DRC-2023-070648 - 0901a0688125e995

DRC-2023-070648 195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
State of Utah

SPENCER J. COX
Governor

DEIDRE HENDERSON
Lieutenant Governor
Department of
Environmental Quality

Kimberly D. Shelley
Executive Director

DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL

Douglas J. Hansen
Director
M E M O R A N D U M

TO: Project File C-2023-32

THROUGH: Phil Goble, Uranium Mill Section Manager

FROM: Heather Mickelson, PE, PG
DATE: August 29, 2023

SUBJECT: August 14, 2023 Inspection of the Disposal of 11e.(2) Decommissioning Debris from In
Situ Leach Facilities at the White Mesa Uranium Mill. Radioactive Material License No.
UT 1900479, Amendment 10.

Authority
Radioactive Materials License #UT1900479 Amendment 10, Condition 10.5: “In accordance with the
licensee's submittal to the NRC dated May 20, 1993, the licensee is hereby authorized to dispose of 11e.(2)
byproduct material generated at licensed in-situ recovery (ISR) [previously known as in-situ leach (ISL)]
facilities as per 10 CFR 40 Appendix A, Criterion 2 and from other uranium recovery facilities, subject to the
following conditions:” (Conditions are included below in the Requirements and Compliance
Determination section.)

R313-12-3 (quoting 10 CFR 40.4): “Byproduct Material means the tailings or wastes produced by the
extraction or concentration of uranium or thorium from any ore processed primarily for its source
material content, including discrete surface wastes resulting from uranium solution extraction
processes.”1

10 CFR Part 40 Appendix A, Criterion 2: “To avoid proliferation of small waste disposal sites and
thereby reduce perpetual surveillance obligations, byproduct material from in situ extraction operations,
such as residues from solution evaporation or contaminated control processes, and wastes from small
remote above ground extraction operations must be disposed of at existing large mill tailings disposal
sites; unless, considering the nature of the wastes, such as their volume and specific activity, and the
costs and environmental impacts of transporting the wastes to a large disposal site, such offsite disposal

1 This definition amends the language given in Section 11e.(2) of the Atomic Energy Act as amended in 1954 to include ISL
facilities on the same footing as conventional uranium mills. This is done by referencing “solution extraction” in the
definition. Text of the Atomic Energy Act as amended in 1954 can be found in NUREG-0980, Volume 1, No. 10.
August 29, 2023
August 29, 2023
Third Quarter (August) 2023 ISL Decommissioning Debris Disposal Inspection Report
August 29, 2023
Page 2

is demonstrated to be impracticable or the advantages of onsite burial clearly outweigh the benefits of
reducing the perpetual surveillance obligations.”

Observations
Heather Mickelson, PE, PG and Ryan Johnson, of the Utah Division of Waste Management and
Radiation Control (Division) and Brandi O’Brien, as an IMPEP inspector observed the burial of two (2)
load of 11e.(2) byproduct material on August 14, 2023 at the White Mesa Uranium Mill. The mill is
owned and operated by Energy Fuels Resources (Licensee). The Division received notice (DRC-2023-
068056) of the disposal electronically on July 6, 2023 and by hardcopy on July 12, 2023.

Operating Procedures and Records
The Standard Operating Procedure (SOP) PBL-10, dated August 4, 2021, governs the disposal of 11e.(2)
byproduct material from ISL facilities.

The Licensee maintains hard copies of the buried 11e.(2) material records onsite. Records are moved
from the White Mesa Mill’s office building to an onsite storage container within the restricted area when
file space inside the office building becomes limited.

Copies of the data packets for each load disposed during this inspection are attached to this report.

11e.(2) Byproduct Material Disposal Activities and Description
Prior to August 14, 2023, the disposal pit location was determined, located by survey, and excavated.
The bottom of the excavation extended into the tailings sand. The 11e.(2) byproduct material was
placed near the burial pit for burial (Photos 1).

During the August 14, 2023 inspection, the Division observed the final disposal activities. The
excavation depth was surveyed (Photo 2). The 11e.(2) byproduct material was moved into the
excavation (Photo 3) and the top of the material was surveyed. Clean cover was then placed over the
11e.(2) byproduct material and then compacted to further minimize void spaces (Photos 5 and 6). The
vertical extent of the burial was below the top of the tailings and above the bottom liner.

The disposal activities were for one load of 11e.(2) byproduct material from URI-Rosita in Kingsville
Texas. The material consisted of fiberglass pipes.

During the disposal activities, filter socks from a previous disposal were observed at the surface of the
cell. It is appeared that the excavation activities had exposed them. They were mostly covered with
clean fill and otherwise not moveable. These filter socks were in two locations about 10 and 20 feet
from the excavation pit. Clean fill was placed, compacted, and smoothed over the filter socks that were
approximately 20 feet from the excavation pit. The filter socks that were 10 feet from the excavation pit
were picked up and placed in the excavation pit. These socks (approximately two) were picked up with
bare hands.

Upon leaving the restricted area, all personnel scanned themselves and no individual had a measurable
reading.

Close Out Meeting
A preliminary inspection findings meeting was held on August 14, 2023 and observations made during
the inspection were discussed. This meeting included: Heather Mickelson, Ryan Johnson, Brandi
Third Quarter (August) 2023 ISL Decommissioning Debris Disposal Inspection Report
August 29, 2023
Page 3

O’Brien, Logan Shumway and Garrin Palmer. During this meeting, the Licensee committed to
submitting requested information. It was received on August 17, 2023 and the inspection was finalized
on August 22, 2023.

During the preliminary inspection meeting, the Division staff recommended that employees use gloves
when picking up 11e.(2) byproduct material.

Requirements and Compliance Determination
Radioactive Materials License #UT1900479, Condition 10.5B: “All ISR contaminated equipment shall
be dismantled, crushed, or sectioned to minimize void spaces. Barrels containing waste other than soil or
sludges shall be emptied into the disposal area and the barrels crushed. Barrels containing soil or sludges
shall be verified by the Licensee to be full prior to disposal. Barrels not completely full shall be filled with
tailings or soil prior to disposal. ”

The activities observed and information gathered during this inspection support the conclusion that the
Licensee is complying with this license condition. The licensee confirmed that all materials were
crushed by rolling over them with the bulldozer prior to being placed in the excavation. The pipes were
crushed as they were placed into the excavation pit and compacted.

Radioactive Materials License #UT1900479, Condition 10.5C: “All ISR byproduct material shall be
buried in Impoundment No. 3 unless prior written approval is obtained from the Director for alternate burial
locations.”

The activities observed and information gathered during this inspection supports a conclusion that the
Licensee is complying with this license condition. All 11e.(2) byproduct material was buried in Tailings
Cell No. 3.

Radioactive Materials License #UT1900479, Condition 10.5D: “All disposal activities shall be
documented and records thereof maintained on-site. The documentation shall include all items required by
this License.”

The activities observed and information gathered during this inspection support the conclusion that the
Licensee is complying with this license condition. The Licensee maintains records of the 11e.(2)
byproduct material disposed of onsite. These records document the nature of each load of material
received, where it is buried, and how it was handled, including all measures taken to comply with all of
License Condition 10.5.

