DRC-2015-004290 - 0901a0688054fe91

State of Utah
Department of
Environmental Quality
Alan Matheson
Acting Executive Director
GARY R HERBERT
Governor
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
Spencer J Cox
Lieutenant Governor
D t\C- £0)5- 00 hrZ^
MEMORANDUM
TO: File C-2015-54
THROUGH: Phil Goble, Section Manager
FROM: Russell J. Topham, P.E.
DATE: June 30,2015
SUBJECT: Engineering Module 73. Inspection of Disposal of Bulk Byproduct Material June 16.
Radioactive Materials License UT 1900479 (License) - Energy Fuels Resources (USA) Inc.
(EFR) White Mesa Mill, Blanding, Utah
On June 16, 2015, I traveled to the White Mesa Mill to perform an inspection of in-situ leach (ISL) waste
disposal operations on behalf of the Utah Division of Radiation Control (DRC). This inspection responds
to a 1 le.(2) Byproduct Receipt Notification from EFR, dated May 20, 2015. 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 Material License.
On May 20, 2015 the DRC received notice that EFR would receive four loads of 1 le.(2) byproduct
material, and intended to dispose of that waste in Cell 3 on June 16, 2015. Three loads were ultimately
received prior to the commencement of the burial activity.
I checked in at the White Mesa mill at 8:00 AM on June 16, 2015, and asked to see David Turk. Mr. Turk
assigned Garrin Palmer to oversee the disposal operation. The crew had not yet finished preparations, so
Mr. Palmer and I reviewed storm water pooling on the ore pad and on Cell 2 while awaiting the crew to
gather at the disposal site.
At approximately 9:00 AM the crew assembled at the disposal area with the requisite equipment (a loader
and small dozer). The three loads were disposed in two excavations. The field crew used the appropriate
paperwork, i.e. Revision 3.3 of Procedure PBL-10, to guide the operation.
Material disposed consisted of:
• Bagged miscellaneous decommissioning debris from Cameco, Crow Butte, near Crawford,
Nebraska, shipped by Greenfield Logistics, bearing Shipper Number W-2-15; and,
• Chipped pipe and miscellaneous loose decommissioning debris from Cameco, Smith Ranch, in
Douglas, Wyoming, shipped by Greenfield Logistics, bearing Shipper Number 5/15-18 and 5/15-
19.
168 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 100% recycled paper
C-2015-54
Memorandum: Inspection of June 16, 2016
Page 2
The bill of lading for each of these loads appears in the attachments to this report.
Mr. Palmer, with assistance from one of the equipment operators, surveyed the level at the bottom of the
excavation prior to waste placement. Using a front-end loader and a small dozer, crews placed the waste in
the excavations and tamped it down. Mr. Palmer then surveyed the elevation of the top of the waste, and
the crews attempted to fill the excavation to the top with soil.
The material floated on solution in the excavations; therefore, the crew sent for a pump to dewater the
excavations. Dewatering took long enough that placing of the final loads of cover material and much of the
compaction of the cover occurred after I terminated observation of the operation. The crew track-walked
the capping fill to the extent practical during my observation, but floating debris and excess fluid in the
excavation prevented completing the backfilling and compacting operation at that time. The crew did not
finish the operation until late in the afternoon. Photos were provided as evidence of final excavation
closure.
EFR appears compliant with Part 10.5.E.(2) of the RML with respect to the elevation of burial. It appeared
that all provisions of the approved disposal SOP were followed during placement and burial of the bulk
waste.
Finding. EFR appears to have followed applicable provisions of the RML and of the SOP for the burial
operation.
Recommendation: I recommend closing out the inspection of June 16, 2015.
Attachments: Receipt Notification dated May 20, 2015, Bill of Lading and Disposal Documentation for
each load disposed on June 16, 2015, photos of the disposal operation provided by the licensee.
DRC-2015-002522
Energy Fuels Resources (USA) Inc.
6425 South Highway 191, PO Box 809
Blanding, UT. US, 84511
435 678 2221, fax [phone]
www.energyfuels.com
May 20, 2015
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) UT1900479 condition 10.5.F, Energy Fuels Resources
(USA) Inc. is hereby notifying the Division of Radiation Control that the White Mesa Uranium Mill will be
receiving and disposing of four loads of 1 le.(2) byproduct materials by June 16, 2015.
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 435.678.4113.
