DRC-2012-002552 - 0901a06880339543

DRC-2012-002552
ENERGYFUELS
Energy Fuels Resources (USA) Inc
225 Union Blvd Suite 600
Lakewood. CO, US, 80228
303 974 2140
www energyfuels com
VIA EMAIL AND OVERNIGHT DELIVERY
December 19,2012
Mr Rusty Lundberg
Director of the Utah Division of Radiation Control
State of Utah Department of Environmental Quality
195 North 1950 West
P O Box 144850
Salt Lake City, UT 84116-4850
2012
Re: White Mesa Mill State of Utah Radioactive Material License No. UT 1900479
Response to Letter of November 29,2012
Report Justifying Additional Volume of Excavation at Former Claricone Site (Response)
Request for Information
Dear Mr Lundberg:
This letter responds to the Division of Radiation Control's ("DRC's) above-named Request for
Information of November 15, 2012, which EFRI received on November 19, 2012 regarding EFRI's
October 26, 2012 Response Letter and Summary Report Justifying Additional Volume of Excavation for
Claricone (the "Response Letter and Summary Report"). DRC's comments are reproduced verbatim,
below, followed by EFRI's response For ease of review, a revised version of the Summary Report,
with changes indicated in redline/stnkeout format, is enclosed, along with a clean copy ofthe report
DRC Comment'
1 While the plan concept looks appropriate, the map provides little detail to assure that
excavation occurs where intended Decommissioning activities will likely result in removal of
structures and other permanent landmarks prior to performing the excavation To correct this
situation, please provide either coordinates or a boundary description for the proposed
excavation site Tie the coordinates or boundary to known USGS survey monumentation
EFRI Response
EFRI used the Mill's handheld GPS survey instrument to locate survey coordinates (latitude and
longitude) for nine points around the perimeter of the previously completed excavation The coordinates
are based on the NADA 83 coordinate system Mr Russ Topham of DRC advised EFRI m a phone
discussion on December 12, 2012, that this method is acceptable to DRC The attached revisions to the
Letfer to Rusty Lundberg
December 19,2012
Page2of 11
figure in Attachment 2B of the Revised Summary Report provide the survey coordinates for each of the
nine points
DRC Comment:
2 Decommissioning activities near the excavation site will likely result in disturbance ofthe
ground surface To assure that the excavation reaches the proper depth, please provide the
elevation above mean sea level for the excavation floor Tie this elevation to USGS
monumentation
EFRI Response-
EFRI determined the cunent surface elevation by survey coordinated to the USGS survey monument
number MILL 101 (near the Mill's Cell 1) Based on the survey from this monument, the surface
elevation of the clean backfill at the former Claricone area is 5625 49 feet amsl As discussed in the
Revised Summary Report, the bottom of the previously completed excavation, was 25 feet below the
ground surface, (or 5600 49 feet amsl). The bottom of the proposed excavation will be 27 feet below
ground surface (or 5598 49 feet amsl)
DRC Comment
3 The portion of the Response devoted to justifying the quantity of earth to be moved did not
consider the possibility that workers may need to follow contamination outside the intended
limits of excavation Please adjust the Response to reflect this consideration If necessary,
please adjust the volume of new fill required
EFRI Response'
EFRI has provided a revised version of the Summary Report entitled Proposed Excavation at Mill
Decommissioning to Remove Potentially Contaminated Soil, which was imtially submitted on October
26, 2012 As discussed in the Revised Summary Report, EFRI agrees to excavate additional soil volume
as follows*
EFRI proposes to excavate an additional two feet in every direction (around the penmeter and below the
bottom of the existing excavation). The excavation of an additional two feet in each direction will result
in an estimated 1,000 cubic yards of potentially contaminated soil to be excavated
The proposed excavation v^ll require the removal of the 4,600 cubic yards of clean backfill in order to
reach the additional two feet of potentially contaminated soil around the perimeter and bottom of the
former excavation. The removed 4,600 cubic yards would theoretically be set aside for reuse in
refilling the excavation, and would not need to be placed in the tailings area For conservatism, the cost
estimate has assumed that up to 2,000 cubic yards of the 4,600 removed clean fill could potentially be
contaminated and would also be disposed in the tailings system rather than replaced in the excavation as
backfill.
Lettfer to Rusty Lundberg
December 19,2012
Page 3 of 11
In response to DRC Comment 3, above, we also agree to add an additional estimated volume of 1,000
cubic yards to address the possibility that additional contamination potentially extended outside the
proposed 2-foot penmeter excavation
The above addition for theoretically-contaminated soil inside and outside the 2-foot perimeter
excavation comprise an additional 3,000 cubic yards of soil to be excavated Therefore, the volume
estimate of disposed contaminated soils has been increased to 4,000 cubic yards, quadruple the volume
mdicated by the proposed 2-foot penmeter.
