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• The settled sludge will be stored in the settling cell. The sludge will be removed and <br />disposed of at the end of the mine life or sooner if retention time is compromised. The <br />sludge will be'sampled to determine its radium, uranium and trace metals content, and <br />disposed of appropriately in accordance with all applicable regulations. <br />Energy Fuels collected a sludge sample from a similar treatment pond at its mine facility <br />in Utah and had the sample analyzed for uranium and radium content. A Toxicity <br />Characteristic Leach Procedure (TCLP) test was also performed to determine whether the <br />sludge could be classified as a hazardous waste. The laboratory results are presented in <br />Appendix C. The radium activity level and uranium content were found to be 2.1 pCi/g <br />and 25.2 mg/kg (equivalent to 17.1 pCi/g), respectively. This stodge is essentially a very <br />low-grade uranium ore. Under the Colorado Department of Public Health and <br />Environment's (CDPHE's) interim policy on TENORM dated February 2007, this <br />material would be exempt from CDPHE regulation as its radium and uranium activity <br />levels are less than 3 pCi/g and 30 pCi/g, respectively. The TCLP results were also <br />negative for the eight Resource Conservation and Recovery Act (RCRA) metals. <br />Energy Fuels will collect and analyze a sample of the pond sludge prior 4o making <br />arrangements for its removal and disposal. Depending on the analytical results, the sludge <br />may be recycled or disposed of using one or more of the following options: <br />1, Pumping it out of the pond with a vacuum truck, mixing it with cement grout and <br />. then placing it in a mined out area of the underground workings. <br />2. Mixing it with ore and sending it to a uranium mill for recovery. <br />3. Allowing it to dry and then disposing of it at an approved standard landfill. <br />The sludge analytical results and disposal methods will be documented and reported to <br />the appropriate regulatory agencies. <br />I• <br />14 <br />