DRC-2024-006106

M E M O R A N D U M
TO:File C-2024-26
THROUGH:Adam Wingate, Section Manager, Uranium Recovery SectionRyan Johnson, PG, Health Physicist, Uranium Recovery Section
FROM:Heather Mickelson, P.E., P.G, Uranium Recovery Section
DATE:July 1, 2024
SUBJECT:2024Surety Estimate Review, Anfield Resources Holding Corp.,Shootaring Canyon Uranium Mill, Ticaboo, Utah
On March 29, 2024, the Division of Waste Management and Radiation Control (DWMRC) received the 2024Surety Updatefor the Shootaring Canyon Mill (DRC-2024-005210)(Mill), dated March 21,
2024. The proposed surety represents an increase of $2,966,311 from the approved 2022 surety value of $12,294,452.
I recommend approving the 2024 surety estimate in the amount of $15,260,763.
Comments
The 2023 Surety Update for the Shootaring Canyon Uranium Mill (DRC-2023-003843) required additional information (DRC-2023-071868). This information, along updated costs through 2023,
were included in the 2024 Surety Update. Information specifically requested related to the debris stockpile, the dust control pond, and contractor quotes.
Debris Stockpile
Cost estimates to segregate and dispose of the material in the debris stockpile area were added. Previous estimates indicated that all material in the debris stockpile area was to be
disposed of in the mill tailing cells. However, not all material is 11e.(2) byproduct material.
The 2024Surety Update includes costs to segregate the material into 11e.(2) byproduct material and non-11e.(2) byproduct material. Material that is 11e.(2) byproduct material will be
disposed of in the mill tailing cells. Non-11e.(2) byproduct material will be scanned for transport outside the restricted area and then shipped to a recycling facility or appropriate
landfill.
Dust Control Pond
Cost estimates to remove, transport, and dispose of the dust control pond, as well as costs to abandon Water Well #1, were also included in the 2024 Surety Update.
This pond supplied water for dust control in the restricted area during its construction. The pond is located outside the restricted area and directed water by pipe into the restricted
area, with Water Well #1 providing the water. Previous surety estimates included disposal in the tailings cell. However, this material is not 11e.(2) byproduct material and cannot be
placed in the tailings cell.
Contractor Quotes
Contractor quotes needed to be updated throughout the 2023 surety estimate. The most recent surety update with updated contractor quotes was from 2020.
Contractor quotes are updated every three years. During the two interim years, the costs can be updated with a CPI adjustment. The next year requiring updated contractor quotes is
2026. The 2025 cost estimate can be with a CPI adjustment.
Summary
The purpose of this review is to update cost estimates to decommission and reclaim the mill buildings and the mill site to levels allowing unrestricted use, as described in 10 CFR Part
40 Appendix A Section 1. The breadth of coverage in the 2024 Surety Update provided is consistent with that required of other licensees.
Mill site decommissioning costs include dismantling, decontamination, and/or disposal of all structures and equipment, including the mill site and the mill site vicinity, ore storage
area, access roads around the perimeter of the tailing’s disposal site, evaporation pond residues, and reclamation of disturbed areas from the cleanup activities.
Contamination removal from windblown material and historical mill activities, as well as well-plugging costs, have also been included in the estimate. These costs include excavation
of soiland placement into the tailings cell, with sample collection and analysis to confirm that unrestricted use release criteria are met.
Tailings impoundment area reclamation cost estimates including the placement and production of additional cover materials (including a rock armor layer), construction of diversion channels,
and other measures required for long-term stability. The current tailings have been dewatered and an interim cover has been placed, therefore, costs associated with a stabilization
period for the tailings are not required.
Radiological survey and environmental monitoring sample collection and analysis are included in the estimate.
Personnel costs, other than those needed to complete the work, have also been included in the estimates. These costs cover roles such as project manager/engineer, secretary, clerk, radiation
safety officer, superintendent, technicians, and security. Additionally, costs associated with long-term care, contractor’s profit, and a 25% contingency are included in the estimate.