Regards,
David Turk
Environmental Health & Safety Manager
Energy Fuels Resources (USA) Inc.
cc: Denver Central Files
Photo 1: Placing waste in first excavation. Photo taken June 16, 2015.
» >Sv.-«
mm
mm
• *?j Li- 'y"aCi
Photo 3: Placing fill soil on waste. Photo taken June 30, 2015.
Photo 2: Bags of waste floating on the solution in the excavationi. Photo taken
June 16, 2015.
,A. • i Ml
Photo 4: Placing waste in second excavation. Photo taken June 16, 2015.
Photo 5: Placing cover soil over waste. Photo taken June 16, 2015.
Photo 7: Waste floating despite attempts to cover with soil. Photo taken June
16, 2015.
Photo 6: Placing and leveling cover soil over waste. Photo taken June 16, 2015
No7 PBL-10 j ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3.3 ! STANDARD OPERATING PROCEDURES
, Date: November 13, j Title: 1 le.(2) Byproduct Disposal
! 2014 !
Page 11 of 13
ATTACHMENT 2
lle.m BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date:
Name of employee receiving the load: X^CCs
Generator of the Byproduct Material: ^ruto Ru\-\e_
Shipper's Manifest or Bill of Lading number: CO - "Z.~ 15"
Was the State of Utah given notice to the receipt/disposal activities associated with this load 3^Yes^r
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? /t/A
Which tailings cell was the material placed in? Ct-\ t 3
Was the material placed on a tailings beach area of the cell or on an area of the cell that was underlain
by tailings sands?
Was the material segregated from any Mill material or equipment disposed of in the cell?
....... Yc3
Was the material segregated from byproduct material from other ISL sources disposed of in the cell?
f No.f PBL-10
j Rev No.: R-3.3
i Date: November 13,
I 2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 11 e.(2) Byproduct Disposal
Page 12 of 13
Manifest or BOL#: LO-ZrSS—
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? '^5
Documentation of approval Z,^.^ • UTl'r'Wf'Tf /} <f
Was the ISL material segregated from disposed Mill material and other
ISL material? A>>
Refer to plat(s) used to confirm. <£>// 3 //e l
X
ML
Was the maximum lift thickness above tailings less than 4 feet thick?
Was the maximum lift thickness of subsequent lifts less than 2 feet
thick?
Has 4 foot of tailings sands been maintained under each disposal
area? y^j
Refer to drawings used to confirm Ce// J c*c»s/. 7?,^,^.^
Is the bottom of each disposal area at least 12 feet from the sides or
dikes of the tailings cell? y*_%
Refer to drawings used to confirm. Ce// J C*.,^. £r<i~-S"Vs
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?
_._VsJ_
Was the shipment properly covered?
No.: PBL-10
Rev. No.: R-3.3
Date. November 13,
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) B>product Disposal
Page 13 of 13
Manifest or BOL #: LO-^-- \S
Are additional settlement monitors required to be placed for this generator?
__ A/A
If required, where were settlement markers were placed?
... MA _
Radiological receipt survey measurements:
PXO-Q ^ ^R.(Ur-
Breathing Zone:
1. Was a Breathing Zone Sample collected? Yes or/^o \
2. If yes, what were the results of the sampling?
Was a photograph taken during the unloading activities? ^eSyr No
j
STRAIGHT BILL OF LADING
ORIGIN AL-NOT NEGOTIABLE
Page 1 of 1 Greenfield Logistics. LLC
(N«m» of Carrier) (SCAC)
Date Cs>~
an Collact on Doftrory ihipmarti. tha InOna COD must appear befom conntgnae'i nama 0/ s> otharwtaa
provtdatj tn Ram 430, Sac 1.
To: Consignee Denison Mines Corp (USA)
Street 6425 3. Hwv 191
City Blandlna .State UT Zip Code 84511
From: Shipper Crow Butte Resources. Inc.
Street 86 Crow Butte Rd.
City Crawford State NE Zip Code 69339
24 nr. Emergency Contact Tel. No: (3081665-1393
Route: Vehicle:
Nmber
No. of unite &
container typo HM Basic Description
Proper Shipping Nam*, Hazard Claaa,
Identification Number (UN or NA). Packing Group, par 172101,17Z2Q2,172203
CLASS7
Total Quantity
(Weight, Volume,
QaDons. etc.)
