Package - Rear Right
Package - Driver Side - Left f ooo
Package - Driver Side - Right /OOO 2_
Package - Passenger Side - Left z
Package - Passenger Side - Right
Package - Front - Left
Package - Front - Right
Package - Bottom - Left AJ/A AJlA
Package - Bottom - Right AJ/A
D.O.T. Markings/Labels Installed on Package: (J(E
Comments ^ r o st^l/r/j? /V--
NO
Radiation/Contamination Limits
Gamma (contact reading) - 200 milliRem/hr
Removable (U nat - low toxicity alpha emitter) - 220 dpm/cm2
ririLi.irNfc AJMJ HALAKDU U S MATERIALS SAFETY ADMINISTRATION
HAZARDOUS MATERIALS
CERTIFICATE OF REGISTRATION
FOR REGISTRATION YEAR(S) 2013-2016
Registrant: MESTENA URANIUM LLC
Attn: MICHAEL MAXSON
500 N SHORELINE STE 700
CORPUS CHRIST!, TX 78401-0326
This certifies that the registrant is registered with the U.S. Department of Transportation as required by
49 CFR Part 107, Subpart G.
This certificate is issued under the authority of 49 U.S.C. 5108. It is unlawful to alter or falsify this
document.
Reg. No: 052413 550 028VX Issued: 05/24/2013 Expires: 06/30/2016
HM Company ID: 106513
The following must be maintained at the principal place of business for a period of three years from the
date of issuance of this Certificate of Registration:
(1) A copy of the registration statement filed with PHMSA; and
(2) This Certificate of Registration
Each person subject to the registration requirement must furnish that person's Certificate of Registration
(or a copy) and all other records and information pertaining to the information contained in the registration
statement to an authorized representative or special agent of the U. S. Department of Transportation upon
request.
Each motor carrier (private or for-hire) and each vessel operator subject to the registration requirement
must keep a copy of the current Certificate of Registration or another document bearing the registration
number identified as the "U.S. DOT Hazmat Reg. No." in each truck and truck tractor or vessel (trailers
and semi-trailers not included) used to transport hazardous materials subject to the registration
requirement. The Certificate of Registration or document bearing the registration number must be made
available, upon request, to enforcement personnel.
For information, contact the Hazardous Materials Registration Manager, PHH-52, Pipeline and Hazardous
Materials Safety Administration, U.S. Department of Transportation, 1200 New Jersey Avenue, SE,
Washington, DC 20590, telephone [phone].
Record Keeping Requirements for the Registration Program
Alta Mesa Project
EMERGENCY PROCEDURES
Guide 162
Radioactive Materials (Low to Moderate Level Radiation)
POTENTIAL HAZARDS
Health * Radiation _
tnmjKKtition aeadeng. Pnrfcagiay durability inemMec »* potential tram! nf rarfirwrtw mi5»nf {.ym^
• Undirmgcd packages sitt safe. Comeots of ibmwged packages na./ cause higher external rudHatiaii exposure, or both cwimal end internal tidafioa exposuie if comews ire released. • Low rad&tkm hazard wbanuir^aWjuistdecc^ released fixmpadcii^ca-banc container,
bazaoJ win vary fiom law 10 taodasce. • Level of bazard win depend OQthe type and amount of radioactivity, the land of material icisin, write (he surfaces it to oa.
• SCHTC potent tnay be rcltascii from pac^
fire** « Released radioactive numvinh or contmoinatsd objects usually will be visible if pacbuoas feUx.
« Some exclusive DM shipments of ball: and packaged materials will not have RADIOACTrVBTnbab. Placards.
rmrHngs sad shipping papora provide irfiwtifjfattoa. • Same packages may have a RADIOACTtVEIabol in d&Geco<^faa2anlbbeL The second hozwl is usually
greater dun too radiation hszatdso follow this. GUIDE is well ss tlie response GUIDE for (be second hazard* class
label. • Same radioactive mamritiU cannot be detected by commonly available iiutnimeors.
• Runoff from control of cargo fire may cause low-level pollution.