The enclosed revised Summary Report reflects these proposed changes in redline. The White Mesa Mill
Reclamation Cost Estimate has been modified to reflect the increased excavation volume discussed
above.
If you have any questions, please contact me at [phone]
Yours very truly.
ENERGY FUELS RESOURCES (USA) INC.
Jo Ann Tischler
Director, Compliance
cc David C Frydenlund
Phihp Goble
Dan Hillsten
Harold R Roberts
Tom Rushing
David E Turk
Kathy Weinel
Attachments
Redline
Letffer to Rusty Lundberg
December 19,2012
Page 4 of 11
REVISED SUMMARY REPORT
PROPOSED EXCAVATION AT MILL DECOMISSIONING
TO REMOVE POTENTIALLY CONTAMINATED ADDITIONAL SOIL
Description of Previous Excavation
A sketch of the White Mesa Mill process area indicating the approximate location and boundaries of the April
2012 Claricone excavation are provided m Attachment 2A Contaminated equipment, process matenal, and soil
was disposed m Cell 3
As described in the May 4, 2012 Notice and Plan, after removal of Claricone equipment, associated structures,
and the pumpable portion of the spilled solutions, the April 2012 Claricone excavation was conducted as follows
The extent of soil removal addressed both chemical and radiological contamination All soils visibly wet,
stained or discolored were excavated until uncontammated dry background soils remained
The bottom and sides of the excavation were scanned by microR meter (measunng residual gamma
contamination) When the bottom or sides of the excavation indicate gamma levels greater than background
levels, the excavation was resumed, additional contaminated soil was removed, and the bottom and sides ofthe
excavation were re-scanned until all surfaces result in gamma levels less than or equal to cleanup background
(Cleanup background was defined as two times the average of four measured background readmgs taken as
described in Attachment 3 This approach accounted for the contnbution to background of gamma radiation
from other nearby process equipment such as the clanfier, thickener, and CCD impounds ) When the bottom
and sides of the excavation indicated gamma levels of less than cleanup background as defined above, the
excavation was considered complete, and the area was prepared for backfill and re-grading
The May 4, 2012 Notice and Plan indicated that the total estimated volume removed from the excavation was
1,134 cubic yards Based on final drawings and the volume of clean replacement soil used to backfill the
excavation, the total estunated volume of material actually removed was 4,600 cubic yards as indicated in the
figure m Attachment 2B The excavated volume of 4,600 cubic yards was subsequently replaced with clean
backfill
Conservative Basis for Larger Excavation Volume
The previously completed excavation attempted to locate and remove all contaminants discharged dunng the
Clancone spill by
1 Removal of all material visibly stained or wet Any soil apparently wet, containmg visible spilled
material (crystals, precipitates, lumps), discolored, or having an otherwise non-typical appearance, was
excavated
2 Removal of radionuclides based on delineation by gamma detection A gamma survey was considered
to be suitable because the spilled Claricone solutions contained appreciable concentrations of gamma-
emittmg radionuclides
3 Assumption that chemical constituents would be removed by removal of detectable radionuclides The
Clancone contained saturated solutions undergoing solid/liquid separation for recovery of solid
constituents, and did not contain gaseous or volatile constituents that would not be detected by either
visual examination or radiological scanning Although the transport of chemical constituents m
environmental media may differ substantially from the transport of those constituents identifiable by
Letfer to Rusty Lundberg
December 19,2012
Page 5 of 11
radiological scannmg, it was assumed that chemical constituents would be captured because the very
short duration between the Claricone spill and the completion of the removal action (15 days total) would
not allow for any appreciable migration of chemical constituents
The areal footprint of the excavation was determined by assuming the entire area up to adjacent equipment in
every direction around the 29 foot diameter Clancone would be removed As indicated in Attachment 2B, an
area approximately 56 feet in its narrowest dimension and 80 feet m its longest dimension was excavated
After removal of all the visibly contaminated soil, the depth of the excavation was determined by locating the
deepest depth below ground surface at which any radiological (gamma) detection exceeded the background