Radioactive Materials License #UT1900479, Condition 10.5E: “Disposal Requirements for 11e.(2)
byproduct material: the licensee shall perform byproduct material disposal activities in accordance with the
current Standard Operating Procedure (SOP) for 11e.(2) byproduct material disposal. Said plan includes the
following minimum provisions:

(1) The material disposal area must be located on a tailings beach area of the conventional
impoundment or on an area of the impoundment that is underlain by tailings sands;
(2) The elevation of the material disposal area will not exceed the plane or grade of the elevations of
the uppermost flexible membrane liner of the conventional impoundment;
(3) (Reserved)
Third Quarter (August) 2023 ISL Decommissioning Debris Disposal Inspection Report
August 29, 2023
Page 4

(4) Absence of void space inside barrels disposed, including physical verification before disposal;
and
(5) Detailed engineering drawings which demonstrate:
a. There are at least 4 feet of tailings sands under the bottom of each disposal area; and
b. The bottom of each disposal area is located at least 12 feet from the sides or dikes of the
impoundment.”

The activities observed and information gathered during this inspection supports the conclusion that the
Licensee is complying with this license condition. The Licensee met the requirement to submit the
procedure with the initial version of SOP PBL-10, and now uses Revision R-3.5, dated August 4, 2021.
Revision R-3.5 addresses all of the items specified in License Condition 10.5. The original version and
every subsequent revision of this procedure were submitted to the Division for review and approval
prior to implementation.

Further, the Licensee is complying with the SOP, such as, minimizing void space, and placing the waste
in the tailing sands with at least four feet of sands below it and at least 12 feet from the side or dike of
the cell.

Radioactive Materials License #UT1900479, Condition 10.5F: “The Licensee shall notify the Director in
writing at least 7 calendar days prior to the proposed scheduled date for disposal of any 11e.(2) byproduct
material in the conventional impoundments.

An annual summary of the amounts of 11e.(2) byproduct material disposed of from off-site generators shall
be included in the Annual Technical Evaluation Report required in License Condition 12.2.”

The activities observed and information gathered during this inspection supports the conclusion that the
Licensee is complying with this license condition. The Division received notice (DRC-2023-068056) of
the disposal electronically on July 6, 2023 and by hardcopy on July 12, 2023, which complies with the 7
days advance notice requirement.

The annual summary submittal will be evaluated by DWMRC separately from this inspection.

Conclusions and Recommendations
The Licensee appears fully compliant with applicable laws, standards, requirements, and license
conditions with respect to disposal of 11e.(2) byproduct material generated as decommissioning debris
from ISL uranium recovery facilities.

The Licensee submitted an updated SOP for its 11e.(2) Byproduct Disposal (PBL-10) (DRC-2023-
070906) dated August 23, 2023, and completed training on the updated SOP on August 25, 2023. The
Division completed its review of the updated SOP and recommended approval with memo from the
Division dated August 29, 2023 (DRC-2023-070866). An approval letter should be issued shortly.

The updated SOP discourages manually handling of the 11e.(2) byproduct material and requires the use
of gloves if doing so is necessary.

Third Quarter (August) 2023 ISL Decommissioning Debris Disposal Inspection Report
August 29, 2023
Page 5

Attachments: 11e.(2) Disposal Photolog
11e.(2) byproduct receipt notification dated July 6, 2023, which was received
electronically on July 6, 2023 and by hardcopy on July 12, 2023.
Document packet for URI-Rosita 11e.(2) byproduct material bearing Bill of Lading
#23ROS-0012
Document packet for URI-Rosita 11e.(2) byproduct material bearing Bill of Lading
#23ROS-0013
Division Memo – ALARA Issue with 11e.(2) Disposal at the White Mesa Mill
DRC-2023-070906 – Updated SOP for 11e.(2) Byproduct Disposal from Licensee
Licensee Training Records

Photo 1. 11e.(2) byproduct material to be buried. Photo taken on August 14,
2023.
Photo 2. Energy Fuels Resources surveying the bottom of the excavation pit.
Photo taken on August 14, 2023.
Photo 3. Energy Fuels Resources moving 11e.(2) byproduct material into the
excavation pit. Photo taken on August 14, 2023.
Photo 4. Energy Fuels Resources placing fill over the 11e.(2) byproduct
material and compacting with a bulldozer. Photo taken on August 14, 2023.
Photo 5. Final compacted area of the 11e.(2) byproduct material burial
location. Photo taken on August 14, 2023.
July 6, 2023
VIA Electronic Mail (PDF) and UPS
Mr. Doug Hansen
State of Utah Department of Environmental Quality
195 North 1950 West
PO Box 144880
Salt Lake City, UT 84114-4880
Dear Mr. Hansen
Re: 1 le.(2) Byproduct Receipt Notification
Energy Fuels Resources (USA) Inc.
6425 South Highway 191 , PO Box 809
Blanding, UT. US, 84511
435 678 2221 , fax [phone]
www.energyfuels.com
Pursuant to Radioactive Materials License (RML) UTI 900479 condition 10.5.F, Energy Fuels Resources
(USA) Inc. is hereby notifying the Division of Waste Management and Radiation Control that the White
Mesa Uranium Mill will be receiving and disposing of loads by July 18th, 2023.
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 435.678.4114.
Regards,
Garrin Palmer
cc: Denver Central Files
DRC-2023-068056
DRC-20 195 North 1950 West • Salt Lake City, UT Mailing Address: P.O. Box 144880 • Salt Lake City, UT 84114-4880 Telephone [phone] • Fax [phone] • T.D.D. 711 www.deq.utah.gov Printed on 100% recycled paper
State of Utah
SPENCER J. COX Governor
DEIDRE HENDERSON Lieutenant Governor
Department of Environmental Quality
Kimberly D. Shelley Executive Director
DIVISION OF WASTE MANAGEMENT AND RADIATION CONTROL
Douglas J. Hansen Director
M E M O R A N D U M
TO: 2023 HP White Mesa Mill Inspection Folder
THROUGH: Phil Goble (U-Mill/RAM Section Manager) 8/24/2023
Heather Mickelson (U-Mill Engineer) 8/24/2023
FROM: Ryan Johnson (U-Mill HP Inspector) 8/24/2023
DATE: 8/23/2023
SUBJECT: ALARA Issue with 11e.(2) Disposal at the White Mesa Mill
Background
On August 14, 2023, an inspection was conducted at White Mesa Uranium Mill (Mill) by Ryan Johnson and Heather Mickelson, representatives of the Division of Waste Management and Radiation Control (Division) of the Utah Department of Environmental Quality. Brandi O’Brian from the State of Wyoming accompanied the inspection as part of the Nuclear Regulatory Commission’s (NRC) IMPEP
team for the 2023 review of State of Utah’s Agreement State program. As part of this inspection the
Division Inspectors observed 11e.(2) disposal activities on tailing impoundment #3. During this observation it was noticed that some material from a previous 11e.(2) disposal activity was not completely buried. Ms. O’Brian pointed it out to Ms. Mickelson and Ms. Mickelson asked the Mill employee accompanying the Inspectors to put the material into the disposal trench. Upon request the
Mill employee did what was requested and picked up the material by hand and threw it into the disposal
trench. It was noted by Ms. O’Brian that the White Mesa employee was not wearing gloves when he picked up material and threw it into the trench. After the 11e.(2) disposal activities the Inspectors and the Mill employee went back the Administration Building and scanned out of the restricted area using a hand held Alpha scintillator (The Mill uses Ludlum Model 177 meters with an Alpha probe). The
radiation scans of the Inspectors and the employees did not detect any contamination.
During the preliminary closeout meeting with Mill management, the inspectors explained what they had observed regarding the interaction with the 11e.(2) material by Mill personnel sans gloves.
Page 2

