HomeMy WebLinkAboutDRC-2019-012708 - 0901a06880b41940Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.com
ENERGYFUELS
Div of Waste Management
and Radiation Control
OCT 1 5 2019
77C,-24 19-012:708
October 9, 2019
SENT VIA E-MAIL AND EXPEDITED DELIVERY
Mr. Ty L. Howard
Director
Division of Waste Management and Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144880
Salt Lake City, UT 84114-4820
Re: Volume and Procedural Modification Request for lle.(2) Byproduct Material
Disposal, Radioactive Materials License UT1900479, White Mesa Uranium Mill,
Blanding Utah
Dear Mr. Howard:
The Nuclear Regulatory Commission ("NRC") regulations in 10 CFR 40 Appendix A, Criterion
2, focuses on avoiding proliferation of small disposal sites and thereby reduce perpetual
surveillance obligations at in-situ uranium recovery ("ISR") operations and other small remote
uranium extraction sites. Accordingly, ISR facilities do not have permanent 1 le.(2) disposal
facilities on site. Instead, upon final closure ISR facilities are decommissioned to free-release
(clean closure) standards. In order to accomplish this, as a condition of their licenses they are
required to enter into and maintain a contract for the disposal of their 11 e.(2) byproduct materials
at an existing off-site licensed 1 1 e.(2) byproduct disposal facility, such as the White Mesa Mill
(the "Mill"). In response to Criterion 2 referenced above, and to accommodate the license
requirements of ISR facilities under this program, the Mill has received and disposed of 1 1 e.(2)
byproduct material from ISR facilities since 1993 under Section 10.5 of the Mill' s Radioactive
Materials License ("RML"), UT1900479. In order to better aceommodate the operational
requirements of ISR licensees, and based on the Mill's experience to date, EFRI would like to
request three changes to the current RML conditions for 1 1 e.(2) byproduct disposal activities as
delineated below. In addition, since 1993 in-situ leach ("ISL") facilities are now referred to as
ISR facilities; therefore references should be changed accordingly.
Section 10.5 of the Mill's RML states:
"In accordance with the licensee's submittal to the NRC dated May 20,1993, the licensee is hereby
authorized to dispose of byproduct material generated at licensed in-situ leach (ISL) facilities,
subject to the following conditions:
Letter to Ty L. Howard
October 9, 2019
Page 2 of 3
A. Disposal of ISL waste is limited to 5000 cubic yards from a single source."
Energy Fuels Resources (USA) Inc. ("EFRI") hereby requests that the RML Section 10.5.A be
modified to read as follows:
A. Disposal of 1 1 e.(2) material from ISR facilities is limited to a total of 10,000 cubic yards
("cy") per year from all sources provided that:
i. the licensee may exceed this amount in any year if required to accept ISR
waste from any facility in connection with the final
reclamation/decommissioning of the facility; and
ii. the licensee may accept an unlimited amount of 1 le.(2) byproduct material
from any facility owned or operated by the licensee or an affiliate of the
licensee.
This volume change reflects the original volume contemplated by the NRC in its RML,
Amendment 33. Further, this volume change allows for the receipt of reclamation items from ISR
facilities as necessary, without the delays associated with the submission of individual volume
change requests.
To conservatively assure that sufficient disposal capacity is available, the annual tailings capacity
evaluation will use 20,000 cy (unless there are any facilities that are going into final reclamation,
in which case this amount will be increased accordingly, if necessary) for future receipts. This
conservatism will be incorporated into the calculation as noted in Section 2.6 of the Standard
Operating Procedure ("SOP"). The annual tailings capacity evaluation will include this amount
converted from cubic yards to dry tons. This conservatism provides assurance that any 1 le.(2)
byproduct materials from ISR facilities will be accounted for prior to receipt.
Section 10.5 D of the Mill's RML states that:
"All disposal activities shall be documented and records thereof maintained on-site. The
documentation shall include descriptions of the ISL waste and the disposal locations, as well as all
actions required by this License condition."
Section 10.5.E of the Mill's RML states that:
"ISL Disposal Requirements. The licensee shall perform ISL disposal activities in accordance with
the current Director approved Standard Operating Procedure (SOP) for ISL disposal. Said plan
includes the following minimum provisions:
(3) Such ISL byproduct material shall be segregated from any mill material and equipment
disposed of in the cells pursuant to License Condition 10.4, and the ISL byproduct material
from each in-situ leach source shall be segregated from the byproduct material from all
other in-situ leach sources;"
2
Letter to Ty L. Howard
October 9, 2019
Page 3 of 3
EFRI hereby requests a change to the above requirements in 10.5.D and 10.5.E.(3) to remove the
location documentation and waste segregation stipulations to read as follows:
D. All disposal activities shall be documented and records thereof maintained on-site. The
documentation shall include the information required in the Director-approved SOP.
