DRC-2013-001422 - 0901a06880353460

ENERGYFUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
VIA EMAIL AND OVERNIGHT DELIVERY
February 27, 2013
Mr. Rusty Lundberg
Director of the Utah Division of Radiation Control
State of Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84116-4850
Re: White Mesa Uranium Mill - RML UT1900479
Engineering Module 73 and Standard Operating Procedure C'SOP") PBL-10 and
Request for Information ("RFI")
Dear Mr. Lundberg: DRC-2013-001422
This letter responds to the Division of Radiation Control ("DRC") comment letter and RFI dated
January 14, 2013 regarding inspections, conducted pursuant to Engineering Module 73 and SOP PBL-
10, of lle.(2) byproduct disposal at the White Mesa Mill throughout 2012. For ease of review, each
DRC comment or request is provided verbatim in italics, below, followed by Energy Fuels Resources
(USA) Inc.'s ("EFRI's") response.
DRC Comment #1
EFR has an approved Standard Operating Procedure, No. PBL-1 0, 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 II e. (2) byproduct material.
EFRI Response #1
No response required.
DRC Comment #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.
EFRI Response Wl
No response required.
N:\WMM\Inspections and NOVs\RML Inspections and NOVs\02.28.13 rspnse to 02.15.13 insepction Itr 1 le2\02.28.13
response to 01.14.13 inspection Itr 11 e2.doc
Letter to Rusty Lundberg
February 27, 2013
Page 2 of 5
DRC Comment #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 12112-16 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 not take exception to the practice
observed, but does have concern that a nonconforming load may create a compliance dilemma upon
rejecting the load.
EFRI Response #3
During a telephone discussion with Russ Topham of DRC on January 22, 2013, EFRI clarified that
"inspection at the point of receipt," which is normally done at the un-tarping station where loads are
normally opened and inspected, is inside the Mill's restricted area, just as the tailings Cell 3 area is
inside the Mill's restricted area. We also clarified that "inspection at the point of receipt" was not
designed to facilitate rejection of loads without decontamination. The point of receipt location (the
un-tarping station) simply allows for easier and safer inspection, since the Mill personnel can climb
atop the inspection platform to more easily view the contents of the uncovered container. However, as
far as decontaminating and releasing a potentially rejected load, there is no difference in compliance
requirements, whether a load is uncovered and inspected at the "point of receipt" or the tailings area
(or any other location within the restricted area). Since both the un-tarping station and the tailings area
are within the restricted area, both require decontamination prior to release as indicated in Section 8.0
of SOP PBL-10.
Nevertheless, EFRI does agree to clarify the SOP specifically to allow inspection of loads at the
disposal cell area, as discussed under our response to DRC's Request for Information, below.
DRC Recommendation #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.
EFRI Response #4
EFRI has changed the form to include a space to identify the load. A proposed amended SOP PBL-10,
Revision No. 3.2, which contains this and other changes, as discussed in the response to the Request
Letter to Rusty Lundberg
February 27,2013
Page 3 of 5
for Information, is provided in Attachment 1.
DRC 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.
EFRI Response
Thank you for your concem. As discussed with Mr. Topham on January 22, 2013, EFRI evaluated
whether the decontamination and release procedures cited referenced in SOP PBL-10 are robust
enough to ensure that a container bearing a rejected load can be surveyed to achieve release criteria,
whether the rejection occurs at the point of receipt or anywhere else within the restricted area. EFRI
has evaluated the current procedures, release criteria, and release SOPs, and has confirmed that the
circumstance described by Mr. Topham as a potential concem could not occur. The Mill has never
encountered, in over 32 years of operation, a situation in which a container was received with the
restricted area and could not be released. Any conveyance or container which enters the restricted
area, regardless of contents, can be decontaminated and/or repackaged to meet the appropriate DOT
release requirements. EFRI has adequate commercial arrangements with the generators of the ISL
lle.(2) material to address any situation in which materials or conveyances must be rejected and
additional measures or costs are involved to ensure release of the conveyance and retum to its
originator.