Note: 11e.(2) Disposal is when 11e.(2) material from other uranium recovery facilities such as ISRs comes to the White Mesa Mill to be buried in tailings impoundment #3. These disposal activities are authorized under 10 CFR 40 Appendix A Criterion #2 and referenced in State of Utah rules in R313-24.
The total amount of 11e.(2) material that the White Mesa Mill can receive and where it can be buried is
in Utah Radioactive Material License UT1900479 License Condition 10.5. Issue
On August 23, 2023, in a conference call between the NRC and Division Management, the NRC
brought up the observation that the Mill employee picked the 11e.(2) material and threw it into the disposal trench with no gloves on. The NRC indicated that they saw this as an ALARA issue and expected the Division to take the appropriate action to address it. The NRC indicated that they would follow-up with the Division on this issue when they come to Utah in September of 2023.
Mill’s Corrective Response After the NRC shared their concerns with Division Management, that same day, Phil Goble contacted the Inspectors and asked them to follow-up with the Mill. Ryan Johnson contacted Kathy Weinel,
EFRI’s Director Regulatory Compliance, and Garrin Palmer, Mill’s Radiation Safety Officer, and
discussed the NRC’s ALARA issue. It was determined that the Mill would document this issue in their annual ALARA Report and that the SOP for 11e.(2) disposal would be revised to include gloves as required PPE and how loose 11e.(2) material will be handled in the future. The Mill also committed to additional training on 11e.(2) disposal for their personnel.
Division Follow-up The Division will follow-up on this issue on September 13th and 14th, when the next HP inspection will occur. The Division will also follow-up during the next 11e.(2) disposal engineering inspection and
during the ALARA HP inspection performed by Division Staff in November of 2023.
Note: Via email on August 24, 2023, EFRI submitted a redline/strikeout version of their revised 11e.(2) Disposal SOP for Division review addressing the concern identified during the August 14, 2023 inspection.
August 24, 2023
Sent VIA OVERNIGHT DELIVERY
Mr. Doug Hansen Director Division of Waste Management and Radiation Control Utah Department of Environmental Quality 195 North 1950 West
Salt Lake City, UT 84114-4820
Energy Fuels Resources (USA) Inc. 225 Union Blvd. Suite 600 Lakewood, CO, US, 80228 303 974 2140 www.energ fuels.com
Re: Transmittal of Revised Standard Operating Procedure ("SOP") for lle.(2) byproduct material disposal at the White Mesa Uranium Mill
Dear Mr. Hansen:
This letter transmits Energy Fuels Resources (USA) Inc. 's ("EFRJ's") proposed revisions to the White Mesa Mill (the "Mill") SOP for 11 e.(2) byproduct disposal conducted in accordance with Radioactive Material License ("RML") Section 10.5. These revisions include changes made to:
1.Address observations during a recent inspection by Division of Waste Management and RadiationControl ("DWMRC") Personnel.2.Correct typographical errors.
Pursuant to Section 10.5.E EFRJ is submitting this revised SOP for review and approval. For ease ofreview
we have provided both redline/strikeout and clean versions of the document.
If you should have any questions regarding this SOP please contact me.
Yours very truly,
i(w.y )v ,U//Ll,[ENERGY FUELS RESOURCES (USA) INC.Kathy W einel
Director, Regulatory Compliance
CC: David Frydenlund Logan Shumway Scott Bakken Garrin Palmer Tanner Holliday
DRC-2023-070906
REDLINE
No.: PBL-10 ,Rev._No.: R-�.0_ Date: August 423, 202-1-J
1.0 Purpose
-·· -·ENERGY FUELS RESOURCES (USA) INC. .... �T !.>-�P!\RP.. QJ?.Ei&\ TJ.NG. P�_o_c;:):::P.IJRJ;:S..--f�gt,_l __ qf_I)_ ·-••. ___ ..••. ,.-·· { Formatted: English (United States) Title: I le (2) Byproduct Disposal Energy Fuels Resources (USA) Inc. ("EFRI") receives I le.(2) byproduct material ("byproduct material") from uranium in-situ recovery ("JSR") operations for disposal under License Condition I 0.5. 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 Bvproduct Material
All byproduct material must be approved for disposal by the Mill Radiation Safety Officer ("RSO"), or his designee, prior to shipment to the Mill. The byproduct material must conform to Titles IO 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 dumpcontainer, etc.)
4.Results of analysis for U-Nat, Ra-226, Th-230 and Pb-210 on all sludges and soils and othermaterial that is suited to sample collection. !f a representative sample of the material was takenin connection with a previous shipment of material, then the results of that previousrepresentative sample may be relied upon, and may be referred to or restated in thedocumentation that accompanies the shipment of the material. For byproduct material which isnot suited to sample collection (i.e. metals, process equipment, filter media, pipes, etc.) theShipper 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 ofthe completed shipping manifestthat will accompany the shipment and the anticipatedshipping date.
The Environmental Coordinator or their designee will verify, prior to receipt of any shipment of byproduct material, that the disposal of such byproduct material will not cause the Mill to exceed the limits of byproduct material, set out in Mill License condition 10.5.
3.0 Designated Disposal Area
The Environmental Coordinator, or their designee will designate from time to time one or more designated disposal areas (each a "Designated Disposal Area") being a general area within a tailings cell for the disposal of byproduct material. Each Designated Disposal Area must meet the following criteria:
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC. �t!y_._N(),: __ ��¥1...J!. . � ... � •· ST A�Q1� QP_E&\ T.l_N_Q_ P_�_Q�EQ\J��-.. . J'!lg� 2 _qf.J.� .. ...•..•..•••.•...• { Formatted: English (United States) Date: August 423, Title: 11 e (2) Byproduct Disposal 202-l-3 I . 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 thecell that is underlain by tailings sands;
3.There must be at least 4 feet of tailings sands under the Designated Disposal Area;• ····{ Formatted: Indent: Left: O", Hanging: 0.5"
4.The Designated Disposal Area must be located at least 12 feet from the sides or dikes of thetailings cell;
5.Survey information or other document review will be maintained to confirm that the elevationof the Designated Disposal Area once filled with byproduct material must not exceed the planeor grade of the elevation of the uppermost flexible membrane liner of the tailings cell;
6.ISRL wastes will be disposed in cells that have received prior written approval from theDirector for this purpose.
7.Designated Disposal Areas include either trench areas or tailings beach areas. The proceduresfor placement are not dependent on which area the byproduct material is placed in. The aboveprocedures are the same for both trench areas and tailings beach areas.
4.0 Notification to Director
EFRI shall notify the Director in writing at least 7 calendar days prior to the proposed scheduled date for disposal of any byproduct material. Written evidence of this notification will be kept on file at the Mill.
5.0
I.
2.
3.
Bmroduct Material Receiving
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 EFRI's safety rules and procedures while on company property. The scale house operator will sign the Safety Training Form as the instructor for EFRI. Completed Safety Training Forms will be turned in to the Safety Department for future reference.
The onsite transportation expert shall inspect all copies of the Shipping Manifest and the transporter's Bill of Lading to ensure that the shipment is destined for the Mill and confirm with the Environmental Coordinator, or their designee that the shipment has been approved for receipt.
Record the inbound date and both the truck and trailer numbers on the Scale house Weight Ticket (SWT).
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC. ,Rev._No.: R-�.0_ .. --�-T.�NQh@.OJ:'J:iMTJJ':I.G.P.�.QGJ;;P.!-!��---··· .P�&Cl -� _qf.lL .. . ... ·-············{ Formatted: English (United States) Date: August 423, Title: 11 e.(2) Byproduct Disposal 202-1-3
4.Enter the loaded weight of the truck and trailer on the SWT.
5.The scale house operator will contact the Environmental Department so that the shipment canbe escorted by Environmental personnel to the Designated Disposal Area specified by theEnvironmental Coordinator.
6.Prior to transporting material to the Designated Disposal Area (de pending on weather), thedriver will be instructed to open or untarp the load. The Environmental personnel and thetransportation expert will visually inspect, to the degree possible, the byproduct material toensure that the material matches the material description on the shipping manifest. Anydiscrepancies between the byproduct material received and the manifest information will bereported to the Environmental Coordinator.
a.Any byproduct material suspected of not conforming to Section 2.0 of this SOP willnot be transported to the disposal site, unless a determination is made by theEnvironmental Coordinator that the material in question conforms to Section 2.0 ofthis SOP.
b.Barrels containing soil or sludges shall be checked to determine if they are full priorto transporting them for disposal. Barrels not completely full shall be documentedand shall be filled with tailings or soil prior to disposal. (License Condition 10.5.B).