Fire or •SoaSe^ilhSmSnltowiyTwS^
» CALL Emetyqr P«T TcUphnfM Nomfrer Oc Shipping taper Hat, gShipping Faper not available or no nawcr, rcfa- to appCTprtatg telephone nnpihr'rPttcdat tbtacAofftUg atcrlon. • Mottoes tor rescue, litvn ling, flnt aid, On control and other hazards are higher than the priority for measuring nuttadon levds.
4 R^dlodoa Autfwaty must be notified of accident oomfitiofls. Radiation Authority is usually responsible for decisions about
radiological cxiaseqtieiiccs and closure of eowrgeocies. 4 As an immediate precautionary mmnr., isolate spill or leak area for ai least 25 meters (75 fccO in all directions. • Swy upwind. * Keep unwrhorlrrd personnel away. - --• Detain or Itnlstr iininjirod persons ty eqapnrnr.SKpected to he oonnuntaaxsdioelay d^coaumiiation end cleanup until unsrvctiOQS arc received from Radiation Antbority.
protective • Positive pretctse aelf-cootaincd breathing apparatus (SCBA) and attuctural tuefightots'pnxective clothing will
Clothing provide adrqmfir ptoceetiaa.
evacuation UtySpfiT
• Consider initial downwind evacuation for at least 100 maters (330 feet).
* Kn alaty ciiaotity of (his. mtrrriHl it invcived tna maprfire. cocsidcr to imrjalcvgcuatioa distance of 300
i OWO fceO in «H fireerJoos.
EMERGENCY RESPONSE
FIrv • Fieacneaofiiadlnigrvfcinai^^
• Move <^aiuiueii fcoao. fire area if you can <fc) it without risk.
• Do got snore danafjed packagesaatove nndamaged packages oat of fire zone.
SmmUKna 4 DocheofctiOOL, Water s«yc*te£ular foam.
• I^fi»o-c«wol waterlorii^tthy^
Spill or * Donottooeh
* AvertaftaT 4 DicetnooSocl
* Cover powder
otspOkdi.
pllitic sheet or tan? to i
pttQdqr overt •ccwdtflfto the Mom of rheinjuy. «rased«b^itj^rieoDii.
First Aid 4 rise fint aid 4 Do
4 Oire t sf*icrnulsii(<bje«tfcrng.
4 AiailinntBl OS^njDD rf bPMCMBgis ^tW^*J
•* fr«*«>«rff««*»a^-*«« rntiin • i —TJ~- frrtn tVin innw«,ll*T«ly^hfh T*-1" " "^"^ r^^^g v-nrin-furntieinitZO
4 Iiga^pcracw coot«min«trdbyootitict with released ma uid^ ascdooi hszsrd to ry^Mit^pctBOBBcl,
equlpmeat or fnrilirirm
« Ensure that mrrfiral peooanel ne aware of the materitl(s) involved and take ptecarttions to pcotect themselves and
prevent spread of coatatninaiion.
DRIVER INSTRUCTIONS
Pursuant to 49 CFR 173.427, specific instructions for maintenance of exclusive
use shipment controls shall be provided by the offeror to the carrier. Such
instructions must be included with the shipping paper information.
The following instructions are to be adhered to in the delivery to Dennison Mines
Blanding, Utah Facility:
1. Directions to Dennison Mines Blanding, Utah facility are enclosed.
2. Drivers are not to climb onto top of trailer during routine vehicle safety
checks.
3. Emergency response actions and telephone numbers are included In
the shipping papers.
4. Contact Mestena Uranium LLC at 361-561-4780 (call collect) if any
suspicious activities or incidents occur during delivery.