Weight
(Subject to
Collection)
RATE Charges
(For Carrier
Uee Only)
2 roll ofTs XX RADIOACTIVE MATERIAL, Low Specific Activity (LSA-1), 60 cubic yards
PHYSICAL FORM: Solid byproduct material
CHEMICAL FORM: NATURAL URANIUM OXIDE U04-2H20
LABELS APPLIED: N/A
TRANSPORT INDEX: N/Aper49CFR172.203(dM5)
ACTIVITY OF SHIPMENT: _8.47x107_Bq
THIS VEHICLE IS ASSIGNED FOR EXCLUSIVE USE OF CAMECO
RESOURCES UNDER PROVISIONS OF 49 CFR 173.42S (b)
DO NOT LOAD OTHER FREIGHT IN THIS VEHICLE, TRANSFER EN
ROUTE, OR BREAK SEAL
PLACARDS: RADIOACTIVE 7
PLACARDS TENDERED: YE8/NO
CBR SHIPMENT #:
No*H1) Whm tha nto la daoandant on »aaja, aNpanm an, raruirad ID M apacflfcaay
'***.o1topn^lmhwB*vit*nm*)****l*V**>**m'**»>**
prarldad by audi pnaaaona. 8w MMR. Ham 171 (9) CamraoVai raajufctng apodal or adaKanal on or aaanson In handing or atoning ioua>b»iorr«rl«^airtpad^adai«>«naiiaiaa»itr»«tiuiti1IOii. Baa Bacaon 2(a) ot tarn 3S0, BO* of lading, Fndgtt BHa, arid 8»a«liaiilao»ChaiDai and 8odk«i 1(1)01 Ola Contact mm and oonrMona lor a Bat ot auori arifcaja.
I nataby daclwa Bad dia uunaarai ot Wa ODnalanrnant aia fc% and aoounMy doacribod abova by ttia anpor atapolne nama and ara olalaTBad. padagad. rnoraad, and ajbataddlplasvd, and ara bi all raaaicla In propar oondMon ha tianaport auuwdbiu to
ON BEHALF O* SHIPPER
acpa a> aaaai 7 araa mtmm fan >X fc a> at
T» Ill^n ma lili«| *********
COD FEE: PREPAID • COLLECT D t
TOTAL
CHARGES
FREIGHT CHARGES UD caaatatldaraa tf O aatoMi
TTrrrrr.iiiiiiniinin mniiaii —• — r, n.tll nm llfl-^-. r-r-r-^^--r-:ntin r- run-p-f-' r*——'I—— —•—-—- -•—1 T^I~
aadilirtnirtaard«»»adabow«dilc*i»^oana^ ilinlliialuii.lonBaia^aa^aniaatodafta^^ dlamutuadyagiaadaaloaiiili milnr of nflor nnyot, —W ****^o** w*vm^yaek™& mMroJalodm&cmtimmdmM lrda»ia^taa»orariyaaMpiopany.tJal»^nirili»^ Sri»^ha.nfrt«ttW»l)i«th»»larao»x I tr» a^ tarrni and oandlttor» aw narafr
aual plaoa ot dalaary at and ID aaeh party at any dma
SHIPPER: Crow Butts Resources, Inc.
PER PER:
DATE DATE: (j 15
CARRIER: Greenfield Logistics, LLC
Generator of Byproduct material: Crow Butte
Controled Elevation used (Cell 3) 5613.04
Area Elevation Transit Shot
Initial shot for trench
Top of trench
Bottom of trench
Initial shot used for material
Top of material in trench
5608
5602.09
5604.38
5.1
10.14
16.05
5.1
13.76
Top of cell 3 Liner 5608.5
Feet below liner 4.12
/A*
u>
U>-Z- &
.1 mi
^r-^t'T' '-"-.3* - -/
•.r v-
No : PBL-10 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-3.3 j STANDARD OPERATING PROCEDURES Page 11 of 13
Date: November 13, ; Title: I le (2) Byproduct Disposal
2014 I [
ATTACHMENT 2
lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date: 3^g-e>—K £ ivis
Name of employee receiving the load: Tg-t-Ay S\^J*c
Generator of the Byproduct Material: t.a^+ . n - <^.u~ p,.»f.k
Shipper's Manifest or Bill of Lading number: 5/ j^-i/j
Was the State of Utah given notice to the receipt/disposal activities associated with this load? C^esW
No
Who gave and when was the notification given?