determined as described above The entire footprint was then excavated to that maximum depth The excavation
was completed to a depth of 25 feet below ground surface ("bgs") across the entire footpnnt
Nonetheless, dunng discussions with DRC in August 2012, DRC indicated concem that due to the lack of
confirmatory radiological sampling, the gamma survey method may not have bounded the entire extent of the
contamination Although EFRI believes that the contamination has been removed in its entirety, EFRI agreed to
assess an additional area and depth that could be excavated at the time of Mill decommissioning, as an extra
measure of conservatism
Justification for Calculated Soil Volume
Although EFRI believes the contamination has been removed, EFRI has agreed to removal of an additional soil
volume as indicated in Attachment 2B EFRI proposes to excavate an additional two feet in every direction
(around the penmeter and below the bottom of the existing excavation) The excavation of additional two feet in
each direction will result in an estimated 1,000 cubic yards of potentially contaminated soil to be excavated
For the purposes of developing a conservative estimate of additional cost for the reclamation surety, EFRI has
tn^led-quadrupled the excavation volume from 1,000 to ^;QOQ4.000 cubic yards for the cost calculations for the
reasons discussed herein
The proposed excavation will require the removal of the 4,600 cubic yards of clean backfill m order to reach the
additional two feet of potentially contammated soil around the perimeter and bottom of the former excavation
The removed 4,600 cubic yards would theoretically be set aside for reuse in refilling the excavation, and would
not need to be placed in the tailings area
For conservatism, the cost estimate has assumed that up to 2,000 cubic yards of the 4,600 removed clean fill could
potentially be contaminated and would also be disposed in the tailings system rather than replaced m the
excavation as backfill
In order to address the possibility that workers may need to remove some additional contamination outside the
intended two feet excavation penmeter as drawn m the figure in Attachment 2B. the volume estimate assumes an
additional 1.000 cubic yards may potentially be excavated outside the proposed perimeter Since the presence of
any theoretical contamination outside the perimeter has not been demonstrated, a precise location for the removal
ofthe additional 1.000 cubic yards has not been drawn on the figure
Therefore, the volume estunate of disposed contaminated soils has been tripled from 1,000 to ^70004.000 cubic
yards
Letter to Rusty Lundberg
December 19,2012
Page 6 of 11
Surface Map and Cross Sections
As mentioned above, a surface map of the Mill mdicating the area of the proposed additional Clancone
excavation is provided in Attachment 2A A detail of the proposed excavation area is provided in Attachment 2B
The removal resulted m an excavation with a flat floor at 25 feet bgs and vertical sidewalls throughout the "hole"
Based on information from well logs at the nearest wells (MW-27, TWN-2, and TW4-25), the top of the low
permeability Mancos shale in the vicinity of the excavation varies from less than 5 feet to approximately 9 or
more feet The top of the lower permeability Dakota sandstone vanes from approximately 16 feet to over 27 feet
EFRI agrees to perform the additional excavation at the time of decommissioning consistent with the previously
completed excavation, that is, to excavate a vertical-walled flat bottomed excavation 2 feet wider in each
dimension than the completed and backfilled excavation Excavated soil would be disposed in the tailings cells
Surefy Estimate
A revised surety estimate including line items for work associated with excavation, removal and disposal of the
additional volume of soil to be removed is provided in Attachment 3 As discussed above, for conservatism, the
revised surety estimate assumes triple the 1,000 cubic yard volume indicated in the drawings, that is it assumes a
3,000 cubic yard additional excavation
The assumption of an additional 3,000 cubic yard excavation resulted in an additional line item under the Mill
Decommissioning costs entitled "Claricone Contaminated Soil Disposal" of $6,937 This addition to the surety
estimate results in a revised total surety estunate of $20,309,858
Letter to Rusty Lundberg
December 19,2012
Page 7 of 11
ATTACHMENT 1
Letter to Rusty Lundberg
December 19,2012
Page 8 of 11
ATTACHMENT ISA
Location of Former Claricone Area
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Letter to Rusty Lundberg
December 19,2012
Page 9 of 11
ATTACHMENT i2B
Mill Decommissioning
Planned Soil Removal m Claricone Area
