DRC-2016-004483 - 0901a06880610b50

ENERGYFUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
PRC-2014,-00^4-93 www.energyfuels.com
March 1, 2016
Sent VIA E-MAIL AND OVERNIGHT DELIVERY
Div of Waste Management
and Radiation Control
MAR - 3 2016
Mr. Scott Anderson
Director
Division of Waste Management and Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144880
Salt Lake City, UT 84114-4820
Re: Transmittal of Revised Chloroform Plume Reclamation Plan and Cost Estimate
UDEQ Docket No. UGW20-01 White Mesa Uranium Mill
Dear Mr. Anderson:
Reference is made to the Energy Fuels Resources (USA) Inc. (“EFRI”) Chloroform Plume Reclamation Plan
and Cost Estimate (“CPRP-CE”), submitted to the Division of Waste Management and Radiation Control
(“DWMRC”) on January 11, 2016. Pursuant to comments from your staff, EFRI is submitting revisions to
Attachment A of the CPRP-CE. The attached updated estimate represents a total revision to Attachment A of
the CPRP-CE and replaces Attachment A in its entirety.
The attached cost estimate has also been included in the Miscellaneous Tab in the White Mesa Mill Annual
Surety Update, submitted to DWMRC and dated March 1, 2016.
If you should have any questions regarding this submittal please contact me.
Yours very truly,
Energy Fuels Resources (USA) Inc.
Kathy Weinel
Quality Assurance Manager
CC: David Frydenlund
Harold Roberts
David Turk
Logan Shumway
Scott Bakken
Attachment A
White Mesa Mill Chloroform Project Reclamation Plan Cost Estimate
Chloroform Pumping System - Required Surety Estimate
Task 1:
Task 2:
Task 3:
Task 4:
Task 5:
Operation for a 10 year period.
Maintenance for a 10 year period.
Monitoring for a 10 year period.
Reporting for a 10 year period.
Chloroform System Abandonment
Direct Costs
Indirect Costs
Total
$ 185,252
$ 104,382
$ 763,045
$ 101,653
$ 21,920
$ 1,176,252
$99,233
$1,275,485
Profit Allowance
Contingency
Licensing & Bonding
UDEQ Contract Administration
10.00% $2,192
0.00% $0
2.00% $23,525
4.00% $47,050
2.25% $26,466
$99,233
Engineering Design Review
Indirect Costs
Chloroform Pumping System - Required Surety Estimate
Task 1: Operation for a 10 year period.
Assumptions
The full Chloroform pumping and monitoring system has already been installed.
Operation will be performed by the Environmental Technician at $30,890 per hour.
Environmental Technician will be local labor hired by a DWMRC Contractor. A 15% markup has been applied to the actual labor rate.
Daily operation checks take 1.0 hours for 1 Environmental Technician.
Weekly operation checks take 3.0 hours for 1 Environmental Technician.
Measure Depth to Water Monthly 6 hours for 1 Environmental Technician.
Water from the chloroform pumping sysytem will be pumped to the evaporation or tailings ponds or used in the Mill process. After
reclamation, the water will pumped to the Cell 2 Slimes evaporation pond. The costs associated with the Cell 2 slimes evaporation
pond are included in the Miscellaneous items.
Power $0.07/KWH
Average power of each pump motor = 0.75 hp.
Average pumping time per day =1.1 hr.
Item
Daily Operation Checks - Labor
Quantity Units
Hrs/Day
Quantity Units
365 hrs/Yr
Cost
$ 11,274
Weekly Operation Checks - Labor Hrs/Wk 156 hrs/Yr $4,819
Measure Depth to Water Monthly Hrs/Month 72 hrs/Yr 2,224
Pumping hours per well per quarter 1.1 Hrs/Day 401.5 hrs/Yr 16.00
Total per year
Total 10 years
18,525
$ 185,252
Task 2: Maintenance for a 10 year period.
Assumptions
Maintenance will be performed by the Environmental Technician at $30,890 per hour.
Environmental Technician will be local labor hired by a DWMRC Contractor. A 15% markup has been applied to the actual labor rate.
Pump Replacement takes 4 hours for 2 Environmental Technicians.
Average of 3 pump replacements per year. Each replacement pump costs $2,200.
Flow Meter Replacement takes 2 hours for 2 Environmental Technicians.