D^.JL T^rl £ 20-\£
Description of byproduct material disposal area/activities:
Has each drum been inspected to identify the presence of any void spaces? Ay.A
Have all drums with void spaces been filled with tailings sands or soil? A/A
Which tailings cell was the material placed in? /' e\ \ 3
Was the material placed on a tailings beach area of the cell or on an area of the cell that was underlain
by tailings sands?
Was the material segregated from any Mill material or equipment disposed of in the cell?
Vc3
Was the material segregated from byproduct material from other ISL sources disposed of in the cell?
Vo
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 12 of 13
Manifest or BOL #: s\\.r- it
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? f<tj
Documentation of approval A^y,- ur/fccir1/ f
Was the ISL material segregated from disposed Mill material and other
ISL material?
Refer to plat(s) used to confirm. ( c // 7 Z- *r$-o l Jr,u
Engineer's or
Environmental
Coordinator's
Initials
Was the maximum lift thickness above tailings less than 4 feet thick?
Was the maximum lift thickness of subsequent lifts less than 2 feet
thick?
Has 4 foot of tailings sands been maintained under each disposal
area?
Refer to drawings used to confirm Cdt 7 Ce.d. 0> cp. .
Is the bottom of each disposal area at least 12 feet from the sides or
dikes of the tailings cell?
Refer to drawings used to confirm. Ce'l 3 d$*jk -tfrg^, V»y Will the elevation of the material exceed the plane or grade of the
elevation of the uppermost flexible membrane liner of the cell?
this How was 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?
Art^ i^^i ^t^~L ft-A VOTTU «v AcZ<-r 0-4- \e^<^ Ce^r- i^ysid at-r~
Were void spaces filled with tailings?
Yc*
Was the shipment properly covered?
s>t*L tvbevc.-..
No.: PBL-10
Rev No.. R-3 3
Date: November 13,
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 13 of 13
Manifest or BOL #: $\{\-\$
Are additional settlement monitors required to be placed for this generator?
If required, where were settlement markers were placed?
Radiological receipt survey measurements:
Breathing Zone:
1. Was a Breathing Zone Sample collected? Yes or^o)
2. If yes, what were the results of the sampling?
Was a photograph taken during the unloading activities? Xekor No
STRAIGHT BILL OF LADING
ORIGINAL-NOT NEGOTIABLE
Greenfield Logistics (Name of Carrier) (SCAC)
Shipper No^"/lyl?
Carrier No.
Date
on Collect on OeHvery ahrpmanli, Ins lattera COD muat appear before consignee's name or aa
otherwise provided In Item 430, Sec 1
To: Consignee ENERGY FUELS
Street 6425 South HWY 191
City Blandinq State UT Zip Code 84511
From: Shipper CAMECO RESOURCES. INC.
Street: 762 Ross Rd
City Douglas State WY Zip Code 82633
24 hr. Emergency Contact Tel. No: 905-885-8745
Route: Vehicle
Number
No of
units &
container
type
HM Basic Description
Proper Shipping Name, Hazard Class,
Identification Number (UN or NA). Packing Group, per 172.101,172 202,172.203
Total
Quantity
(Weight, volume,
Gallons, etc)
Weight
(Subject to
Correction)
RATE Charges
(For Carrier
Use Only)
1 Roll
off
XX UN2913, RADIOACTIVE MATERIAL, SURFACE CONTAMINATED OBJECT (SCO-
IK CLASS 7
27.82m5
(36.4yd1)
RADIONUCLIDE: RESIDUAL NATURAL URANIUM & ASSOCIATED DAUGHTER
PRODUCTS
PHYSICAL FORM: SOLID
CHEMICAL FORM: NATURAL URANIUM OXIDE UO4-2H20
TOTAL ACTIVITY: 3.7E7Bq (0.001 Ci)
TRANSPORT INDEX: N/A AS PER 49CFR172.203(d)(5)
PLACARDS: RADIOACTIVE 7
EXCLUSIVE USE SHIPMENT: THIS VEHICLE IS ASSIGNED FOR EXCLUSIVE
USE OF CAMECO RESOURCES, INC. UNDER PROVISIONS OF 49 CFR 173.427
INCLUDING EXEMPTING FROM MARKING AND LABELING REQUIREMENTS
DO NOT LOAD OTHER FREIGHT IN THIS VEHICLE, TRANSFER EN ROUTE
PLACARDS TENDERED: YES: X NO • REMIT COD TO.