E. ISR Disposal Requirements. The licensee shall perform placement activities of 1 1 e.(2)
byproduct material from ISR facilities in accordance with the current Director-approved
SOP. Said SOP includes the following minimum provisions:
(3) Such ISR byproduct material shall be disposed of in the cells pursuant to License
Condition 10.4;
The proposed change would allow more expeditious and efficient placement of 1 1 e.(2) byproduct
materials with no adverse effects. It is important to note that the liner protection elements in 10.5.E
would remain in effect and thereby continue to be protective of the liner.
Redlined revised SOPs for 1 1 e.(2) byproduct material disposal and tailings capacity evaluations
are included in Attachments A and B for Division of Waste Management and Radiation Control
("DWMRC") approval.
If you should have any questions regarding this letter, please contact me.
Yours very truly, Mir kt;--44,
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
CC: Scott Bakken
Mark Chalmers
David Frydenlund
Paul Goranson
Garrin Palmer
Harold Roberts
Logan Shumway
Terry Slade
3
Attachment A
No. : PBL-10
Rev. No.: R-3.45
Date: February 1,
20180ctober 9, 2019
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 11 e.(2) Byproduct Disposal
Page 1 of 13
1.0 Purpose
Energy Fuels Resources (USA) Inc. ("EFRI") receives 1 1 e.(2) byproduct material ("byproduct
material") from uranium in-situ leach 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 dump
container, etc.)
4. Results of analysis for U-Nat, Ra-226, Th-230 and Pb-210 on all sludges and soils and other
material that is suited to sample collection. If a representative sample of the material was taken
in connection with a previous shipment of material, then the results of that previous
representative sample may be relied upon, and may be referred to or restated in the
documentation that accompanies the shipment of the material. For byproduct material which is
not suited to sample collection (i.e. metals, process equipment, filter media, pipes, etc.) the
Shipper will determine the range, the average and the total activity, measured in millirem/hour
(mr/hr) at a range of one meter, for each shipment.
5. A copy of the completed shipping manifest that will accompany the shipment and the anticipated
shipping date.
The Environmental Coordinator or their designee will verify, prior to receipt of any shipment of
byproduct material, that the disposal of such byproduct material will not cause the Mill to exceed the
limits of 5,000 cubic yards of byproduct material from a single source, set out in Mill License condition
10.5k
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
No.: PBL-10
Rev. No.: R-3.45
Date: February 1,
204-80ctober 9, 2019
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: I 1 e.(2) Byproduct Disposal
Page 2 of 13
criteria:
1. The Designated Disposal Area must be in an active tailings cell (i.e., a tailings cell that is not
fully covered with interim cover);
2. The Designated Disposal Area must be on a tailings beach area of the cell or on an area of the
cell that is underlain by tailings sands;
3. There must be at least 4 feet of tailings sands under the Designated Disposal Area;
4. The Designated Disposal Area must be located at least 12 feet from the sides or dikes of the
tailings cell;
5. Survey information or other document review will be maintained to confirm that the elevation
of the Designated Disposal Area once filled with byproduct material must not exceed the plane
or grade of the elevation of the uppermost flexible membrane liner of the tailings cell;
.1. Detailed engincering-drawinp; must have been prepared and kept n file at thc Mill that
dcm nstratc f r each Designated Dis sal Arca that:
a) There arc at 1ee4-
twt4
b).4) The tt m of the Designated Dis sal Arca is located at least 12 feet fr m the sides r
dikes of the tailings cell ; and
c) Each disposed ISL byproduct material has been segregated from any mill material and
equipment disposed of in the cells and the ISL byproduct material from each in situ leach
source will be segregated from the byproduct material from all other in situ leach sources;
776. ISLR wastes will be disposed in cells that have received prior written approval from the
Director for this purpose.
8. Prior written approval must have been obtained from the Director of the Utah Radiation
Control Board (the "Director") for each Designated Disposal Arca, under Mill License
condition 10.5C, and evidence of such approval must be on file at the Mill.