c.If weather conditions exist that makes the opening of the conveyance impossible atthe untarping station, the Environmental personnel may take the conveyance to asuitable location in which to inspect the load. A suitable location will be one wherethe load may be viewed where employees are safely out of the way when theconveyance doors are opened and where if material was to fall out of the conveyance,that contamination issues will not be incurred. An example area could h!Lthe tailsimpound area near the disposal site.
6.0 Bvproduct Malcrial nload.ing
I.The Environmental Coordinator will specify the specific location within the broader DesignatedDisposal Area for disposal of the shipment.
2.Environmental personnel will escort the shipment to the designated location in the DesignatedDisposal Area for unloading of the byproduct material.
3.Proposed Methods and Procedures to Fully Protect the Liner While Accessing TailingsCells for Disposal ofISR Byproduct Material and Mill Equipment
a.The shipment will be transported to the Designated Disposal Area only on establishedroadways onto the tailings cells.b.At no time will a shipment be transported over or in a manner that will damageunprotected dikes, liners, other structures or settlement monitors associated with any of the
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC. Aev._No.: R-¼4.0 ______ ........ H A.J:,JP�_RI?. 0-':'J::M T.IJ':!.G. P..�9�!:;P.\.!�S....-��g(, _4 _qf_l) -... . ...........••.. • · ( Formatted: English (United States) Date: August 423, Title: I le (2) Byproduct Disposal 202+3 tailings cells. c.There must be at least 4 feet of tailings sands under the Designated Disposal Area;d.The Designated Disposal Area must be located at least 12 feet from the sides or dikes ofthe tailings cell (active areas will be marked as noted above);e.No travel into the disposal area will be allowed unless the disposal cell liner is coveredby 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 dayshave not lapsed, then the shipment may be, but is not required to be contained in the shippingcontainer (that is, the container-bin or trailer) on site until the required 7 day notice has beengiven 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 beengiven or if such 7 day period has not lapsed, then the byproduct material will be unloaded in anarea of the tailings cell that is not covered with interim cover and from which the material can beremoved if necessary. Once the required notice has been given and the required 7 days havelapsed, the byproduct material will then be placed into the designated area.
b)If the material is in a self-unloading container, the driver will be instructed to unload ensuring all personnel are clear of the trailer and the immediate area. Byproduct material will be dumped from the transport in a safe manner to minimize dust. If the material requires unloading by a forktruck, a ramp will be installed and unloading will proceed.
c)After unloading, the Environmental personnel will visually inspect the unloaded byproductmaterial to ensure that there is no newly discovered material which does not match the materialdescription on the shipping manifest. Any discrepancies between the byproduct materialreceived and the manifest information will be reported to the Environmental Coordinator. Anybyproduct material suspected of not meeting the requirements set forth in Section 2.0 of this SOPwill be kept segregated from other waste material until a determination is made of itsacceptability for disposal.
d)After unloading, a photo of the unloaded material will be taken which is attached to the shippingdocumentation for verification of shipment contents.
e)Beta-gamma measurements will be taken at several locations around the unloaded material. Thisinformation 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 inmrem/hr at 2 meters, shall be recorded.
f)Measurements using a photoionization detection meter ("PID") will be taken at several locationsaround the unloaded material to ensure that there are no organics present. The information willbe recorded on the Environmental Department's copy of the shipment documentation. lforganicsare detected, the Environmental Coordinator must be advised, and no compaction or covering
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC. .Rt;y_._J\J(_),� B-:--:¥4 ... JL. ... STANDARD OPERATING PROCEDURES ... --.__g�g_".5._qf.l.L __ • . • • _ .•.•••... • • { Formatted: English (United States) Date: August 423, Title: 11 e.(2) Byproduct Disposal 202-1-J activities relating to the shipment shall occur until specifically instructed by the Environmental Coordinator. The Environmental Coordinator and Safety Coordinator will determine if any additional safety precautions are required to be taken by workers or otherwise as a result of the detection of the organics, and will implement any such precautions. The Environmental Coordinator will also contact EFRI corporate regulatory personnel and the shipper to verify that the detected organics are 1 le.(2) byproduct material from the shipper's ISL facility. Once the Environmental Coordinator has verified that the organics are byproduct material compaction and covering activities will proceed.
g)A breathing zone sample will be taken periodically during unloading and cover activities. If thegross alpha exceeds 25% of the applicable DAC, then the RSO will be notified, and all otherunloading activities of byproduct material from that particular ISL site will require the use ofrespiratory protection, until further notice by the RSO.
h)After unloading the byproduct material, replace the tarp or close the trailer, unless the trailer isbeing decontaminated for unrestricted release.
i)Direct the driver back to the scales for an empty weight.
j)The scale house operator will record the empty weight on the appropriate SWT.
k)Shipment and disposal activities will be documented as described in Section 10, below.
7.0 Covering o{ 8\'produet Material
1.After the byproduct material has been accepted by the Environmental Coordinator, or theirdesignee, the byproduct material will be spread within the designated area within the DesignatedDisposal Area to facilitate compaction and covering.
2.The byproduct material will be compacted with at least four passes of the construction equipmentprior to placing an additional layer.
3.Free volumes in the byproduct material will be minimized by filling, sectioning, or crushing.Random fill or tailings sands will be used to fill voids in and around the byproduct material.
4.All contaminated equipment shall be dismantled, crushed, or sectioned to minimize void spaces.Barrels containing waste other than soil or sludges shall be emptied into the disposal area and thebarrels crushed. Barrels containing soil or sludges shall be verified to be full prior to disposal.Barrels not completely full shall be filled with tailings or soil.
5.A one foot thick, or thicker, cover comprised of native soil will be placed over the byproductmaterial working area. The fill and cover material will be compacted with at least one pass ofthe construction equipment.
6.The Environmental Coordinator or their designee will inspect the placement of the byproductmaterial prior to covering to physically verify that the procedures in this Section 7 .0 have been
No: PBL-10 ENERGY FUELS RESOURCES (USA) INC. .Rev.�No.: R-J.,..54.0 ___ STANDARD OPERATING PROCEDURES ---·-��g_1,_� .<?f .l.? .... . . . . . ....... , _ .. · · { Formatted: English (United States) Date: August 423, Title: I le (2) Byproduct Disposal 202+3
adequately performed.
8.0 Decontamination and Release of Trailers and Trucks
All trailers and trucks will be decontaminated after unloading prior to leaving the Mill. Shippers or transporters will notify EFRI 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 173.428 or 173.443. Any trailers that are to be released for unrestricted use will be decontaminated according to the requirements found in Table 2 of the Nuclear Regulatory Commission's (NRC's) Regulatory Guide 8.30 Rev. I "Health Physics Surveys in Uranium Recovery Facilities" or NRC document "Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special Nuclear Material" issued May 1987. Trailers requiring repair will be decontaminated for unrestricted release, to facilitate repairs by the transporter at the transporter's own site. Trailers may be repaired without undergoing full decontamination ifrepaired within the restricted area of the Mill.
For the appropriate decontamination procedures, refer to the following Standard Operating Procedures for the appropriate conveyance:
End Dump Trailer Intermodal Container Standard Container Trailer
9.0 Hazard Identification and Safetv
1.Required Personal Protective Eguipmenl (PPE)
SOP PBL-9 SOP PBL-2 SOP-PBL-2
In all areas of the Mill covered by this procedure, hard hats, safety glasses and steel-toed shoesare required at a minimum. These must be worn in the restricted area of the Mill. Gloves shallbe \\'Om when manuall handllna. material. Prior to disposal, the RSO will determine what levelof respiratory protection, if any, will be required.
2.Industrial Hazards and . afetv
d)Use caution when the trailers are backing to the unloading area.