ADDRESS
Nota-(l)lflrnarttoratabdtparK*vitonvalua ahlppara in raqulrad to alata ipadfleaVy on
wrongtha agraad ordadaradvalua of Via propBrty. asfouowl Thaagroadordadaradvalua
ol tha proparty a htraby tpactflcaJry tbrttd by tha ahlppar to be not
(2) Whart tha applcfbla tam prodakm loadfy a fcntaton ol tha cantata labMy abaanl a
ralaaia or a valua dadaratkin by tha ahlppar and tha aNppar doea not rataaaa tha camara
Many or dtdiro a valua, tha carriara Mattr ahan ba llmllad to tha want provldad by such
provalont Saa MMFltem 172.
(3) CommodHai raqurfng tpadal or aoaNonat earn or altantlon In handing or atovang muat
ba 10 markad and pacaapad aa to enaura afra aanaportatton Sao8actlon2(o)oraarn3SO.
Bib of Lading. Fraght BUa. and Sauarnanai of Chargaa and Bacdon 1(a) ol tha Contract
awma and cotvJdorm tor a art of arch ortlcloi
I haraby daclara that tho contamt of 1Kb
ccralgnnwit ara fully and accuraariy daacrtbad
atnra by dta propar trapping nama and ara
craadflod, packagad. markad. and
labatadf/placard. and ara at all raapacbi In
proper condflfofi for transport sccordng ID
eppflcable rtt.wna aortal and national
governmental regulators
ON BEHALF OF SHIPPER
lat««lbaMnn7ilMa • «niir#«wiaiBlMdi
(tlgraaiM CtfMlgnor}
COO FEE
PREPAID
COLLECT. $
TOTAL
CHARGES >
FREIGHT CHARGES
RECEIVED subject to ttie clatatttcalora and tanffi In affect on tit data of baue of thta Bfl of Lading BM property described above in apparent good order, eicept at noted (contents and condBton of contarrb, of package* unknown), markad, consigned, and
destined as relocated above which aald carrier {tiie word carrier being understood ftraughout this contract as meaning any parson or corporation In possession of Ha property under the contract) agrees to carry to to usual place of daavery at said destination, If on
Ki route othafwba to deliver to another carrier on the route to said destination tl it mutually agreed as to secti earner of ed of any of said property over all or eny portion of Mid route to ctosonafco and as to each perry al any time Irrterested in all or any takf property that every service to ba performed rvsteurtder shall be subject to al the UB ol lading terms and condWont ki (ha governing detartteatton on the dais of me shipment
Shipper hereby certaes Vial ha Is fanvasr with au the ie*ng terms and con/Ubcm* In Vie governing ctesaMcation and the said terms and cwvJanns are hereby agreed to by the shipper and accepted for himself and hLs assigns
SHIPPER: CAMECO RESOURCES, INC. CARRIER: Greenfield Logistics
PER PER
DATE
1? Rev 3 - Apr 02, 2015
'<f Page I of 1 I L
J \4) Radiation Protection Program\WYO-RPP-01 (Volume IV-Health Physics)\WYO -RPP-0VfForrns)\vVYO -RPP-01.071 Bill of Lading-By-Product-
SCO.doc
Efierqy Fuel ^ Reb ource &
Wh ite Mesa M •». j "J
6^c:5 S, Highway 1'31
B I and 3 n g J7" B45 1 i
! ran^dct i a n Hi
5 1018
Vehicle ID*;
TV a iler IDs
ftccount IDs
Order ID:
Owney1 ID;
Material ID:
Do tin. ID s
1 1 <e)£ WYO SMITH RPNC
1 (e)£ Mat 11 (c)
Da t e
Fn s #3/ J 9/2131 5
Dut s ©5/ 13/c'iZii 5
Gros =v s u
T a re :
Net "
#9 : 31
J «Zi: 17
57 3CM lb
487 40 lb
1458i? lb
Seal
1
1
CM)
BRANDING
C o HI in e n t s ; R / 0 # i
0 perators 4
Si gnat ure?s
Cherq e b y Weigftt
j/jA
5 .1 /i
73
t 1 C cf
1 i
05
1715
i9/30 i;
V : 1 /
e ) 3 Mat C I") u '
57 3J/1© lb
4rj7 4» lb
14 560 lb
Tot Chy :
(M)
Smith Ranch
Controled Elevation used (Cell 3)
Initial shot for trench
Top of trench 5607.46
Bottom of trench 5601.82
Initial shot used for material
Top of material in trench 5605.57
5.1
9.91
15.55
5.1
11.8
Area Elevation Transit Shot
Top of cell 3 Liner 5608.5
2.93 Feet below liner
\
3^
/A.