977. Byproduct material from each ISL facility is disposed in Designated Disposal Areas specific to
that ISL facility. Designated Disposal Areas include either trench areas or tailings beach areas.
The procedures for placement are not dependeant on which area the byproduct material is
placed in. The above procedures are the same for both trench areas and tailings beach areas.
Detailed engineering drawings must have been prepared and kept on file at the Mill that demonstrate
for each Designated Disposal Area that: When a new Designated Disposal Area is needed, EFRI will
delineate the usable area within the cell footprint with stakes, fencing, bollards or other material(s)
such that it is clear that the area meets requirements in items 3 and 4 above.
No.: PBL-10
Rev. No.: R-3.45
Date: February 1,
20180etober 9, 2019
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1le.(2) Byproduct Disposal
Page 3 of 13
There are at Ieast 4 feet of tailin
and
s sands under the bottom of the Designated Disposal Area;
The bottom of the Designated Disposal Area is located at least 1 2 feet from the sides or dikes
of the tailings cells; and
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 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.
2. The onsite transportation expert shall inspect all copies of the Shipping Manifest and the
transporter's Bill of Lading to ensure that the shipment is destined for the Mill and confirm with
the Environmental Coordinator, or their designee that the shipment has been approved for
receipt.
3. Record the inbound date and both the tnick and trailer nurnbers on the Scale house Weight
Ticket (SWT).
4. Enter the loaded weight of the truck and trailer on the SWT.
5. The scale house operator will contact the Environmental Department so that the shipment can
be escorted by Environmental personnel to the Designated Disposal Area specified by the
Environmental Coordinator.
6. Prior to transporting material to the Designated Disposal Area (pending on weather), the driver
will be instructed to open or untarp the load. The Environmental personnel and the
transportation expert will visually inspect, to the degree possible, the byproduct material to
ensure that the material matches the material description on the shipping manifest. Any
discrepancies between the byproduct material received and the manifest information will be
reported to the Environmental Coordinator.
No.: PBL-10
Rev. No.: R-3.45
Date: Febniaff-i-i
204-80ctober 9, 2019
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 e.(2) Byproduct Disposal
Page 4 of 13
a. Any byproduct material suspected of not conforming to Section 2.0 of this SOP will
not be transported to the disposal site, unless a determination is made by the
Environmental Coordinator that the material in question conforms to Section 2.0 of
this SOP.
b. Barrels containing soil or sludges shall be checked to determine if they are full prior
to transporting them for disposal. Barrels not completely full shall be documented
and shall be filled with tailings or soil prior to disposal. (License Condition 10.5.B).
c. If weather conditions exist that makes the opening of the conveyance impossible at
the untarping station, the Environmental personnel may take the conveyance to a
suitable location in which to inspect the load. A suitable location will be one where
the load may be viewed where employees are safely out of the way when the
conveyance doors are opened and where if material was to fall out of the conveyance,
that contamination issues will not be incurred. An example area could the tails
impound area near the disposal site.
6.0 Byproduct Material Unloading
1. The Environmental Coordinator will specify the specific location within the broader Designated
Disposal Area for disposal of the shipment. In-designating-the-speeifie-leeatien-within-the-bfeadef
Designated Disposal Area for disposal of the shipment, the Environmental Coordinator will
ensure that all byproduct material will be segregated from any Mill material and equipment
frem-eaeh4S-L-seuree-will-be-segfegated-frem-the-bypfeduet-material-frem-all-ether-ISL-seurees.:
2. Environmental personnel will escort the shipment to the designated location in the Designated
Disposal Area for unloading of the byproduct material.
• 3. Proposed Methods and Procedures to Fully Protect the Liner While Accessing Tailings
Cells for Disposal of ISRL Byproduct Material and Mill Equipment
a. The shipment will be transported to the Designated Disposal Area only on established
roadways onto the tailings cells.
b. At no time will a shipment be transported over or in a manner that will damage
unprotected dikes, liners, other structures or settlement monitors associated with any of the
tailings cells.
c. There must be at least 4 feet of tailings sands under the Designated Disposal Area
(ialeeufnentatiert-ef-the-dispesal-afea-must-be-eempleted-and-en-file-prier-te-Elay-Elispesai
activities);
d. The Designated Disposal Area must be located at least 12 feet from the sides or dikes of
the tailings cell (active areas will be marked as noted abovedeetimentatien-ef-the-Elispesal
afea-fnust-be-eempIet-ed-and-en-file-pfier-t-e-any-dispesal-aetivities);
e. No travel into the disposal area will be allowed unless the disposal cell liner is covered
by at least 18 inches of soil or fill material at the point of access.