Nonetheless, although EFRI has determined that no changes to the decontamination and release
procedures are required, EFRI has chosen to make some changes to the lle.(2) Byproduct Disposal
SOP. We have provided in Attachment 1 an amended SOP PBL-10, Revision 3.2 which includes the
following changes. The revised SOP:
• Includes language that specifically allows inspection of loads at either the un-tarping station, or
in other areas as is the case under extremely cold conditions,
• Adds a location on the 1 le.(2) Byproduct Disposal Documentation Form to identify the load,
• Assigns certain responsibilities to the Mill's Radiation Safety Staff, in lieu of the RSO,
• Updates the title "Executive Secretary" of the Division of Radiation Control to "Director," and
• Updates the company name to EFRI.
Letter to Rusty Lundberg
Febmary 27,2013
Page 4 of 5
If you have any questions, please contact me at [phone].
Yours very tmly.
ENERGY FUELS RESOURCES (USA) INC.
Jo Ann Tischler
Manager, Compliance and Licensing
cc David C, Frydenlund
Phil Goble, Utah DRC
Dan Hillsten
Ronnie Nieves
Harold R. Roberts
Russ Topham, Utah DRC
David E. Turk
Kathy Weinel
Attachments
No.: PBL-10
Rev. No.: R-3.2
Date: Deoembor 18,
3012JQnuaFy
February 2733.2013
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Titie: 1 le (2) Byproduct Disposal
Pagel ofl33
1.0 Purpose
Energy Fuels Resources (USA) Inc, ("EFRI") receives lle.(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
feis-their 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 designeeRSORadiation Safety Personnel' will €ilse-verify,
prior to receipt ofany 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
' Radiation Safety personnel consist of appropnatelv trained personnel from the Mill's Radiation. Environmental, or Safety Departments.
No.: PBL-10
Rev. No.: R-3.2
Date: December 18,
2012JQnuarv
February 2733.2013
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Titie: 1 le (2) Byproduct Disposal
Page 2 of 133
3.0 Designated Disposal Area
The Environmental Coordinator, or their designeeRSORadiation Safety Personnel will designate from
time to time one or more designated disposal areas (each a "Designated Disposal Area") being a
general area within a tailings 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
fiilly 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
Executive SecretarvDirector of the Utah Division of Radiation Control (the "Director") for this
purpose.
8. Prior written approval must have been obtained from the DirectorExocutive Seorotary of the
Utah Radiation Control Board (the "Executive SecTetaryDirootor"4-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
No.: PBL-10
Rev. No.: R-3.2
Date: Dooombor 18,
20iajQnuarv
February 2733.2013
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Titie: 1 le (2) Byproduct Disposal
Page 3 of 133
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.
4.0 Notification to DirectorExccutivc Sccrctftfv
EFRI shall notify the DirectorExecutive Seorotary in vsriting 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 expertRadiation Safety Personnel 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 designeeRSO that the
shipment has been ^proved 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 EnvironmontalRadiation SofetvRadiation Safety
Department so that the shipment can be escorted by EnvironmontalRadiation SafetyRadiation
Safety personnel to the Designated Disposal Area specified by the RSQEnvironmental
Coordinator.
6. Prior to transporting material to the Designated Disposal Area (depending on weather), the
driver will be instructed to open or untarp the load. The load may be opened or untarped at the
un-tarping station or at other locations as described under item c. below.The Environmental
personnel and the transportation-eatpeftRadiation Safety personnelRadiation Safety personnel
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
RSQEnvironmental Coordinator,
No PBL-10
Rev No R-3 2
Date Deoembor 18,
2012JQnuafy
February 2733.2013
ENERGY FUELS RESOURCES (USA) INC
STANDARD OPERATING PROCEDURES
Titie 11 e (2) Byproduct Disposal
Page 4 of 133
a Any byproduct matenal suspected of not conformmg to Section 2 0 of this SOP will
not be transported to the disposal site, unless a determination is made by the
RSOEnvironmental CoordmatorRadiation Safety Personnel that the matenal m
question conforms to Section 2 0 of this SOP
b ^Barrels containing soil or sludges shall be checked to determme if they are full pnor
to transportmg them for disposal Bairels not completely full shall be documented
and shall be filled with tailings or soil pnor to disposal (License Condition 10 5 B)
fe-c If weather conditions exist that makeo the opening of the convoyanoe imposoiblo at