15-IS 5
< ... -
H»»...
» .1 ».•..- is, *
-V
V •3
1
• ••' :
ir
,7
*
3R?
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 11 of 13
ATTACHMENT 2
lle.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date:
Name of employee receiving the load:
Generator of the Byproduct Material:
Uicv./J Tu*k~
Shipper's Manifest or Bill of Lading number: £~/i>~ -
Was the State of Utah given notice to the receipt/disposal activities associated with this load?^e^or
No
Who gave and when was the notification given?
Description of byproduct material disposal area/activities:
ihjC-^jzbjl ^ fl^pkr}
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? C-e-lL j
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?
YCA
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
Manifest or BOL #:
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title' 1 le.(2) Byproduct Disposal
Page 12 of 13
IJ3
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 /».. t # Uf'iz?»/ -*?
Was the ISL material segregated from disposed Mill material and other
ISL material? Y*s
Refer to plat(s) used to confirm. 3 //e. Z- /?;* s&ja/ ft-'* I_t i_£ . _. ~ ' — ' J " "--r
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/ 7el
Refer to drawings used to confirm £dl 3 Cc*%>h 0^—-^^
Is the bottom of each disposal area at least 12 feet from the sides or
dikes of the tailings cell? y
Refer to drawings used to confirm. £<'i 3 c'c»^. jO^^oyj
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
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 prior to placement of subsequent lifts?
Were void spaces filled with tailings?
. ZUi
Was the shipment properly covered?
No.: PBL-10
Rev. No.: R-3.3
Date: November 13,
2014
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Manifest or BOL #: fTln— i<j
Are additional settlement monitors required to be placed for this generator?
If required, where were settlement markers were placed?
A/A
Page 13 of 13
Radiological receipt survey measurements:
Breathing Zone:
1. Was a Breathing Zone Sample collected? Yes or^fc^)
2. If yes, what were the results of the sampling?
Was a photograph taken during the unloading activities? /Yes/tar No
STRAIGHT BILL OF LADING
ORIGINAL-NOT NEGOTIABLE
Shipper No5"^S"-/^
(Name of Carrier) (SCAC)
Carrier No.
on Collect on Delivery shipments, the letters COD mutt appear before consignee's nama or as
otherwise providad In Item 430, Sac 1
To: Consignee Energy Fuels
Street 6425 South Hwv 191
City Blandinq State UT Zip Code 84511.
From: Shipper CAMECO RESOURCES. INC.
Street: 762 Ross Rd
City Douglas . State WY Zip Code 82633_
24 hr. Emergency Contact Tel. No: 905-885-8745
Route: Vehicle.
Number
No of
units &
container
type
HM Basic Description
Proper Shipping Name, Hazard Class,
Identification Number (UN or NA), Packing Group, per 172.101,172.202.172 203
Total
Quantity
(Weight, volume.
Gallons, etc.)
Weight
(Subject to
Correction)
RATE Charges
(For Carrier
Use Only)
1 Roll
off
XX RQUN2S13, RADIOACTIVE MATERIAL, SURFACE CONTAMINATED OBJECT
(SCQ-1), CLASS 7
18.88m3
(24.7yd*)
RADIONUCLIDE: RESIDUAL NATURAL URANIUM & ASSOCIATED DAUGHTER
PRODUCTS
PHYSICAL FORM: SOLID
CHEMICAL FORM: NATURAL URANIUM OXIDE UO«-2H20
TOTAL ACTIVITY: 2.7E10Bq (0.741 CI)
TRANSPORT INDEX: N/A AS PER 49CFR172.203(d)(5)
PLACARDS: RADIOACTIVE 7
EXCLUSIVE USE SHIPMENT: THIS VEHICLE IS ASSIGNED FOR EXCLUSIVE
USE OF CAMECO RESOURCES, INC. UNDER PROVISIONS OF 49 CFR 173.427
INCLUDING EXEMPTING FROM MARKING AND LABELING REQUIREMENTS
DO NOT LOAD OTHER FREIGHT IN THIS VEHICLE, TRANSFER EN ROUTE
PLACARDS TENDERED: YES : X NO • REMIT COD. TO.