e)Ensure that all personnel within 50 feet of the area where an end dump trailer is about to dumpits load are aware that unloading is about to commence. Move at least 25 feet away from the rearof the trailer during the initial unloading operation.
f)Drivers must use caution during the unloading process and be aware of any overhead hazards.
g)Do not place any part of your body inside the trailer when the trailer is being tipped and thetailgate is open. Only work around the tailgate after it has been properly blocked open.
h)Use caution when entering or exiting equipment. Be sure to use the ladders and hand rails. Do
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC. Rev._No.: R-h¼.0_ STANDARD OPERA TING PROCEDURES _J>�g_l;;}_Qf.l2 ____ .......... ·····.fiile:.11i.(2) By0p;�d�ci Di�p�s�i--.. ............... --· { Formatted: English (United States) Date: August 423, 202+3
3.
not jump off the equipment.
i)__Always use a ladder when entering and/or exiting the interior of a trailer.
+r anual handlin of anv material is discoura ed. If it · necessary 10 manual!\' handle material. gloves shall be worn as directed bv the R O or afetv oordinator.
Mobile Equipment
a)Only trained and authorized persons may operate mobile equipment.b)All mobile equipment shall be inspected by the operator and any safety defects corrected beforethe 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 in operating condition.
d)Walk around any piece of equipment before starting or moving it. Make certain no one is in adangerous position and there are no obvious defects or hazards.
e)Use caution when entering or exiting equipment. Be sure to use the ladders and hand rails. Donot 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 hazardsare not allowed.
i)Report all accidents to your supervisor regardless ofhow minor they are. If property damage orpersonal 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 whererequired.
10.0 Documentation
I.a) Documentation of Shipments
For each shipment of byproduct material the following records will be maintained in the Mill'sEnvironmental Department files:
•Shipper's Manifest and Bill of Lading.
Formatted: List Paragraph, Left, No bullets or numbering, Widow/Orphan control
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC. J{.ev. No.: R-H4.0_ .... .. ---STANDARD OPERA TING PROCEDURES __l\1ge_�_qf_1_2 ___ .. . . .. Tiile:' 1 i-;_(2) 0Byp;od�ct0Di�p-os�i ............... Date: August 4.Ll., 202+3 •Laboratory/activity analysis of the byproduct material performed by the Shipper.•Completed SWT.•7-day notice to Director.•Photo of the byproduct material.•Byproduct material radiological scan information.•Breathing zone monitoring data, if applicable.•Equipment release forms.
All documents and photographs should be dated and the Shipper's Manifest and or Bill of Lading number indicated on the document.
b)Documentation of Disposal
Byproduct material disposal will be documented on the Disposal Documentation Form provided in Attachment 2. Attachment 2 may be accompanied by photographs, a written description or both. Attachment 2 or other written description will include:
•How the material was placed in the tailing cells;•lfvoid spaces in the drums/barrels containing soil or sludge were filled with tailingssands;•How the area was compacted;•Document that materials placed on tailings are no more than 4 feet thick andsubsequent lifts no more than 2 feet thick;•Document that there are 4 feet of tailings under the bottom of each disposal area andthe bottom of each disposal area is located at least 12 feet from the sides or dikes ofthe tailings area;•Document that the elevation of the material will not exceed the plane or grade of theelevation of the uppermost flexible membrane liner of the cell.•Confirmation that the shipment was properly covered; and•Where settlement markers were placed. The Mill will maintain a plat of eachDesignated Disposal Area, which illustrates the location of each shipment ofbyproduct material.
2.The Mill will maintain on file a copy of the Director's written approval of each DesignatedDisposal Area.
11.0
An annual summary of the amounts of byproduct material disposed of in each calendar year shall be sent to the Director as specified in License Condition 10.5F.
Training ........ .
An annual basis, all onsite personnel that are involved in the receiving or disposing of this material shall be trained in the activities associated with this procedure. This training shall be documented and maintained on file.
. . { Formatted: English (United States)
[ Formatted: Font: Bold, Underline
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC. .R�Y .. �9: . .R.��...Jl .............. �ThN.l?h.�.Ql?J::�TJN.G.!'.13-9.<=:J::P.\IM� ........ f(l.g_<:.�.of_l.2 Date: August 423, Title: I le (2) Byproduct Disposal 202+3 ATTACHMENT I SAFETY TRAINING FOR DELIVERY PERSONNEL Welcome to Energy Fuels Resources (USA) Inc. 's, White Mesa Mill. In order to assure your safety while on our property, we would like to acquaint you with the safety rules and procedures, which you will be required to follow while on our property.
1.0 General Safety
1.Approved hard hats and safety glasses are required at all times except when inside the cab ofyour truck.
2.This is a smoke free facility. No smoking is allowed on the property. Eating anything, drinking,chewing candy, gum or tobacco is also not allowed in the Mill Restricted Area due to radiationhazards.
3.Maintain a safe speed at all times when driving in the Mill Restricted Area. The maximumspeed limit is posted at I 5 mph. Energy Fuels Resources (USA) Inc. 's equipment has the rightof way on the ore pad and Mill roadways.
4.Be aware of the possibility of a truck turning over while dumping. Ensure that the truck is onlevel ground and brakes are set prior to dumping.
5.Check for potential overhead hazards prior to dumping.
6.If material is hung up in the trailer bed, it is not permissible to work in the bed while it is in thedump position. !fit 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 periodsof cold weather.
9.Use caution when entering or exiting equipment.
2.0 Radiation afch•
1.All drivers are required to scan for alpha radiation prior to leaving the Mill Restricted Area.
2. All equipment, i.e. trucks and trailers, will be scanned for radiation prior to leaving the Mill'sRestricted Area.
Driver (Printed) Scale House Operator
Driver (Signature) Date
. . · { Formatted: English (United States)
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC. .R,ev._No.: R-:hM.0_ .. ........ �T.JJ-�_Qh.RP..91:'HMT.Il'Y.G.P_l-3._0q=:[!1,.!�S . .. ··--Pag_e I0_of_]?_ . . . . ---· ••.. --· { Formatted: English (United States) Date: August 423, Title: I le (2) Byproduct Disposal 202-l-j_
ATTACHMENT 2 l lc.(2) BYPRODUCT MATERIAL DISPOSAL DOCUMENTATION FORM
Date: _____ _
Name of employee receiving the load: __________ _
Generator of the Byproduct Material: ________ _
Shipper's Manifest or Bill of Lading number: __________ _
Was the State of Utah given notice to the receipt/disposal activities associated with this load? Yes or No
Who gave and when was the notification given?
Description of byproduct material disposal area/activities:
Has each drum been inspected to identify the presence of any void spaces? ______ _
Have all drums with void spaces been filled with tailings sands or soil'> _______ _
Which tailings cell was the material placed in? ____________ _
Was the material placed on a tailings beach area of the cell or on an area of the cell that was underlain by tailings sands?
Formatted:
202-l-3
No.: PBL-10 )lev._No.: R-�.o .•.... Date: August -1-U, 202-1-3 ENERGY FUELS RESOURCES (USA) INC. ..... __ STANDARDOPERATINGPROCEDURES ... Title: 1 le.(2) Byproduct Disposal Manifest or BOL #: ____ _ Are additional settlement monitors required to be placed? If required, where were the settlement markers placed? Radiological receipt survey measurements: Breathing Zone: 1.Was a Breathing Zone Sample collected? Yes or No2.If yes, what were the results of the sampling?Was a photograph taken during the unloading activities? Yes or No ···-r�&1eJi_()f.!?-_ .. ....•..••...•.... --{ Formatted: English (United States)
CLEAN
No.: PBL-10
Rev. No.: R-4.0 Date: August 23, 2023
1.0 Purpose
ENERGY FUELS RESOURCES (USA) INC. STANDARD OPERA TING PROCEDURES Page 1 of 12 Title: l le.(2) Byproduct Disposal
Energy Fuels Resources (USA) Inc. ("EFRI") receives lle.(2) byproduct material ("byproduct material") from uranium in-situ recovery ("ISR") operations for disposal under License Condition 10.5. The following procedure applies to acceptance, handling, and disposal of byproduct material at the White
Mesa Mill (the "Mill").
2.0 Prior to Shipment of Byproduct Material
All byproduct material must be approved for disposal by the Mill Radiation Safety Officer ("RSO"), or
his designee, prior to shipment to the Mill. The byproduct material must conform to Titles 10 and 49 of the U.S. Code of Federal Regulations ("CFR") and the Shipper must certify that the byproduct material does not contain hazardous waste as defined in the Resource Conservation and Recovery Act ("RCRA").
Information regarding the byproduct material to be disposed of should be received prior to receipt of the
shipment at the Mill, and shall include:
1.The volume of material in cubic feet or yards, or quantity of drums and their size.
2.A description of the material (e.g. sludge, process materials, filter media, pipe, etc.)