the untarpmg station. y^eThe Environmental-Radiation Safety 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 matenal was to fall
out of the conveyance, that contamination issues will not be mcurred An example
area could be the tailings impound area near the disposal site
6.0 Byproduct Matenal Unloadmg
1 The RSG-Environmental Coordmator will specify the specific location withm 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
CoordmatorRSG will ensure that all byproduct matenal will be segregated from any Mill
-matenal and equipment disposed of in the cell pursuant to Mill license condition 10 4, and that
the byproduct matenal from each ISL source will be segregated from the byproduct material
from all other ISL sources
2 EnvironmentalRadiation SafetyRadiation Safety personnel will escort the shipment to the
designated location in the Designated Disposal Area for unloading of the byproduct matenal
3 Proposed Methods and Procedures to Fully Protect the Lmer While Accessing Tailings
Cells for Disposal of ISL Byproduct Matenal and Mill Equipment
a The shipment will be transported to the Designated Disposal Area only on established
roadways onto the tailmgs cells
b At no time will a shipment be transported over or m a manner that will damage
unprotected dikes, liners, other structures or settlement monitors associated with any of the
taihngs cells
c There must be at least 4 feet of tailmgs sands under the Designated Disposal Area
(documentation of the disposal area must be completed and on file pnor to any disposal
activities),
d The Designated Disposal Area must be located at least 12 feet from the sides or dikes of
the tailmgs cell (documentation of the disposal area must be completed and on file pnor to
any disposal activities),
e No travel into the disposal area will be allowed unless the disposal cell liner is covered
Fonnatted List Paragraph, No bullets or
numbenng, Widow/Orphan control
No PBL-10
Rev No R-3 2
Date Deoember 18,
2013JQnuarv
February 2733.2013
ENERGY FUELS RESOURCES (USA) INC
STANDARD OPERATING PROCEDURES
Titie 11 e (2) Byproduct Disposal
Page 5 of 133
by at least 18 mches of soil or fill matenal at the point of access
If the 7 calendar day notice referred to m 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 shippmg
contamer (that is, the contamer-bm or trailer) on site until the required 7 day notice has been
given and the 7 calendar days have lapsed
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,
the byproduct matenal will then be unloaded in the designated area. If such notice has not been
given or if such 7 day penod has not lapsed, then the byproduct matenal will be unloaded in an
area of the tailings cell that is not covered with mtenm 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 matenal will then be placed into the designated area,
b) If the matenal is m a self-unloading contamer, the dnver will be mstructed to unload ensurmg
all personnel are clear of the trailer and the immediate area. Byproduct matenal will be
dumped from the transport in a safe manner to minimize dust If the matenal requires
unloadmg by a fork truck, a ramp will be mstalled and unloadmg will proceed
c) After unloading, the Environmental Radiation SafetyRadiation Safety -personnel will visually
inspect the unloaded byproduct matenal to ensure that there is no newly discovered matenal
which does not match the matenal description on the shippmg manifest Any discrepancies
between the byproduct matenal received and the manifest information will be reported to the
RSQEnvironmental Coordinator Any byproduct matenal 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 determmation is made of its acceptability for disposal
d) After unloading, a photo of the unloaded matenal will be taken which is attached to the
shipping documentation for venfication of shipment contents
e) The location of the shipment of the byproduct material will be documented on the plat of each
Designated Disposal Area illustratmg the disposal area withm 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 mformation will be recorded on the Radiation Department's copy of the shipment
documentation The measurement range m mrem/hr at 2 meters, and the average measurement,
measured m 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 matenal to ensure that there are no organics present The
information will be recorded on the lie(2) Byproduct Matenal Disposal Documentation
FormEnvironmontalRadiation Department's copy of the shipment dooumontationprovided in
Attachment 2 to this SOP If organics are detected, the Environmental CoordinatorRSQ must
No PBL-10
Rev No R-3 2
Date Deoember 18,
2012JQnuorv
February 2733.2013
ENERGY FUELS RESOURCES (USA) E^C
STANDARD OPERATING PROCEDURES
Titie 11 e (2) Byproduct Disposal
Page 6 of 133