ADDRESS
NMo-(1) Wliare IM rats Is dependent on«*liM
wrHng the egrsed or declared value of tie property,
of aw property Is hereby spscMcsOy statsd by tie
srs requbedto slate
ASM Ths
lobs not
(2) Whsra ths spotfcobla tsrHI proMoss tp^slln«»*jno(l)t.c«rt^il««*y »b»»nl«
relsoM or s value dodersrjon by Ins shlppor and tie snipper does not rslssss the carrier's tabes? or sectors • vehis, the canal's labs* shell be llnM to ths sslsm prrMsed by such
proiMons SeeNMFl.ssm 172
(3) Conimodnos rsqirirlng specbil or erMMonst core or atsrriton In bending or stumor must
be so msrked end packaged ss to ensure sere traneportafon &ee&ocabn2{e)oflrem3Q0.
eMorUoVe.FreWBras.and Sletamerrai ol Charges end Bedon 1 (a) of sta Contract
terms and eondBons for s 1st of such articles
I hsrsby dsclare tiet ths coMensi or Irde
consignment are tuDy end accurstely described
above by the proper shipping nam* end sro
clnisWed. packaged, marksd, snd
tsbsled/iptacerd, and ara In all respect ki
proper candMon for transport scumJIng to erjptceble Intemsttonal snd nesonsl
aowernmentel reguletfons
««M«ktonwrt » tot**
COD FEE
PREPAID
COLLECT S
TOTAL
CHARGES
FREIGHT CHARGES
FAEtOHT PREPAID
•Op!**
RECEIVED subject lo the ducMcatoni and tariffs in effect on tha dale of issue of this Bll of Ladina, the property described ebovs in apparent good order, aicept et noted (content* and condMon «f contents of packages unknown), markad. corM>Bned, and
destined as ndfcated above which said carrier (the word carner being understood throughout OK* contract aa meaning any person or corporation in possession of this property under tie contracT) agrees to carry to ft* usual place of defcrsry el aaU desBiuflon if on
Its route otherwise to detver to another carrier on the route to said deettrtattor. \\ h mutua&y agreed as to each carrier of eQ or any of, said property over all or any portion of said route to oeefJnston and aa to each party at any Urns interested In all or any said
property hat every service to be performed hereunder shell be subject to efl the bil of lading terms and ctmdflon* In the summing claatfceson on the date of the shipment
Snapper hereby csrtfiee that ha bj hrntaar with aft tha isdang terms and conditions in tha governing claasttcafcn and the said term* and condOons are hereby agreed to by the shipper and accepted for bmse-f and hta assigns
SHIPPER: CAMECO RESOURCES, INC. CARRIER: (xfltr&lU
PER PER
L5 DATE
Rev3 Apr 02, 2015
Page 1 of 1 Q**r> J Tvrk-
)M) Radiation Protection PrograrmWYO-RPP-01 (Volume IV-Health Physics)\WYO -RPP-0I (Forms)\WYO -RPP-0I.071 Bill of Lading-By-Product-
BCO.doc
Ensr'av Fuels Resources <LiS9) Corp.,
White Mesa Mill Transaction No,
£435 B. Highway 191 51033
B I a n d a n g UT 8 4 5 1 i
Dat; e T i me Sca 1 e
Ens 0S/PJ/2015 W9:01 1
Outs 05/315 09: £3 1
V e h 3 c1e ID: 13
Trailer ID: Gross: 6934® lb CM)
Account ID; U<«)£ WYO SMITH RANCH Tare; 44360 1. b
Order ID: Net: 94980 lb
Owner IDs
Material ID: 3 1 <e)£ Mat 1 1 '.<?)£ Material Rtreint
Destin. TD: BLOND INO
Comments: R/04 0FT_U 1150
Operator: 4 Charge by Wejght
S i gnat u r e : ^J^t/f^h
Si 033 i/>5/3 1 .5155 3 0?:iZU 39340 lb (M)
T5 05/ 3 J -31:03.3 09:33 44360 lb
! 1. ' c.3 3 wY3 r":49S0 i b
il\e)E Met Net Cho s 0 Tot Chq« ^
Smith Ranch
Controled Elevation used (Cell 3)
Area
5612.27
Elevation Transit Shot
Initial shot for trench
Top of trench 5607.46
Bottom of trench 5601.82
Initial shot used for material
Top of material in trench 5605.57
5.1
9.91
15.55
5.1
11.8
(is- /1
Top of cell 3 Liner 5608.5
Feet below liner 2.93
Sj 15-1?