3.A description of the shipping container (i.e. end dump trailer, intermodal container, side dumpcontainer, etc.)
4.Results of analysis for U-Nat, Ra-226, Th-230 and Pb-210 on all sludges and soils and othermaterial that is suited to sample collection. If a representative sample of the material was takenin connection with a previous shipment of material, then the results of that previousrepresentative sample may be relied upon, and may be referred to or restated in thedocumentation that accompanies the shipment of the material. For byproduct material which isnot suited to sample collection (i.e. metals, process equipment, filter media, pipes, etc.) theShipper 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 anticipatedshipping date.
The Environmental Coordinator or their designee will verify, prior to receipt of any shipment of byproduct material, that the disposal of such byproduct material will not cause the Mill to exceed the limits of byproduct material, set out in Mill License condition 10.5.
3.0 Designated DisposaJ Area
The Environmental Coordinator, or their designee will designate from time to time one or more designated disposal areas ( each a "Designated Disposal Area") being a general area within a tailings cell for the disposal of byproduct material. Each Designated Disposal Area must meet the following
criteria:
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC. Rev. No.: R-4.0 STANDARD OPERA TING PROCEDURES Page 2 of 12 Date: August 23, 2023 Title: 11 e.(2) Byproduct Disposal
1.The Designated Disposal Area must be in an active tailings cell (i.e., a tailings cell that is notfully covered with interim cover);
2.The Designated Disposal Area must be on a tailings beach area of the cell or on an area of thecell 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.ISRL wastes will be disposed in cells that have received prior written approval from theDirector for this purpose.
7.Designated Disposal Areas include either trench areas or tailings beach areas. The proceduresfor placement are not dependent on which area the byproduct material is placed in. The aboveprocedures are the same for both trench areas and tailings beach areas.
4.0 Notification to Director
EFRI shall notify the Director in writing at least 7 calendar days prior to the proposed scheduled date for disposal of any byproduct material. Written evidence of this notification will be kept on file at the Mill.
5.0 Byproduct Material Receiving
1.When each truck driver enters the restricted area for the first time, the scale house operator willprovide hazard training for the driver. The driver will be provided with the Safety TrainingForm (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 EFRI's
safety rules and procedures while on company property. The scale house operator will sign theSafety Training Form as the instructor for EFRI. Completed Safety Training Forms will beturned in to the Safety Department for future reference.
2.The onsite transportation expert shall inspect all copies of the Shipping Manifest and thetransporter's Bill of Lading to ensure that the shipment is destined for the Mill and confirm withthe Environmental Coordinator, or their designee that the shipment has been approved forreceipt.
3.Record the inbound date and both the truck and trailer numbers on the Scale house WeightTicket (SWT).
4.Enter the loaded weight of the truck and trailer on the SWT.
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC. Rev. No.: R-4.0 STANDARD OPERA TING PROCEDURES Page 3 of 12 Date: August 23, 2023 Title: 11 e.(2) Byproduct Disposal
5.The scale house operator will contact the Environmental Department so that the shipment can
be escorted by Environmental personnel to the Designated Disposal Area specified by the
Environmental Coordinator.
6.Prior to transporting material to the Designated Disposal Area (de pending on weather), thedriver will be instructed to open or untarp the load. The Environmental personnel and the
transportation expert will visually inspect, to the degree possible, the byproduct material to
ensure that the material matches the material description on the shipping manifest. Anydiscrepancies between the byproduct material received and the manifest information will bereported 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 theEnvironmental Coordinator that the material in question conforms to Section 2.0 ofthis SOP.
b.Barrels containing soil or sludges shall be checked to determine if they are full priorto transporting them for disposal. Barrels not completely full shall be documentedand shall be filled with tailings or soil prior to disposal. (License Condition 10.5.B).
c.If weather conditions exist that makes the opening of the conveyance impossible at
the untarping station, the Environmental personnel may take the conveyance to asuitable location in which to inspect the load. A suitable location will be one wherethe load may be viewed where employees are safely out of the way when the
conveyance doors are opened and where if material was to fall out of the conveyance,
that contamination issues will not be incurred. An example area could be the tailsimpound area near the disposal site.
6.0 Byproduct Material Unloading
1.The Environmental Coordinator will specify the specific location within the broader DesignatedDisposal Area for disposal of the shipment.
2.Environmental personnel will escort the shipment to the designated location in the DesignatedDisposal Area for unloading of the byproduct material.
3.Proposed Methods and Procedures to Fully Protect the Liner While Accessing TailingsCells for Disposal of ISR Byproduct Material and Mill Equipment
a.The shipment will be transported to the Designated Disposal Area only on establishedroadways onto the tailings cells.b.At no time will a shipment be transported over or in a manner that will damage
unprotected dikes, liners, other structures or settlement monitors associated with any of thetailings cells.c.There must be at least 4 feet of tailings sands under the Designated Disposal Area;
d.The Designated Disposal Area must be located at least 12 feet from the sides or dikes of
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC. Rev. No.: R-4.0 STANDARD OPERA TING PROCEDURES Page 4 of 12 Date: August 23, 2023 Title: 1 le.(2) Byproduct Disposal
the tailings cell (active areas will be marked as noted above); e.No travel into the disposal area will be allowed unless the disposal cell liner is coveredby 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 dayshave not lapsed, then the shipment may be, but is not required to be contained in the shippingcontainer (that is, the container-bin or trailer) on site until the required 7 day notice has beengiven 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 beengiven or if such 7 day period has not lapsed, then the byproduct material will be unloaded in an
area of the tailings cell that is not covered with interim cover and from which the material can beremoved if necessary. Once the required notice has been given and the required 7 days havelapsed, the byproduct material will then be placed into the designated area.
b)If the material is in a self-unloading container, the driver will be instructed to unload ensuring allpersonnel are clear of the trailer and the immediate area. Byproduct material will be dumpedfrom the transport in a safe manner to minimize dust. If the material requires unloading by a forktruck, a ramp will be installed and unloading will proceed.
c)After unloading, the Environmental personnel will visually inspect the unloaded byproductmaterial to ensure that there is no newly discovered material which does not match the materialdescription on the shipping manifest. Any discrepancies between the byproduct material
received and the manifest information will be reported to the Environmental Coordinator. Anybyproduct material suspected of not meeting the requirements set forth in Section 2.0 of this SOPwill be kept segregated from other waste material until a determination is made of itsacceptability for disposal.
d)After unloading, a photo of the unloaded material will be taken which is attached to the shippingdocumentation for verification of shipment contents.
e)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 rnrem/hr at 2 meters, and the average measurement, measured inmrem/hr at 2 meters, shall be recorded.
f)Measurements using a photoionization detection meter ("PID") will be taken at several locationsaround the unloaded material to ensure that there are no organics present. The information willbe recorded on the Environmental Department's copy of the shipment documentation. If organicsare detected, the Environmental Coordinator must be advised, and no compaction or covering
activities relating to the shipment shall occur until specifically instructed by the Environmental
Coordinator. The Environmental Coordinator and Safety Coordinator will determine if anyadditional safety precautions are required to be taken by workers or otherwise as a result of thedetection of the organics, and will implement any such precautions. The Environmental
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC. Rev. No.: R-4.0 STANDARD OPERATING PROCEDURES Page 5 of 12
Date: August 23, 2023 Title: 11 e.(2) Byproduct Disposal