be advised, and no compaction or covenng activities relating to the shipment shall occur until
specifically mstructed by the Environmental CoordinatorRSQ The Environmental Coordinator
and Safety CoordinatorRSQ 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 CoordmatorRSQ will also contact EFR
corporate regulatory personnel and the shipper to verify that the detected organics are 1 le (2)
byproduct matenal from the shipper's ISL facility Once the Environmental CoordmatorRSQ
has venfied that the organics are byproduct material compaction and covenng activities will
proceed
h) A breathing zone sample will be taken penodically durmg unloading and cover activities If
the gross alpha exceeds 25% of the applicable DAC, then the RSO will be notified, and all
other unloadmg activities of byproduct matenal from that particular ISL site will require the
use of respiratory protection, until further notice by the RSO
i) After unloadmg the byproduct material, replace the tarp or close the trailer, unless the trailer is
being decontaminated for unrestncted 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 appropnate SWT
1) Shipment and disposal activities will be documented as descnbed in Section 10, below
7.0 Covenng of Byproduct Matenal
1 After the byproduct matenal has been accepted by the Environmental CoordinatorRSOr-er
theirhisRadiation Safety Personnel deoignoo. the byproduct matenal will be spread within the
designated area withm the Designated Disposal Area to facilitate compaction and covenng
2 The byproduct matenal will be compacted with at least four passes of the construction
equipment pnor to placing an additional layer
3 Free volumes m the byproduct material will be mmimized by filling, sectioning, or crushmg
Random fill or tailings sands will be used to fill voids m and around the byproduct matenal
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 venfied to be full pnor
to disposal Barrels not completely fiill shall be filled with tailmgs or soil
5 A one foot thick, or thicker, cover compnsed of native soil will be placed over the byproduct
matenal workmg area The fill and cover matenal will be compacted with at least one pass of
No PBL-10
Rev No R-3 2
Date Deoembor 18,
2012JQnuarv
February 2733.2013
ENERGY FUELS RESOURCES (USA) ESfC
STANDARD OPERATING PROCEDURES
Titie 11 e (2) Byproduct Disposal
Page 7 of 133
the construction equipment
6 The Environmental CoordmatorRSQ or theirhis designeeRadiation Safety personnel will
inspect the placement of the byproduct matenal prior to covenng to physically venfy that the
procedures in this Section 7 0 have been adequately performed
8.0 Decontammation and Release of Trailers and Trucks j
AU trailers and trucks will be decontammated after unloading pnor to leavmg the Mill Shippers
or transporters will notify EFR whether a specific trailer is to be| released for restncted or unrestncted
use Any trailers that are to be released for restncted use will] be decontammated accordmg to the
requirements contained in DOT Part 49 CFR 173 441(b) and 173 443 Any trailers that are to be
released for unrestncted use will be decontammated according to' the requirements found in Table 1 of
the Nuclear Regulatory Commission's (NRC's) Policy and Guidance Directive FC-85-23, "Guidelmes
for Decontammation of Facilities and Equipment Pnor to Release for Unrestncted Use or Termination
of Licenses for Byproduct, Source, or Special Nuclear Matenal"j issued May 1987 Trailers requinng
repair will be decontammated for unrestricted release, to facilitate repairs by the transporter at the
transporter's own site Trailers may be repaired without undergoing fiill decontamination if repaired
within the restricted area of the Mill j
For the appropnate decontamination procedures, refer to the following Standard Operating Procedures
for the appropnate conveyance
9.0
1
End Dump Trailer
Intermodal Contamer
Standard Container Trailer
Hazard Identification and Safety
Required Personal Protective Equipment (PPE)
SOP PBL-9
SOP PBL-2
S6P-PBL-2
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 wom m the! restncted area of the Mill Pnor to
disposal, the RSO will determme what level of respiratoryj protection, if any, will be required
Industnal 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 jMove at least 25 feet away from the
rear of the trailer durmg the mitial unloading operation ,
e) Dnvers must use caution durmg the unloading process and be aware of any overhead hazards
No PBL-10
Rev No R-3 2
Date Deoember 18,
2013JQnuorv
February 2733.2013
ENERGY FUELS RESOURCES (USA) INC
STANDARD OPERATING PROCEDURES
Titie 1 le (2) Byproduct Disposal
Page 8 of 131
f) Do not place any part of your body mside 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 entenng 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 intenor of a trailer