No.: PBL-10
Rev. No.: R-3.45
Date: February 1,
201 gOctober 9, 2019
ENERGY FUELS RESOURCES (USA) NC.
STANDARD OPERATING PROCEDURES
Title: 1 e.(2) Byproduct Disposal
Page 5 of 13
4. If the 7 calendar day notice referred to in Section 4.0 above has not been given, or the 7 days
have not lapsed, then the shipment may be, but is not required to be contained in the shipping
container (that is, the container-bin or trailer) on site until the required 7 day notice has been
given and the 7 calendar days have lapsed.
5. If the shipment is determined to be acceptable, the following procedures will be followed:
a) If the 7-day notice has been given under Section 4.0 above and the 7 calendar days have lapsed,
the byproduct material will then be unloaded in the designated area. If such notice has not been
given or if such 7 day period has not lapsed, then the byproduct material will be unloaded in an
area of the tailings cell that is not covered with interim cover and from which the material can be
removed if necessary. Once the required notice has been given and the required 7 days have
lapsed, the byproduct material will then be placed into the designated area.
b) If the material is in a self-unloading container, the driver will be instructed to unload ensuring all
personnel are clear of the trailer and the immediate area. Byproduct material will be dumped
from the transport in a safe manner to minimize dust. If the material requires unloading by a fork
truck, a ramp will be installed and unloading will proceed.
c) After unloading, the Environmental personnel will visually inspect the unloaded byproduct
material to ensure that there is no newly discovered material which does not match the material
description on the shipping manifest. Any discrepancies between the byproduct material
received and the manifest information will be reported to the Environmental Coordinator. Any
byproduct material suspected of not meeting the requirements set forth in Section 2.0 of this SOP
will be kept segregated from other waste material until a determination is made of its
acceptability for disposal.
d) After unloading, a photo of the unloaded material will be taken which is attached to the shipping
documentation for verification of shipment contents.
e) The location of the shipment of the byproduct material will be documented on the plat of each
Designated Disposal Area illustrating the disposal area within the Designated Disposal Area
where4he-bypreduet-material-will-be-dispesed-ef:
fe) Beta-gamma measurements will be taken at several locations around the unloaded material. This
information will be recorded on the Radiation Department' s copy of the shipment documentation.
The measurement range in mrem/hr at 2 meters, and the average measurement, measured in
mrem/hr at 2 meters, shall be recorded.
gf) Measurements using a photoionization detection meter ("PID") will be taken at several locations
around the unloaded material to ensure that there are no organics present. The information will
be recorded on the Environmental Department's copy of the shipment documentation. If organics
are detected, the Environmental Coordinator must be advised, and no compaction or covering
activities relating to the shipment shall occur until specifically instructed by the Environmental
Coordinator. The Environmental Coordinator and Safety Coordinator will determine if any
additional safety precautions are required to be taken by workers or otherwise as a result of the
No.: PBL-10
Rev. No.: R-3.45
Date: Febniary-17
20-1-gOctober 9, 2019
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 11e.(2) Byproduct Disposal
Page 6 of 13
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 1 e.(2) byproduct material from the shipper's ISRL facility. Once the
Environmental Coordinator has verified that the organics are byproduct material compaction and
covering activities will proceed.
hg) A breathing zone sample will be taken periodically during unloading and cover activities. If the
gross alpha exceeds 25% of the applicable DAC, then the RSO will be notified, and all other
unloading activities of byproduct material from that particular ISRL site will require the use of
respiratory protection, until further notice by the RSO.
ih) After unloading the byproduct material, replace the tarp or close the trailer, unless the trailer is
being decontaminated for unrestricted release.
ii) Direct the driver back to the scales for an empty weight.
kj) The scale house operator will record the empty weight on the appropriate SWT.
lk) Shipment and disposal activities will be documented as described in Section 10, below.
7.0 Covering of Byproduct Material
1. After the byproduct material has been accepted by the Environmental Coordinator, or their
designee, the byproduct material will be spread within the designated area within the Designated
Disposal Area to facilitate compaction and covering.
2. The byproduct material will be compacted with at least four passes of the construction equipment
prior to placing an additional layer.