Coordinator will also contact EFRI corporate regulatory personnel and the shipper to verify that the detected organics are lle.(2) byproduct material from the shipper's ISL facility. Once the Environmental Coordinator has verified that the organics are byproduct material compaction and covering activities will proceed.
g)A breathing zone sample will be taken periodically during unloading and cover activities. If thegross alpha exceeds 25% of the applicable DAC, then the RSO will be notified, and all otherunloading activities of byproduct material from that particular ISL site will require the use ofrespiratory protection, until further notice by the RSO.
h)After unloading the byproduct material, replace the tarp or close the trailer, unless the trailer isbeing decontaminated for unrestricted release.
i)Direct the driver back to the scales for an empty weight.
j)The scale house operator will record the empty weight on the appropriate SWT.
k)Shipment and disposal activities will be documented as described in Section 10, below.
7.0 Covering of Bvproduct Material
1.After the byproduct material has been accepted by the Environmental Coordinator, or theirdesignee, the byproduct material will be spread within the designated area within the Designated
Disposal Area to facilitate compaction and covering.
2.The byproduct material will be compacted with at least four passes of the construction equipmentprior to placing an additional layer.
3.Free volumes in the byproduct material will be minimized by filling, sectioning, or crushing.Random fill or tailings sands will be used to fill voids in and around the byproduct material.
4.All contaminated equipment shall be dismantled, crushed, or sectioned to minimize void spaces.Barrels containing waste other than soil or sludges shall be emptied into the disposal area and thebarrels crushed. Barrels containing soil or sludges shall be verified to be full prior to disposal.
Barrels not completely full shall be filled with tailings or soil.
5.A one foot thick, or thicker, cover comprised of native soil will be placed over the byproductmaterial working area. The fill and cover material will be compacted with at least one pass ofthe construction equipment.
6.The Environmental Coordinator or their designee will inspect the placement of the byproductmaterial prior to covering to physically verify that the procedures in this Section 7.0 have beenadequately performed.
8.0 Decontamination and Release of Trailers and Trucks
All trailers and trucks will be decontaminated after unloading prior to leaving the Mill. Shippers
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-4.0 STANDARD OPERA TING PROCEDURES Page 6 of 12 Date: August 23, 2023 Title: 11 e.(2) Byproduct Disposal
or transporters will notify EFRI 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 173.428 or 173.443. Any trailers that are to be released for unrestricted use will be decontaminated according to the requirements found in Table 2 of the Nuclear Regulatory Commission's (NRC's) Regulatory Guide 8.30 Rev. 1 "Health Physics Surveys in Uranium Recovery Facilities" or NRC document "Guidelines for Decontamination of Facilities and Equipment Prior to Release for Unrestricted Use or Termination of Licenses for Byproduct, Source, or Special
Nuclear Material" issued May 1987. Trailers requiring repair will be decontaminated for unrestricted
release, to facilitate repairs by the transporter at the transporter's own site. Trailers may be repaired without undergoing full decontamination ifrepaired within the restricted area of the Mill.
For the appropriate decontamination procedures, refer to the following Standard Operating Procedures
for the appropriate conveyance:
End Dump Trailer Intermodal Container Standard Container Trailer
9.0 Hazard Identification and Safety
1.Required Personal Protective Equipment (PPE)
SOP PBL-9 SOP PBL-2 SOP-PBL-2
In all areas of the Mill covered by this procedure, hard hats, safety glasses and steel-toed shoesare required at a minimum. These must be worn in the restricted area of the Mill. Gloves shallbe worn when manually handling material. Prior to disposal, the RSO will determine what level
of respiratory protection, if any, will be required.
2.Industrial Hazards and Safety
d)Use caution when the trailers are backing to the unloading area.
e)Ensure that all personnel within 50 feet of the area where an end dump trailer is about to dumpits load are aware that unloading is about to commence. Move at least 25 feet away from the rear
of the trailer during the initial unloading operation.
f)Drivers must use caution during the unloading process and be aware of any overhead hazards.
g)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.
h)Use caution when entering or exiting equipment. Be sure to use the ladders and hand rails. Donot jump off the equipment.
i)Always use a ladder when entering and/or exiting the interior of a trailer.
j)Manual handling of any material is discouraged. If it is necessary to manually handle material,
gloves shall be worn as directed by the RSO or Safety Coordinator.
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC. Rev. No.: R-4.0 STANDARD OPERATING PROCEDURES Page 7 of 12
Date: August 23, 2023 Title: 1 le.(2) Byproduct Disposal
3.Mobile Equipment
a)Only trained and authorized persons may operate mobile equipment.
b)All mobile equipment shall be inspected by the operator and any safety defects corrected beforethe 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 in operating condition.
d)Walk around any piece of equipment before starting or moving it. Make certain no one is in adangerous position and there are no obvious defects or hazards.
e)Use caution when entering or exiting equipment. Be sure to use the ladders and hand rails. Do
not jump off the equipment.
f)Seat belts shall be used at all times when equipment is in motion.
g)Equipment shall be operated at a reasonable speed consistent with road and weather conditions,subject to a maximum speed limit of 15 mph.
h)Keep the cabs of equipment clean. Loose items that could jam controls or create other hazards
are not allowed.
i)Report all accidents to your supervisor regardless of how minor they are. If property damage orpersonal 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'sEnvironmental Department files:
•Shipper's Manifest and Bill of Lading.•Laboratory/activity analysis of the byproduct material performed by the Shipper.
•Completed SWT.•7-day notice to Director.•Photo of the byproduct material.
•Byproduct material radiological scan information.•Breathing zone monitoring data, if applicable.
•Equipment release forms.
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC. Rev. No.: R-4.0 STANDARD OPERA TING PROCEDURES Page 8 of 12 Date: August 23, 2023 Title: l le.(2) Byproduct Disposal
All documents and photographs should be dated and the Shipper's Manifest and or Bill of Lading number indicated on the document.
b)Documentation of Disposal
Byproduct material disposal will be documented on the Disposal Documentation Form providedin Attachment 2. Attachment 2 may be accompanied by photographs, a written description orboth. Attachment 2 or other written description will include:
•How the material was placed in the tailing cells;•If void spaces in the drums/barrels containing soil or sludge were filled with tailingssands;•How the area was compacted;•Document that materials placed on tailings are no more than 4 feet thick andsubsequent lifts no more than 2 feet thick;•Document that there are 4 feet of tailings under the bottom of each disposal area andthe bottom of each disposal area is located at least 12 feet from the sides or dikes ofthe tailings area;•Document that the elevation of the material will not exceed the plane or grade of the
elevation of the uppermost flexible membrane liner of the cell.•Confirmation that the shipment was properly covered; and•Where settlement markers were placed. The Mill will maintain a plat of each
Designated Disposal Area, which illustrates the location of each shipment ofbyproduct material.
2.The Mill will maintain on file a copy of the Director's written approval of each Designated
Disposal Area.
An annual summary of the amounts of byproduct material disposed of in each calendar year shallbe sent to the Director as specified in License Condition 10.5F.
11.0 Training
An annual basis, all onsite personnel that are involved in the receiving or disposing of this
material shall be trained in the activities associated with this procedure. This training shall bedocumented and maintained on file.
No.: PBL-10 ENERGY FUELS RESOURCES (USA) INC.
Rev. No.: R-4.0 STANDARD OPERA TING PROCEDURES Date: August 23, 2023 Title: 11 e.(2) Byproduct Disposal
Manifest or BOL #: -----
Are additional settlement monitors required to be placed?
If required, where were the settlement markers placed?
Radiological receipt survey measurements:
Breathing Zone:
1.Was a Breathing Zone Sample collected? Yes or No
2.If yes, what were the results of the sampling?
Was a photograph taken during the unloading activities? Yes or No
Page 12 of 12
8/29/23, 10:38 AM State of Utah Mail - FW: 11e-2 Re-training Log
https://mail.google.com/mail/u/0/?ik=9d08354419&view=pt&search=all&permmsgid=msg-f:1775492829659146420&simpl=msg-f:17754928296591464…1/3
Heather Mickelson <[e-mail]>
FW: 11e-2 Re-training Log
Kathy Weinel <[e-mail]>Mon, Aug 28, 2023 at 10:58 AM
To: "[e-mail]" <[e-mail]>, Ryan Johnson <[e-mail]>
Cc: Garrin Palmer <[e-mail]>
Heather and Ryan,