3 Mobile Equipment
a) Only trained and authorized persons may operate mobile equipment
b) All mobile equipment shall be mspected 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
c) Audible backup alarms shall be m operating condition
d) Walk around any piece of equipment before starting or moving it Make certam no one is in a
dangerous position and there are no obvious defects or hazards
e) Use caution when entenng 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 mvolved, 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 Mamtain adequate berms where
required
10.0 Documentation
1 a) Documentation of Shipments
For each shipment of byproduct matenal the following records will be mamtamed m the Mill's
No PBL-10
Rev No R-3 2
Date Deoembor 18,
2012iQnuMa:
February 2733.2013
ENERGY FUELS RESOURCES (USA) INC
STANDARD OPERATING PROCEDURES
Titie 1 le (2) Byproduct Disposal
Page 9 of 133
Radiation Environmental Department files
Shipper's Manifest and Bill of Lading
Laboratory/activity analysis of the byproduct matenal performed by the Shipper
Completed SWT
7-day notice to DirectorExecutive Secretory
Photo of the byproduct matenal
Byproduct matenal radiological scan information
Breathing zone monitoring data, if applicable
Equipment release forms
b) Documentation of Disposal
Byproduct matenal disposal will be documented on the Disposal Documentation Form
provided in Attachment 2 Attachment 2 may be accompanied by photographs, a wntten
descnption or both Attachment 2 or other wntten description will mclude
• How the matenal was placed m the tailmg cells,
• If void spaces m the drums/barrels contaming soil or sludge were filled with tailings
sands,
• How the area was compacted,
• Document that materials placed on tailmgs are no more than 4 feet thick and
subsequent lifts no more than 2 feet thick (this information will be obtamed for each
ISL disposal area and maintained by the engineermg 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 engmeermg 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 mamtam a plat of each
Designated Disposal Area, which illustrates the location of each shipment of
byproduct matenal
The Mill will maintam on file a copy of the DirectorExecutive Secretary's wntten approval of
each Designated Disposal Area
An annual summary of the amounts of byproduct matenal disposed of in each calendar year
shall be sent to the Executive SecretoryDirector on or before November 1 of the calendar year
(License Condition 10 5F) [summary due same year]
No PBL-10 ENERGY FUELS RESOURCES (USA) INC
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2012Januorv
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ATTACHMENT 1
SAFETY TRAINING FOR DELIVERY PERSONNEL
Welcome to Energy Fuels Resources (USA) Inc's, White Mesa Mill In order to assure your safety
whtie on our property, we would like to acquamt 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 mside the cab of
your truck
2 This IS a smoke free facility No smoking is allowed on the property Eating anythmg,
dnnking, chewing candy, gum or tobacco is also not allowed m the Mill Restncted Area due
to radiation hazards
3 Maintain a safe speed at all times when dnving m the Mill Restncted 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 tummg over while dumping Ensure that the truck is on
level ground and brakes are set prior to dumpmg
5 Check for potential overhead hazards pnor to dumpmg
6 If matenal is hung up m the trailer bed, it is not permissible to work in the bed while it is m 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 durmg penods of inclement weather
8 Be aware of the potential for ice build-up on and around the decontamination pad dunng
penods of cold weather
9 Use caution when entermg or exiting equipment
2.0 Radiation Safety
1 All dnvers are required to scan for alpha radiation pnor to leavmg the Mill Restricted Area
2 All equipment, i e trucks and trailers, will be scanned for radiation prior to leavmg the Mill's
Restncted Area
Driver (Pnnted) Scale House Operator
No PBL-10 ENERGY FUELS RESOURCES (USA) INC
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Date Dooomber 18, Titie 1 le (2) Byproduct Disposal 133
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Dnver (Signature) Date
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ATTACHMENT 2
lie (2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date
Name of employee receiving the load
Generator of the Byproduct Matenal
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''
Descnption of byproduct matenal disposal area/activities
I Has each drum been mspected to identify the presence of any void spaces''
I Have all drums with void spaces been filled with tailings sands or soiP
Which tailings cell was the matenal placed in?