TRANSPORT ROUTE
St/Prv Route Interchange Leg Total
TX East
NM
AZ
UT
North
North
Left
North
Bear right
West
Bear left
West
West
Bear right
North
Bear right
West
Bear right
North
West
West
West
North
North
FM755
US-28I
US-S9
Ramp
137
Exit 133
1410
Exit 16B
110 (US 87)
110
Exit 145
125
Exk226B
140
Exit 20
US-49J
US-64
US-64
US-160
US-191
US-191
+ FM755US-281
+ US-28I US-59 -
+ US-59 Ramp
+ RampT37
+ 137 Exit 133
+ Exit 133 1410
+ I410Exhl6B
+ Exitl6BI10
(to TX/NM State Line)
+ 110 Exit 145
+ Exit 145125
+ 125 Exit 226B
+ Exit226BI40
+ 140 Exit 20
+ Exit 20 US-491
+ US-491 US-64
(to NM/AZ State Line)
+ US-64 US-160
+ US-160 US-191
(to AZ/UT State Line)
Blending. UT. "84511
1L5
,.101.5
S.8
0.3
76.9
0.6
28.2
02
563.0
19.2
1.0
226.4
0.7
137.6
02
912
21.9
4.1
29.2
5.2
51.1
1LS
113.0
118.7
119.0
196.0
196.5
224.7
224.9
7*7.9
807.1
808.1
1034.5
1035.1
1172.8
1173.0
1264.2
1286.1
1290.2
1319.5
1324.6
1375-8
Mestena Uranium, LLC
Main Offica
600 N. Shoreftne Btod, Sufte 700
Corpus ChJWL XX 76471
<36l) Fox [phone]
tsqttnasCrriesJ^GtfcTihtm.ayTi
j*r
«eris
Sfrgltft
Radiol fe approxtoeicly 20 ruiica south of Falfimias. or, Hvy 2« I
Mestena Uranrum, L.LC.
Alta M«*a FroJ«ct
766 CU 316
Enolno, IX 7C3S3
(361) $61-4780 OXf. 215
from 2SJ, uVe FM 755 wtsi approximately 8 miles.
The rowf *=yV with FM -ttO 50% North and FM 7IS goitu; South
Ojtewnf 755 South, art fellow it as if lui*s wo^naft it Chwty Rd 3M
{There vdl be a road to the ushl). At Ihe imerseclfon, (uro northCrishtl mi
follow CU. 315 fcu-approxiwatcly 3 miles. "
Turnwest(left) ai the large yeflow gote and follow the road <o the pUt*
Phase park neaUhe office and "sign in"
By-Product Material Shipment Forms List
1. Vehicle Survey
2. Bill of Lading
3. Shipping Paper
4. Release Authorization for By-Product Material
5. Hazardous Materials Certificate of Registration
6. Driver Routing Instructions
7. Emergency Procedures Instructions
SHIPPER'S
RELEASE AUTHORIZATION FOR BY-PRODUCT MATERIAL
DESCRIPTION OF MATERIAL: By-product material from an in-situ uranium rninirig
operation. (Sand, filter cloths, mud)
By execution below, it is represented that the byproduct material being transported is properly
classified, described, loaded and labeled; and, that the byproduct material is completely
contained and in proper condition for transportation, according to the applicable regulations for
the state and federal transportation departments.
The shipper certifies the byproduct material is not listed hazardous waste as defined in the
Resource Conservation and Recovery Act, as amended, 40 CFR 261 et. seg. or comparable state
laws. The byproduct material has no been mixed or conamingled with hazardous waste as
defined in 40 CFR 261 et. seq.. No processes are operated on the site which are RCRA-listed
processes as defined in 40 CFR 261 et. seq. All of the Byproduct Material is byproduct material
defined under the Atomic Energy Act of 1954 as amended, 42 U.S.C. § 2014(e)(2) and 10
CFR§40.4(a->).
