DRC-2023-002106 - 0901a068811a7046

DRC-2023-002106 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: File C-2023-28

THROUGH: Phil Goble, Section Manager

FROM: Heather Mickelson, P.E., P.G

DATE: March 28, 2023

SUBJECT: Engineering Module 70, 2023 Surety Estimate Review, Energy Fuels Resources (EFRI),
White Mesa Mill, Blanding, Utah

On March 2, 2023, The Division of Waste Management and Radiation Control (DWMRC) received the
2023 surety update (DRC-2023-001934) for the White Mesa Mill (Mill), dated February 27, 2023.
Further updates (DRC-2023-002566) were received by DWMRC on March 23, 2023. This update was
dated March 20, 2023. The proposed surety represents an increase of $1,951,890 from the approved
2022 surety value of $21,873,546.

I recommend approving the 2023 surety in the amount of $23,825,436.

Comments

The approach to the surety mirrors the approved 2022 surety, with no change in methods.
Decommissioning costs associated with the North Storage Yard Building and the Ra-226 Pilot Plant and
Contaminant (not yet licensed) were added to the surety estimate. No decommissioning occurred during
2022; therefore, no reduction in the surety estimate was taken.

The principal changes to the surety from 2022 were inflation. Increased costs included: equipment and
fuel costs, labor costs were assumed from the Mill’s personal wages with a 4 % cost of living increase,
drilling, blasting, and mobilization costs of the drilling and blasting crews were increased, long-term
care costs were increased based on the consumer price index for all urban consumers. The vendor bid
for the HDPE liner cost was also confirmed.

No conventional ore runs are anticipated in 2023. The company has included funds to handle the
maximum quantities of alternate feed and conventional ore the licensee expects to receive. The mill
expects to receive and process alternate feed and Chemours ore materials during 2023.
3/28/23
03/28/2023
C-2023-28
Memorandum: 2023 Surety Update Review
Page 2

The reclamation plan will be updated with this licensing action associated with the Ra-226 Pilot Plant.
The estimate may need to be changed with the approved reclamation plan.

The breadth of coverage provided is consistent with that required of other licensees. Items of work
include mobilization, demolition and disposal of office facilities, mill decommissioning and disposal,
decommissioning of all tailings and fluid management impoundments with Impoundment 1 used for
uncontaminated waste and Impoundment 4b cleaned up for unrestricted release. The licensee has
included budget allowances for project management and legal support, 10 years of active post-closure
monitoring, long term care, contractor’s profit, licensing and bonding, contract administration, redesign,
automobile and general liability insurance, and equipment rental.