Was the matenal placed on a tailmgs beach area of the cell or on an area of the cell that was underlam
by tailings sands''
Was the material segregated from any Mill matenal or equipment disposed of in the celP
Was the material segregated from byproduct material from other ISL sources disposed of in the celP
No PBL-10 ENERGY FUELS RESOURCES (USA) INC
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Date Deoember 18, Titie 11 e (2) Byproduct Disposal 133
2012Jcmuarv
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Have the thickness and placement measurements been venfied and documented for the disposal area
by the engineer, specifically
Engmeer'sor
RSQEnvironmental
Coordinator's
Initials
Was the matenal placed in a cell approved by the executive Secretary
for ISL waste disposal
Documentation of approval
Was the ISL matenal segregated from disposed Mill material and other
ISLmatenaP
Refer to plat(s) used to confirm
Was the maximum lift thickness above tailmgs 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 mamtamed under each disposal
area''
Refer to drawmgs used to confirm
Is the bottom of each disposal area at least 12 feet from the sides or
dikes of the tailmgs celP
Refer to drawmgs used to confirm
Will the elevation of the matenal exceed the plane or grade of the
elevation of the uppermost flexible membrane lmer of the cell''
How was this confirmed (eg, 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 pnor 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 ENERGY FUELS RESOURCES (USA) DSIC
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Date December 18, Titie 11 e (2) Byproduct Disposal 133
2012Januarv
February 2733.2013
If required, where were settlement markers were placed''
Radiological/PID receipt survey measurements
Breathmg Zone
1 Was a Breathmg Zone Sample collected'' Yes or No
2 If yes, what were the results of the sampling''
Was a photograph taken dunng the unloadmg activities'' Yes or No
No PBL-10 ENERGY FUELS RESOURCES (USA) INC
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Date February 27, Title 11 e (2) Byproduct Disposal
Page 1 of 13
2013
1.0 Purpose
Energy Fuels Resources (USA) Inc ("EFRI") receives lle.(2) byproduct material ("byproduct
matenal") from uranium in-situ leach operations for disposal under License Condition 10.5. The
following procedure applies to acceptance, handlmg, and disposal of byproduct material at the White
Mesa Mill (the "Mill")
2.0 Prior to Shipment of Byproduct Material
All byproduct matenal must be approved for disposal by the Mill Radiation Safety Officer ("RSO"), or
their designee, prior to shipment to the Mill The byproduct matenal must conform to Titles 10 and 49
of the U.S. Code of Federal Regulations ("CFR") and the Shipper must certify that the byproduct
matenal does not contain hazardous waste as defined m the Resource Conservation and Recovery Act
("RCRA")
Information regarding the byproduct matenal 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 matenals, filter media, pipe, etc )
3. A description of the shipping container (i.e end dump trailer, intermodal container, side dump
container, etc )
4. Resuhs of analysis for U-Nat, Ra-226, Th-230 and Pb-210 on all sludges and soils and other
matenal that is suited to sample collection. If a representative sample of the material was
taken in connection with a previous shipment of matenal, then the results of that previous
representative sample may be relied upon, and may be refened to or restated in the
documentation that accompames the shipment of the material. For byproduct matenal which
is not suited to sample collection (i e metals, process equipment, filter media, pipes, etc) the
Shipper will detemiine the range, the average and the total activity, measured in miUirem/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.
Radiation Safety Personnel^ will venfy, pnor 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
' Radiation Safety personnel consist of appropnately trained personnel from the Mill's Radiation, Environmental, or Safety
Departments
No PBL-10 ENERGY FUELS RESOURCES (USA) INC
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Date February 27, Title 11 e (2) Byproduct Disposal
2013
Radiation Safety Personnel will designate from time to time one or more designated disposal areas
(each a "Designated Disposal Area") being a general area within a tailings 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 firom the sides or dikes of the
tailmgs 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 engineenng drawmgs 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 fi-om the sides or dikes
of the tailings cells, and
c) Each disposed ISL byproduct matenal has been segregated from any mill matenal and
equipment disposed of in the cells and the ISL byproduct matenal from each m-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 pnor wntten approval from the Director
of the Utah Division of Radiation Control (the "Director") for this purpose
8. Prior written approval must have been obtained from the Directorfor 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 tailmgs beach areas
4.0 Notification to Director
No PBL-10 ENERGY FUELS RESOURCES (USA) ESfC
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Date February 27, Title 11 e (2) Byproduct Disposal
2013
EFRI shall notify the Director in wnting at least 7 calendar days prior to the proposed scheduled date
for disposal of any byproduct matenal. Wntten evidence of this notification will be kept on file at the
Mill
5.0 Byproduct Material Receiving
1 When each tmck driver enters the restricted area for the first time, the scale house operator
will provide hazard traimng for the dnver The driver will be provided with the Safety
Trammg 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 Traimng Form as the instmctor for EFR Completed Safety Training Forms
will be tumed in to the Safety Department for future reference.