3. Free volumes in the byproduct material will be minimized by filling, sectioning, or crushing.
Random fill or tailings sands will be used to fill voids in and around the byproduct material.
4. All contaminated equipment shall be dismantled, crushed, or sectioned to minimize void spaces.
Barrels containing waste other than soil or sludges shall be emptied into the disposal area and the
barrels crushed. Barrels containing soil or sludges shall be verified to be full prior to disposal.
Barrels not completely full shall be filled with tailings or soil.
5. A one foot thick, or thicker, cover comprised of native soil will be placed over the byproduct
material working area. The fill and cover material will be compacted with at least one pass of
the construction equipment.
6. The Environmental Coordinator or their designee will inspect the placement of the byproduct
material prior to covering to physically verify that the procedures in this Section 7.0 have been
adequately performed.
No.: PBL-10
Rev. No.: R-3.45
Date: February 1,
20180ctober 9, 2019
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 11e.(2) Byproduct Disposal
Page 7 of 13
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. 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 if repaired within the restricted area of the Mill.
For the appropriate decontamination procedures, refer to the following Standard Operating Procedures
for the appropriate conveyance:
End Dump Trailer SOP PBL-9
Intermodal Container SOP PBL-2
Standard Container Trailer SOP-PBL-2
9.0 Hazard Identification and Safety
1. Required Personal Protective Equipment (PPE)
In all areas of the Mill covered by this procedure, hard hats, safety glasses and steel-toed shoes
are required at a minimum. These must be worn in the restricted area of the Mill. Prior to
disposal, the RSO will determine what level of respiratory protection, if any, will be required.
2. Industrial Hazards and Safety
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 dump
its load are aware that unloading is about to commence. Move at least 25 feet away from the rear
of the trailer during the initial unloading operation.
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. Do
not jump off the equipment.
No.: PBL-10
Rev. No.: R-3.45
Date: Fcbruary 1,
20180ctober 9, 2019
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 11 e.(2) Byproduct Disposal
Page 8 of 1 3
i) Always use a ladder when entering and/or exiting the interior of a trailer.
3. Mobile Equipment
a) Only trained and authorized persons may operate mobile equipment.
b) All mobile equipment shall be inspected by the operator and any safety defects corrected before
the equipment is used. If safe to do so, the equipment may be driven to the shop for repairs.
Otherwise, the equipment must be towed or repaired at the location.
c) Audible backup alarms shall be in operating condition.
d) Walk around any piece of equipment before starting or moving it. Make certain no one is in a
dangerous position and there are no obvious defects or hazards.
e) Use caution when entering or exiting equipment. Be sure to use the ladders and hand rails. Do
not jump off the equipment.
f) Seat belts shall be used at all times when equipment is in motion.
g) Equipment shall be operated at a reasonable speed consistent with road and weather conditions,
subject to a maximum speed limit of 1 5 mph.
h) Keep the cabs of equipment clean. Loose items that could jam controls or create other hazards
are not allowed.
i) Report all accidents to your supervisor regardless of how minor they are. If property damage or
personal injury is involved, do not move the equipment until your supervisor has released it.
j) All gasoline engines must be shut off when refueling.
k) Keep equipment clear of edges, drop offs, and unstable banks. Maintain adequate berms where
required.
10.0 Documentation
1 . a) Documentation of Shipments
For each shipment of byproduct material the following records will be maintained in the Mill's
Environmental Department files:
• Shipper's Manifest and Bill of Lading.
• Laboratory/activity analysis of the byproduct material performed by the Shipper.
• Completed SWT.
• 7-day notice to Director.
• Photo of the byproduct material.
No.: PBL-10
Rev. No.: R-3.45
Date: February 1,
20180etober 9, 2019
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 le.(2) Byproduct Disposal
Page 9 of 13
• 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;
• If void spaces in the drums/barrels containing soil or sludge were filled with tailings
sands;
• How the area was compacted;
• Document that materials placed on tailings are no more than 4 feet thick and
subsequent lifts no more than 2 feet thick (this information will be obtained for each
ISL disposal area and maintained by the engineering department);
• Document that there are 4 feet of tailings under the bottom of each disposal area and
the bottom of each disposal area is located at least 1 2 feet from the sides or dikes of
the tailings area this information will be obtained for each ISL disposal area and
maintained by the engineering department);
• Document that the elevation of the material will not exceed the plane or grade of the
elevation of the uppermost flexible membrane liner of the cell.