DESTINATION: Energy Fuels Resources (USA) Inc. - White Mesa Mill
6425 S.Hwy 191
Blanding, UT 84511
SHIPMENT NUMBER: 155
NAME OF DRIVER:
DATE: ZZJvtfiH BY: TTLLA
06-23.-'1 4 09:00 FR0M-T-335 P0002/0008 F-673
By-Product Material Shipment Forms List
1. Vehicle Survey
2. Bill of Lading
3. Shipping Paper
4. Release Authorization for By-Product Material
5. Hazardous Materials Certificate of Registration
6. Driver Routing Instructions
7. Emergency Procedures Instructions
06-23-'14 09:00 FR0M-
Survey Date
T-335 P0003/0008 F-673
MESTENA URANIUM LLC
D.O.T. RADIATION SURVEY RELEASE RECORD
Technician
Alpha Survey Instrument
Serial Number ^[n^j Efficiency p. Lcfo Model
Model
Gamma Survey Instrument
_____ Serial Number 21 j>\
SHIPMENT # 7VP~ I Shipment Type fyprej^'h
Gamma
Contact
(uR/hr)
Gamma
2 meters
(uRJhr)
Alpha
Removable
(cpm)
Comment
Cab of Truck 2^ N/A N/A
Trailer - Rear N/A
Trailer - Driver Side 10 N/A
Trailer - Passenger Side LLO //O N/A
Trailer - Front AO 21 N/A
Trailer - Bottom 10 N/A N/A
Trailer - Left door N/A N/A
Trailer - Right door N/A N/A
Trailer - Handle N/A N/A
Trailer - Tires N/A N/A
Tractor Cab - Tires N/A N/A
Tractor Cab - Floorboard N/A N/A
Placards Installed: (Y£®^ NO Seals Provided
Comments
06-23.-' 1 4 09:00 FR0M-T-335 P0004/0008 F-673
MESTENA URANIUM LLC
RADIATION SURVEY - D.O.T. PACKAGE
Survey Date ^ -/1/ Technician
Alpha Survey instrument
Model Iwwt (3. Serial Number Zrc\^\ Efficiency ^.26^
Gamma Survey Instrument
Model U^cfW R Serial Number Zl%}%
Package S/N G-^LU Q0\O<\2^ Package Capacity (yd3) Z-5
Contact
Gamma
(uR/hr)
Alpha
Removable
(cpm)
Comment
Package - Rear Left
Package - Rear Right
700
Package - Driver Side - Left
Package - Driver Side - Right SL
Package - Passenger Side - Left SOD Z
Package - Passenger Side - Right
Package - Front - Left
Package - Front - Right 5~0 0
Package - Bottom - Left A//A
Package - Bottom - Right MA
D.O.T. Markings/Labels Installed on Package: (YB
Comments m st J /V.
NO
Radiation/Contamination Limits
Gamma (contact reading) - 200 milliRem/hr
Removable (U nat - low toxicity alpha emitter) - 220 dpm/cm2
06-23-' 1 4 09:00 FROM- T-335 P0005/0008 F-673
©HAZARDOUS MATERIALS
CERTIFICATE OF REGISTRATION
FOR REGISTRATION YEAR(S) 2013-2016
Registrant: MESTENA URANIUM LLC
Attn: MICHAEL MAXSON
500 N SHORELINE STE 700
CORPUS CHRISTI, TX 78401-0326
This certifies that the registrant is registered with the U.S. Department of Transportation as required by
49 CFR Part 107, Subpart G.
This certificate is issued under the authority of 49 U.S.C. 5108. It is unlawful to alter or falsify this
document
Reg, No; 052413 550 02SVX Issued: 05/24/2013 Expires: 06/30/2016
HM Company ID: 106513
Record Keeping Requirements for the Registration Program
The following must be maintained at the principal place of business for a period of three years from the
date of issuance ofthis Certificate of Registration:
(1) A copy of the registration statement filed with PHMSA; and
(2) This Certificate of Registration
Each person subject to the registration requirement must furnish that peison's Certificate of Registration
(or a copy) and all other records and information pertaining to the information contained in the registration
statement to an authorized representative or special agent of the U. S. Department of Transportation upon
request.
Bach motor wrier (private or far-hire) and each vessel operator subject to the registration requirement
must keep a copy of the current Certificate of Registration or another document bearing the registration
number identified as the "U.S. DOT Hazraat Reg, No." in each truck and truck tractor or vessel (trailers
and semi-trailers not inoluded) used to transport hazardous materials subject to the registration
requirement The Certificate of Registration or document hearing the registration number must be made
available, upon request, to enforcement personnel.
For information, contact the Hazardous Materials Registration Manager, PHH-52, Pipeline and Hazardous
Materials Safety Administration, U.S. Department of Transportation, 1200 New Jersey Avenue, SE,
Washington, DC 20590, telephone [phone].
06-23.-'1 4 09:00 FR0M-T-335 P0006/0008 F-673
EMERGENCY PROCEDURES
Guide 162
Radioactive Materials (Low to Moderate Level Radiation)
POTENTIAL HAZARDS
imnpiKtaaoa«ceioeais. fortagagAinftflgy jnuwB asp&feai&l taztttiof redtowdw content increases.
borTi rxffraii w^StenrtftwdMoawpowft ifaanmo are released,
h«»rt will vaiyftom tow »iwxJmue. t Level of lim.»tt! Viin dej>«"J oc (fa type end BmouiU of ca&oacdyiiy, ihttindat material it is Kwdteto* sw&sesUbaa.