2. Radiation Safety Personnel 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 tmck and trailer numbers on the Scale house Weight
Ticket (SWT)
4. Enter the loaded weight of the tmck and trailer on the SWT.
5. The scale house operator will contact the Radiation Safety Department so that the shipment
can be escorted by Radiation Safety persormel to the Designated Disposal Area specified by
the Environmental Coordinator.
6. Pnor to transporting matenal to the Designated Disposal Area (depending on weather), the
driver will be instmcted to open or untarp the load. The load may be opened or untarped at the
un-tarping station or at other locations as described under item c, below Radiation Safety
personnel will visually inspect, to the degree possible, the byproduct material to ensure that
the material matches the matenal description on the shipping mamfest. 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
Radiation Safety Personnel that the matenal 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 pnor
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 ENERGY FUELS RESOURCES (USA) INC
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Date February 27, Title 11 e (2) Byproduct Disposal
Page 4 of 13
2013
c. The Radiation Safety 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 mcurred. An example area could be the tailings 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 matenal from
all other ISL sources.
2. Radiation Safety personnel will escort the shipment to the designated location m 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 stmctures or settlement monitors associated v^th 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 pnor 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 pnor to
any disposal activities);
e. No travel into the disposal area vsdll 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,
the byproduct material will then be unloaded in the designated area If such notice has not been
No PBL-10 ENERGY FUELS RESOURCES (USA) INC
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Date Februafy27, Title 11 e (2) Byproduct Disposal
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given or if such 7 day penod 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 matenal 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 matenal is in a self-unloading container, the driver will be instmcted to unload ensunng
all personnel are clear of the trailer and the immediate area. Byproduct matenal will be
dumped from the transport in a safe manner to minimize dust. If the material requires
unloading by a fork tmck, a ramp will be installed and unloading will proceed.
c) After unloading, the Radiation Safety personnel will visually inspect the unloaded byproduct
matenal to ensure that there is no newly discovered material which does not match the matenal
description on the shipping manifest Any discrepancies between the byproduct matenal
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 matenal until a determmation 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 matenal 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 m mrem/hr at 2 meters, shall be recorded
g) Measurements using a photoiomzation detection meter ("PID") will be taken at several
locations around the unloaded material to ensure that there are no orgamcs present The
information will be recorded on the lle.(2) Byproduct Material Disposal Documentation
Formprovided in Attachment 2 to this SOP. If orgamcs are detected, the Environmental
Coordinator must be advised, and no compaction or covenng activities relating to the shipment
shall occur until specifically instmcted 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 othenvise 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 matenal from the shipper's ISL facility. Once the Environmental Coordinator has
verified that the organics are byproduct material compaction and covenng activities will
proceed
h) A breathing zone sample will be taken penodically 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 ENERGY FUELS RESOURCES (USA) INC
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Date February 27, Title. 1 le (2) Byproduct Disposal
2013
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 dnver 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 descnbed in Section 10, below.
7.0 Covering of Byproduct Material
1. After the byproduct material has been accepted by the Radiation Safety Personnel, 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 constmction
equipment pnor to placing an additional layer
3. Free volumes in the byproduct matenal will be minimized by filling, sectiomng, or cmshing.
Random fill or tailings sands will be used to fill voids in and around the byproduct material
4. All contaminated equipment shall be dismantled, cmshed, or sectioned to minimize void
spaces Barrels containing waste other than soil or sludges shall be emptied mto the disposal
area and the barrels cmshed. 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 constmction equipment.
6 Radiation Safety personnel will inspect the placement of the byproduct material pnor to
covenng to physically verify that the procedures in this Section 7.0 have been adequately
perfonned.