• Confirmation that the shipment was properly covered; and
• Where settlement markers were placed. The Mill will maintain a plat of each
Designated Disposal Area, which illustrates the location of each shipment of
byproduct material.
2. The Mill will maintain on file a copy of the Director's written approval of each Designated
Disposal Area.
An annual summary of the amounts of byproduct material disposed of in each calendar year shall
be sent to the Director on or before November 1 of the calendar year. (License Condition 10.5F).
[summary due same year]
1 1 .0 Training
An annual basis, all onsite personnel that are involved in the receiving or disposing of this
material shall be trained in the activities associated with this procedure. This training shall be
documented and maintained on file.
No.: PBL-10
Rev. No.: R-3.45
Date: February 1,
20180ctober 9, 2019
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: I I e.(2) Byproduct Disposal
Page 10 of 13
ATTACHMENT 1
SAFETY TRAINING FOR DELIVERY PERSONNEL
Welcome to Energy Fuels Resources (USA) Inc.'s, White Mesa Mill. In order to assure your safety
while on our property, we would like to acquaint you with the safety rules and procedures, which you
will be required to follow while on our property.
1.0 General Safety
1. Approved hard hats and safety glasses are required at all times except when inside the cab of
your truck.
2. This is a smoke free facility. No smoking is allowed on the property. Eating anything, drinking,
chewing candy, gum or tobacco is also not allowed in the Mill Restricted Area due to radiation
hazards.
3. Maintain a safe speed at all times when driving in the Mill Restricted Area. The maximum
speed limit is posted at 1 5 mph. Energy Fuels Resources (USA) Inc.'s equipment has the right
of way on the ore pad and Mill roadways.
4. Be aware of the possibility of a truck turning over while dumping. Ensure that the truck is on
level ground and brakes are set prior to dumping.
5. Check for potential overhead hazards prior to dumping.
6. If material is hung up in the trailer bed, it is not permissible to work in the bed while it is in the
dump position. If it is necessary to get in the bed of the trailer to free a hang up, the bed must
be lowered.
7. Be aware of slippery conditions on the ore pad during periods of inclement weather.
8. Be aware of the potential for ice build-up on and around the decontamination pad during periods
of cold weather.
9. Use caution when entering or exiting equipment.
2.0 Radiation Safety
1. All drivers are required to scan for alpha radiation prior to leaving the Mill Restricted Area.
2. All equipment, i.e. trucks and trailers, will be scanned for radiation prior to leaving the Mill's
Restricted Area.
Driver (Printed) Scale House Operator
Driver (Signature) Date
No.: PBL-10
Rev. No.: R-3.45
Date: February 1,
20180ctober 9, 2019
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: I 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:
Shipper's Manifest or Bill of Lading number:
Was the State of Utah given notice to the receipt/disposal activities associated with this load? Yes or
No
Who gave and when was the notification given?
Description of byproduct material disposal area/activities:
Has each drum been inspected to identify the presence of any void spaces?
Have all drums with void spaces been filled with tailings sands or soil?
Which tailings cell was the material placed in?
Was the material placed on a tailings beach area of the cell or on an area of the cell that was underlain
by tailings sands?
Was the material segregated from any Mill material or equipment disposed of in the cell?
No.: PBL-10
Rev. No.: R-3.45
Date: February 1,
20180ctober 9, 2019
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1 1 e.(2) Byproduct Disposal
Page 12 of 13
Manifest or BOL #:
Have the thickness and placement measurements been verified and documented for the disposal area by
the engineer, specifically:
Engineer's or
Environmental
Coordinator' s
Initials
Was the in by the material placed a cell approved executive
SecretaryDirector for ISLR waste disposal?
Documentation of approval
Was ISL from disposed Mill the material segregated material and other
ISL material?
Refer to to plat(s) used confirm.
Was the maximum lift thickness above tailings less than 4 feet
thick?
Was the maximum lift thickness of subsequent lifts less than 2 feet thick?
Has 4 foot of tailings sands been maintained under each disposal
area?
to used confirm Refer drawings to
Is the bottom of each disposal area at least 12 feet from the sides or dikes
of the tailings cell?
used confirm. Refer to drawings to
Will the elevation of the material exceed the plane or grade of the
elevation of the uppermost flexible membrane liner of the cell?
How was this confirmed (e.g., survey or review)
-How was the area compacted? Was each lift compacted by heavy equipment (such as a Cat D-6) at
least 4 times prior to placement of subsequent lifts?
