DRC-2014-005382 - 0901a068804925ad

State of Utah
GARY R. HERBERT
Governor
SPENCER J. COX
Lieutenant Governor
Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
DRC-2014-005382 MEMORANDUM
TO:
THROUGH:
FROM:
DATE:
SUBJECT:
l Goble, Section Manager f ^
File C-2014-71
Phi
Russell J. Topham, P.E
September 11,2014
Engineering Module 70, Annual Surety Review, Energy Fuels Resources (EFRI), White
Mesa Mill, Blanding, Utah.
On March 4, 2014 the Utah Division of Radiation Control (DRC) received the 2014 surety update for the
White Mesa Mill. The DRC discussed the findings of its review of that surety submittal in a conference call
with officials of the licensee on April 16, 2014. The licensee responded to those requests in a revised surety
submittal on May 16, 2014. Further telephone conversations occurred on September 5 and 10, 2014. EFRI
submitted a response letter on September 9, 2014 explaining proposed surety funding decreases in Cells 1
and 4B and proposed through email late on September 10, 2014 a change to the Reclamation Plan to
correspond with the quantity reductions proposed for Tailings Cell 4B. Comments regarding EFRI's
responses follow.
1.0 Summary findings and recommendation
The revised surety submittal addresses all current DRC concerns. The licensee has provided a cost estimate
that reflects current costs for identified work items. The proposed surety estimate is $20,657,587, which
represents a reduction of $468,562 from the 2013 surety of $21,126,149. However, the proposed surely
includes consideration of a reclamation pattern for Tailings Cell 4B not consistent with the currently
approved Reclamation Plan. The DRC Licensing Section opposes revising the reclamation plan (3.2B) at
this time and recommends this change be done with the review of Reclamation Plan 5.0, which is currently
under review. Since the proposed surety calculation does not reflect the currently-approved Reclamation
Plan Revision 3.0 and Amendments 3.1 and 3.2b thereto, I recommend asking the licensee to revise the
estimate to reflect the work outlined in the approved Reclamation Plan.
2.0 Closure configuration
The original submittal included reduced earth moving quantities that were the result of reconfiguring the
intended closure contours to something not consistent with the approved Reclamation Plan, Revision 3.2b.
The DRC had expressed support for the concept involved, but had indicated an inability to accept the
approach in surety without having the concept approved in a revised Reclamation Plan. Therefore, the
licensee committed to submit a revision to the Reclamation Plan for DRC consideration, and to reflect the
195 North 1950 West • Salt Lake City, UT
Mailing Address: P.O. Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax [phone] • T.D.D. [phone]
www.deq. ulah.gov
Printed on 100% recycled paper
Page 2
currently approved Reclamation Plan in the surety. The May 16, 2014 submittal provides a different
variation from the approved Reclamation Plan in the earthwork quantities than the approach used in the
original submittal. I discussed this problem with the licensee via telephone, and received a proposed one-
paragraph amendment to the Reclamation Plan.
I shared the proposed amendment to the Reclamation Plan with the Licensing Section manager, and was
informed that he would not support the change unless it was incorporated into Reclamation Plan revision
5.0, which has stalled in review due to inaction of the licensee regarding information requested.
Without the concurrence of the Licensing Section on approving the change to treatment of Tailings Cell
4B, I cannot recommend approval of the Surety unless the Licensee adjusts the surety estimate to reflect
the currently approved plan.
3.0 Seed mix
The original submittal cited a seed mix vendor quote that was nearly 5 years old. The revised submittal
reflects current pricing based upon RSMeans Reference 32 92 19 14 0500. Using RSMeans has the merit
of currency as well as removing an item from the list of vendor quotes in favor of a more objective third-
party pricing source.
4.0 Crane rental inflation adjustment
The original submittal did not show how the crane rental cost quotations were adjusted for inflation. The
revised submittal includes that calculation step.
5.0 Cell 2 and Cell 3 Dewatering
The original submittal did not avail itself of current data regarding the required dewatering effort. The
licensee lengthened the dewatering time to reflect current data in the revised submittal.
6.0 Office rental inflation adjustment
The original submittal did not show how the office rental cost quotations were adjusted for inflation. The
revised submittal includes that calculation step.