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 unrestncted use will be decontaminated according to the requirements foimd in Table 1 of
the Nuclear Regulatory Commission's (NRC's) Policy and Guidance Directive FC-85-23, "Guidelines
for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination
No PBL-10 ENERGY FUELS RESOURCES (USA) INC
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Date February 27, Title 11 e (2) Byproduct Disposal
2013
of Licenses for Byproduct, Source, or Special Nuclear Material" issued May 1987 Trailers requinng
repair will be decontaminated for unrestncted 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 restncted area of the Mill.
For the appropriate decontamination procedures, refer to the following Standard Operating Procedures
for the appropnate conveyance:
End Dump Trailer SOP PBL-9
Intermodal Container SOP PBL-2
Standard Container Trailer SOP-PBL-2
9.0 Hazard Identification and Safety
1 Required Personal Protective Equipment (PPE)
In all areas of the Mill covered by this procedure, hard hats, safety glasses and steel-toed shoes
are required at a minimum These must be wom in the restricted area of the Mill. Pnor 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 dunng the initial unloading operation
e) Dnvers must use caution dunng 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 intenor of a trailer
3. Mobile Equipment
a) Only trained and authonzed 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
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Date February 27, Title 11 e (2) Byproduct Disposal
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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 entenng 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 Mamfest 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 monitonng data, if applicable.
Equipment release forms.
b) Documentation of Disposal
Byproduct matenal disposal will be documented on the Disposal Documentation Form
provided in Attachment 2. Attachment 2 may be accompamed by photographs, a wntten
description or both. Attachment 2 or other written description will include:
No PBL-10 ENERGY FUELS RESOURCES (USA) INC
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Date February 27, Title 11 e (2) Byproduct Disposal
2013
• How the matenal was placed in the tailing cells;
• If void spaces in the drums/barrels containing soil or sludge were filled v^th 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 tailmgs area this information will be obtained for each ISL disposal area and
maintained by the engineering department);
• Document that the elevation of the matenal 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 maintam a plat of each
Designated Disposal Area, which illustrates the location of each shipment of
byproduct material.
The Mill will maintain on file a copy of the Director's written approval of each Designated
Disposal Area.
An annual summary of the amounts of byproduct material disposed of in each calendar year
shall be sent to the Director on or before November 1 of the calendar year (License Condition
10 5F) [summary due same year]
No PBL-10 ENERGY FUELS RESOURCES (USA) INC
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Date February 27, Title 11 e (2) Byproduct Disposal
2013
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 mles 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 tmck.
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 Restncted Area due
to radiation hazards.
3. Maintain a safe speed at all times when driving m 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 tmck turning over while dumping. Ensure that the tmck is on
level ground and brakes are set prior to dumping.
5 Check for potential overhead hazards pnor to dumping
6. If matenal 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 Restncted Area
2. All equipment, i.e tmcks and trailers, will be scanned for radiation pnor to leaving the Mill's
Restricted Area.
Dnver (Printed) Scale House Operator
Driver (Signature) Date
No PBL-10 ENERGY FUELS RESOURCES (USA) INC
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Date February 27, Title 11 e (2) Byproduct Disposal
2013
ATTACHMENT 2
lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date:
Name of employee receiving the load:
Generator of the Byproduct Matenal-
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 matenal placed m?
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?
Weis the material segregated from byproduct material from other ISL sources disposed of in the celP
No PBL-10 ENERGY FUELS RESOURCES (USA) INC
Rev No R-3 2 STANDARD OPERATING PROCEDURES Page 12 of 13
Date February 27, Title 11 e (2) Byproduct Disposal
2013
Have the thickness and placement measurements been venfied and documented for the disposal area
by the engineer, specifically-
Was the material placed m 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 matenaP
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 celP
How was this confirmed (e.g, survey or review)
Engineer's or
Environmental
Coordinator's
Initials
How was the area compacted? Was each lift compacted by heavy equipment (such as a Cat D-6) at
least 4 times pnor to placement of subsequent lifts'?
Were void spaces filled with tailings?
Was the shipment properly covered*?
Are additional settlement momtors required to be placed for this generator?
No PBL-10 ENERGY FUELS RESOURCES (USA) INC
Rev No R-3 2 STANDARD OPERATING PROCEDURES Page 13 of 13
Date February 27, Title 11 e (2) Byproduct Disposal
2013
If required, where were settlement markers were placed?
Radiological/PID 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 dunng the unloading activities'? Yes or No