Average of 4 flow meter replacements per year. Each replacement flow meter costs $245.
Heat lamp bulb replacement labor is included in daily operational checks.
Average of 14 heat lamp bulb replacements per year. Each bulb cost $10.
Average of 3 pipeline freezing per year.
Clearing of a pipeline freeze takes 8 hours for 2 Environmental Technicians. No material costs.
Item
Pump Replacement
Quantity Units
Labor Hours /
Year
Replaced / year 24
Material Cost
per year Cost
6600 $7,341
Flow Meter Replacement Replaced / year 16 980 $1,474
Heat Lamp Replacement 14 Replaced / year 140 140
Frozen Pipeline Clearing Clearing / year 48 $1,483
Total $ 10,438
Total 10 years $ 104,382
3/1/2016 - 2:22 PM-WMM Rec Plan Est Mar 2016 Rev 4.19
Energy Fuels Resources (USA) Inc.
White Mesa Mill
Task 3: Monitoring for a 10 year period.
Assumptions
Analytical cost per sample = $169
45 samples per quarter
Sample collection will be performed by an Environmental Technician and a Contractor Field Geologist.
Environmental Technician = $31.89 per hour. Field Geologist = $90.00 per hour
Environmental Technician will be local labor hired by a DWMRC Contractor. A 15% markup has been applied to the actual labor rate.
Sample collection requires 80 hours for 2 Environmental Technicians per quarter.
Item Quantity Units Quantity Unit Cost
Analytical Costs 180 Samples/year 169 $/Sample $ 30,420
Sampling Labor - Environmental Technician 320 Hrs/year 30.89 $/hr $9,884
Sampling Labor - Field Geologist 320 Hrs/year 90.00 $/hr 28,800
Field Geologist - Travel Costs 40 Days/year 180.00 $/day 7,200
Total
Task 4: Reporting for a 10 year period.
Total 10 years
76,304
$763,044.67
Assumptions
Reporting will be performed by the Environmental Technician at $30,890 per hour.
Environmental Technician will be local labor hired by a DWMRC Contractor. A 15% markup has been applied to the actual labor rate.
Report preparation is expected to take 40 hours for the Environmental Technician to complete each quarter.
Quarterly analysis of contamination extent is estimated to cost $3,000.
Item Quantity Units Quantity Unit Cost
Report Preparation I 160 | Hrs/year | $30.89 $/hr $4,942
Contamination Analyisis per year $3,000.00 $/Quarter $ 12,000
Total 10 years $ 101,653
Task 5: Chloroform System Abandonment
Assumptions
Pumps and well head enclosures will be loaded on a flat bed truck by hand.
Abandonment will be performed by the Environmental Technician at $30,890 per hour.
Wells will be abandoned in accordance with State of Utah Administrative Code R655-4 subsection 14.9
Flatbed truck with operator costs $55/hr.
Assumed 1 hour of labor to remove each pump and enclosure.
The materials will be discarded in the active trash area of the tailing cells if available or in an off-site landfill.
Well casing will be cut off 2 feet below the ground level.
The well will be abandoned by filling will Hole Plug.
Hole Plug Material cost estimated at $2 per foot of well.
Average well depth of 120 feet.
There is 2,600 feet of underground electrical line and 3,850' of pipeline.
The HDPE pipeline and power line will be uncovered with a 365 Excavator.
The 365 Excavator is estimated to excavate or backfill 412 feet per hour.
The 365 Excavator costs $155/hr without the operator.
The Excavator will also backfill the trench after the pipe has been removed.
Assumed 8 hours to place the pipeline and powerlines in the tailing cell.
Item
Pull pumps and remove enclosures
Quantity Units Labor Hrs
Equipment
Hours Total Cost
13 Pumping Wells 13 13 $ 1,116.56
Abandon All Wells - Labor 38 Wells 38 0 $ 1,173.78
Abandon All Wells - Materials 38 Wells $ 9,120.00
Landfil Charges 1 Surcharge 0 0 $ 5,000.00
Excavate and Backfill Pipeline Trench 12900 Linear Feet 39.34 31.34 $ 5,510.09
Total $ 21,920.43
3/1/2016 - 2:22 PM-WMM Rec Plan Est Mar 2016 Rev 4.19
Energy Fuels Resources (USA) Inc.
White Mesa Mill