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This material is listed as a hazardous substance under CERCLA with a reportable <br />quantity of 1,000 pounds <br />(TSCA - Toxic Substances Control Act, CERCLA - Comprehensive Environmental <br />Response, Compensation and Liability Act) <br />4.5 Disposal of Wastes <br />Wastes from the materials packaging will be placed in the site's roll-off container for <br />solid wastes. Any chemical wastes from use of the reagents will be contained within the <br />trailer. If any spillage of dry chemicals occurs, the material will be swept-up and placed <br />into a proper storage container for reuse. Spillage of chemical solutions will be cleaned <br />up with a water hose and directed toward a floor drain near the back of the trailer. The <br />trailer is set up so the back of the trailer is slightly lower (i.e., '/4 to '/2 inch lower) than the <br />front to provide adequate drainage. A flexible plastic pipe connects the floor drain to a <br />400-gallon storage tank located outside the trailer. Any solution that collects in the <br />storage tank will be evaluated for reuse or proper disposal, as appropriate. <br />The settled sludge will be stored in the Settling Tank. 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 and uranium content and disposed of <br />appropriately in accordance with TENORM regulations promulgated by the Colorado <br />Department of Public Health and Environment. <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 sludge 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 tank sludge prior to making <br />arrangements for it removal and disposal. Depending on the analytical results, the sludge <br />may be disposed of by: <br />1. Pumping it out of the tank 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 processing. <br />3. Allowing it to dry and then disposing of it at an approved landfill. <br />15