Were void spaces filled with tailings?
Was the shipment properly covered?
No.: PBL-10
Rev. No.: R-3.45
Date: Febi-liy47
20180ctober 9, 2019
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: 1le.(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 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
Attachment B
5
No.: PBL-3
Rev. No.: R-54
Date: June 90ctober
9 2019, 2018
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: Tailings Capacity Evaluation
Page 1 of 2
1.0 Purpose:
The State of Utah Division of Waste Management and Radiation Control ("DWMRC")
license for the White Mesa uranium mill ("Mill") is a Performance-Based License ("PBL").
The PBL allows Energy Fuels Resources (USA) Inc. ("EFRI") to evaluate and implement
certain changes in the licensed operation without applying for and receiving a formal
amendment to the DWMRC license. The following procedure outlines the steps to follow
when accepting additional conventional ore or alternate feed materials, to ensure that the
currently permitted capacity of the Tailings Management System is not exceeded. This
Standard Operating Procedure (SOP) is in conformance with the Mill's DWMRC License.
2.0 Tailings Capacity Determination Procedure:
Whenever the Mill is considering receiving conventional ore, 1 le.(2) material, or an alternate
feed, the capacity of the Mill Tailings Management System will have to be evaluated to
ensure that sufficient volume is available to store the projected incremental volumes of
tailings material, as well as the projected volumes of waste material from final reclamation of
the Mill facility, based on the approved Reclamation Plan. This evaluation will be performed
on an annual basis by the Mill Manager, or his designee, and approved by the President and
CEO of EFRI, or his designee. The Tailings Capacity Determination will be completed by
December 1January 31 of each calendar year utilizing the volumes of conventional ore,
1 1 e.(2) material and alternate feed materials projected to be received in EFRI' s approved
operating budget for the following-that year.
The procedure for determining whether there is sufficient capacity is described as follows
and documented on the attached Tailings Capacity Form.
2.1 For the initial evaluation, the base volume ("BV") available will be based on the
remaining capacity in the active tailings cell, as determined by the Mill Manager
from land surveys and production records (copies of which are attached). For each
subsequent evaluation, the previous evaluation will produce a current remaining
tailings capacity value, which will become the new BV for each active tailings cell.
2.2 Mill Management will maintain a Tailings Capacity Evaluation Record ("TCER")
book, in which all evaluation forms and supporting calculations will be maintained.
Refer to the TCER to obtain the BV value to be used in each subsequent evaluation.
2.3 The volume of tailings discharged to the active tailings cells between the date of the
BV and the evaluation date will be estimated based on the Mill's production reports.
No.: PBL-3
Rev. No.: R-54
Date: June 90ctober
9. 2019, 2018
ENERGY FUELS RESOURCES (USA) INC.
STANDARD OPERATING PROCEDURES
Title: Tailings Capacity Evaluation
Page 2 of 2
2.4 The amount of 11(e).2 in-situ waste material deposited into the tailings system
between the date of the BV and the evaluation date will be summarized. The
quantities of material will be listed by supplier and will be based on the Scale House
Weigh Tickets from each shipment.
2.5 The BV, minus the quantities in items 2.3 and 2.4 above, will become the current
tailings capacity. This number will be used as the BV (item 2.1 above) for the
subsequent evaluation.
2.6 The amount of alternate feed material or conventional ore committed to be processed
and deposited into the tailings system will be summarized. The maximum projected
quantities of material will be listed by supplier and stated in dry tons, i.e. less the
estimated moisture content. MaximumAnnual calculations will use 20,000 cy of
11(e).2 materials converted fromt;tated in cubic yards to dry tons. In instances where
the Mill will accept more material to accommodate decommissioning/reclamation of
an ISR facility, the volume will be estimated based on projections from the supplier.
2.7 The sum of the quantities estimated in item 2.6 above will be subtracted from the
current tailings capacity calculated in item 2.5 above, to determine the remaining
capacity available.
2.8 The remaining available volume in each of the active tailings cells will be converted
to an equivalent volume in dry tons using a factor of 86 dry pounds cubic foot of
available storage, or 2,322 dry pounds per cubic yard (1.16 dry tons per cubic yard).
This factor was calculated in the Tailings Capacity Evaluation prepared in May of
2000. The factor was subsequently confirmed from drilling conducted in preparation
of the Tailings Data Analysis Report, MWM, April 2015.