DRC-2022-012601 - 0901a06881090c5b

DRC-2022-012601 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-2022-29

THROUGH: Phil Goble, Section Manager

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

DATE: June 6, 2022

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

On March 4, 2022, The Division of Waste Management and Radiation Control (DWMRC) received the
2022 surety update for the White Mesa Mill (Mill) (dated March 2, 2022), edocs # DRC-2022-004426).
The proposed surety represents an increase of $1,048,686 from the approved 2020 surety value of
$20,824,860.

I recommend approving the 2022 surety in the amount of $21,873,546.

Comments

The approach to the surety mirrors the approved 2021 surety, with no change in methods. Prior to
submitting the 2022 surety, the Hydrochloric Acid Storage Tank System was constructed and added to
the surety estimate. The approach to determine the surety estimate for Hydrochloric Acid Storage Tank
System appears appropriate. The Storage Building constructed on the Ore Storage Pad was constructed
after the submittal of the 2022 Annual Surety Review. This item was not included in the 2022 surety
estimate. DWMRC will wait until the 2023 surety estimate to review the reclamation and
decommissioning estimates for the Storage Building; the costs to remove the Storage Building are
expected to be negligible. No decommissioning occurred during 2021.

The principal changes to the surety from 2021 were inflation. Increased costs included: equipment and
fuel costs, labor costs were assumed from the Mill’s personal wages with a 5 percent cost of living
increase, drilling and blasting costs were increased 7% 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 updated and increased this year.

June 6, 2022
06/06/2022
C-2022-26
Memorandum: 2022 Surety Review
Page 2

No conventional ore runs are anticipated in 2022. The company has included funds to handle the
maximum quantities of alternate feed the licensee expects to receive. The mill expects to receive and
process alternate feed and Chemours ore materials during 2022.

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.