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• Same radtacfivc wtKartiife cannot to 4etMttd by coaunoiily uvtfUblc iiMtwroeds.
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06-Z3-' 1 4 09:01 FROM- T-335 P0007/0008 F-673
Pursuant to 49 CFR 173.427, specific instructions for maintenance of exclusive
use shipment controls shall be provided by the offeror to the carrier. Such
instructions must be included with the shipping paper information.
The following instructions are to be adhered to in the delivery to Dennison Mines
Blanding, Utah Facility:
1. Directions to Dennison Mines Blanding, Utah facility are enclosed.
2. Drivers are not to climb onto top of trailer during routine vehicle safety
checks.
3. Emergency response actions and telephone numbers are included in
the shipping papers.
4. Contact Mestena Uranium LLC at 361-561-4780 (call collect) if any
suspicious activities or incidents occur during delivery.
TRANSPORT ROUTE
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TX Bast
North
North
Left
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West
NM West
Boer right
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Bw right
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UT North
FM755
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US-59
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137
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UIO
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110 (US 37)
110
Exii 145
125
Exit226B
140
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US-491
US-64
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US-191
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i-US-231
+ VS-S9 RBmp
+ RaropT37
+ 137Exit 133
+ KXit 1331410
+ l410Exfcl<5B
+ Exitl6BIlO
(to TONM State Line)
+110 Exit 145
+ Exic 145125
+125 Exit226B
+Exit226BI40
+ 140 Exit 20
•+Exit 20 US-491
+ US-491 US-64
(to NM/AZ State Uos)
* US-64 US460
+ US-160 US-191
(WA2AJT State Une)
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06-23-'1 4 09:01 FR0M-T-335 P0008/0008 F-673
1
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Mestefia Uranium, LLC.
fiacM bcppuHdmeitily M mile* ftMUntu, ORHwySSi.
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Ptew« par* a«r (he office tnti *iiign io''.
r
fm ENERGY FUELS
Energy Fuels Resources (USA) Inc.
6425 South Highway 191, PO Box 809
Blanding, UT. US, 84511
435 678 2221, fax [phone]
www.energyfuels.com
June 24, 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) UT 1900479 condition 10.5.F, Energy Fuels Resources
(USA) Inc. is hereby notifying the Division of Radiation Control that the White Mesa Uranium Mill will be
receiving and disposing of two loads of 1 le.(2) byproduct materials by July 7, 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
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Generator of Byproduct material: Mestena
Controled Elevation used (Cell 3) 5613.04
Area Elevation Transit Shot
Initial shot for trench
Top of trench 5610.22
Bottom of trench 5600.47
Initial shot used for material
Top of material in trench 5607.02
5.4
8.22
17.97
5.4
11.42
Top of cell 3 Liner 5608.5
Feet below liner 1.48
Project C-2014-72
MemorandumRE..lnspec,iono|.NovemberU2o
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Attachment 5
of Burial Locations in Cell 3
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Mem0randUmRE''-Pectio„„fNoveniber 13,2014
Standard rv - Attachrnent 6
dard0peratin§ Procedure PB/-,o Re • •
u, Kevision 3.3
No.. PBL-10
Rev. No.: R-3.3
Date: November 13,
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATrNG 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
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. T he 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: 11 e.(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 OPERATPNG 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 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-3.3
Date: November 13,
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 11 e.(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. Ifthe 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. Ifthe shipment is determined to be acceptable, the following procedures will be followed:
a) Ifthe 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.
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 lie.(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: 11 e (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:
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.
End Dump Trailer
Intermodal Container
Standard Container Trailer
SOP PBL-9
SOP PBL-2
SOP-PBL-2
9.0 Hazard Identification and Safety
Required Personal Protective Equipment (PPE)
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-3.3
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.
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
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: I le.(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)
Driver (Signature)
Scale House Operator
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
lle.(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: 11 e.(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