Retraining for 11e2 disposal operations was conducted last week.

The sign in sheet is attached for your records.

K

Energy Fuels Resources (USA) Inc.
Kathy Weinel
Director, Regulatory Compliance

t:303.389.4134 | c: | f:303.389.4125
[e-mail]
225 Union Blvd., Suite 600
Lakewood, CO 80228
http://www.energyfuels.com
This e-mail is intended for the exclusive use of person(s) mentioned as the recipient(s). This message and any attached files with it are confidential and may
contain privileged or proprietary information. If you are not the intended recipient(s) please delete this message and notify the sender. You may not use,
distribute print or copy this message if you are not the intended recipient(s).

8/29/23, 10:38 AM State of Utah Mail - FW: 11e-2 Re-training Log
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From: Garrin Palmer <[e-mail]>
Sent: Friday, August 25, 2023 12:42 PM
To: Kathy Weinel <[e-mail]>
Subject: 11e-2 Re-training Log

Re-training was completed today.

Energy Fuels Resources (USA) Inc.
Garrin Palmer
Radiation Safety Officer

t:435-678-4114 | c:435-459-9463 | f:
[e-mail]
6425 S. Highway 191
Blanding, UT 84511
http://www.energyfuels.com
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8/29/23, 10:38 AM State of Utah Mail - FW: 11e-2 Re-training Log
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SKM_C45823082512380.pdf
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