NOTES
• 4,600 cuyds of soil was removed at the time of the
removal of the Claricone
• The excavation proposed at the time of mill decomission
totals 1,000 cuyds
• The proposed area includes a two foot extension to the
boundary of previously excavated soils
• The surface elevation is taken as 5625 5 ft above msl as
referenced from mill survey monument MILL 101
ISIONS
By
Project Clancone Excavation Project
County
Location
San Juan County State Utah
White Mesa Mill
Mill Decommissioning
Planned Soils Removal
in Clancone Area
ss 10/4/12 Drafted By gg
Letter to Rusty Lundberg
December 19,2012
Page 10 of 11
ATTACHMENT iSC
Cross Sectional Dimensions of Claricone Excavation
ATTACHMENT 12C
CROSS SECTIONAL DIMENSIONS OF CLARICONE EXCAVATION
The Apnl 2012 excavation of contaminated and additional soil associated with the Claricone spill
consisted of an excavation footprint as shown in the plan drawing in Attachment liB, with
• Excavation to a flat bottom depth of 25 feet below ground surface ("bgs ") all the way across the
blue hatched area of excavation, and
• Approximately vertical side walls around the entire penmeter as indicated by the blue hatched
area in Attachment liB
The proposed excavation of potentially-contaminated additional soil at Mill decommissioning would
consist of
• Excavation to a flat bottom depth of an additional 2 feet, that is 27 feet bgs, all the way across
the area of excavation, and
• A perimeter of an additional two foct2-foot width as indicated by the red hatched area in
Attachment 12B, with approximately vertical side walls
• Potential excavation of an additional 1.000 cubic vards of soil contamination theoreticaiiv
outside the proposed 2-foot width The location of this volume has not been depicted in
Attachment IB
Letfer to Rusty Lundberg
December 19, 2012
Page 11 of 11
ATTACHMENT 2^
Reclamation Cost Estimate Revision 4 12
WHITE MESA MILL RECLAMATION COST ESTIMATE
December 2012
Revision 4.12
Mobilization $437,800
Office Facilities $58,500
Mill Decommissioning $2,139,409
CelM $1,776,448
Cell 2 $1,803,668
Cell 3 $2,057,848
Ceil 4A $1,435,844
Cell 4B $1,465,011
Management Support $2,297,613
Miscellaneous $869,063
Subtotal Direct Costs $14,341,205
Profit Allowance 10 00% $1,434,120
Contingency 15 00% $2,151,181
Licensing & Bonding 2 00% $286,824
UDEQ Contract Administration 4 00% $573,648
Engineenng Design Review 2 25% $322,677
Contractors Equipment Floater $82,250
Automobile and General Liability Insurance $284,600
Long Term Care Fund $833,353
Total Reclamation $20,309,858
Revised Bond Amount $20,309,858
12/17/2012 -11 07 AM - WMM Rec Plan Est December 2012 Rev 4 12
Denison Mines (USA) Corp
White Mesa Mill
MILL DECOMMISSIONING
MILL DECOMMISSIONING
Mill Building Demolition
Resource Descnption Units Cost/Unit Task Units Task Cost
Mechanics
Laborers
Small Tools
Cat 770 Haul Truck
Truck Dnvers
Cat 988 Loader
Cat 988 Loader Operator
Cat 365 Excavator
Cat 365 Excavator Operator
PC 300 w/metal Shears
PC 300 Operator
60 Ton Crane
60 Ton Crane Operator
30 Ton Crane
30 Ton Crane Operator
Equipment Maintenance (Butler)
Concrete Removal
Total Mill Building Demolition
hrs $15 03 640 $9,618
hrs $15 25 320 $4,879
hrs $1 35 960 $1,296
hrs $97 66 640 $62,501
hrs $21 51 640 $13,768
hrs $137 94 160 $22,071
hrs $25 75 160 $4,120
hrs $133 91 160 $21,425
hrs $27 26 160 $4,362
hrs $154 00 160 $24,639
hrs $27 26 160 $4,362
hrs $97 93 160 $15,668
hrs $28 41 160 $4,545
hrs $62 40 80 $4,992
hrs $28 41 80 $2,273
hrs $1910 1,360 $25,974
sf $3 30 37,500 $123,750
$350,244
Ore Feed Demolition
Resource Description Units Cost/Unit Task Units Task Cost
Mechanics
Laborers
Small Tools
Cat 770 Haul Truck
Truck Dnvers
Cat 988 Loader
Cat 988 Loader Operator
Cat 365 Excavator
Cat 365 Excavator Operator
PC 300 w/metal Shears
PC 300 Operator
30 Ton Crane
30 Ton Crane Operator
Equipment Maintenance (Butler)
Total Ore Feed Demolition
hrs $15 03 64 $962
hrs $15 25 32 $488
hrs $1 35 96 $130
hrs $97 66 64 $6,250
hrs $21 51 64 $1,377
hrs $137 94 16 $2,207
hrs $1721 16 $275
hrs $133 91 16 $2,143
hrs $20 65 16 $330
hrs $154 00 16 $2,464
hrs $20 65 16 $330
hrs $62 40 0 $0
hrs $28 41 0 $0
hrs $19 10 112 $2,139
$19,095
SX Building Demolition
Resource Descnption Units Cost/Unit Task Units Task Cost
Mechanics
Laborers
Small Tools
Cat 770 Haul Truck
Truck Drivers
Cat 988 Loader
Cat 988 Loader Operator
Cat 365 Excavator
Cat 365 Excavator Operator
PC 300 w/metal Shears
PC 300 Operator
60 Ton Crane
60 Ton Crane Operator
30 Ton Crane
30 Ton Crane Operator
Equipment Maintenance (Butler)
Concrete Removal
Total SX Building Demolition
12/17/2012 -11 07 AM-WMM Rec Plan Est December 2012 Rev 4 12
hrs $15 03 320 $4,809
hrs $15 25 160 $2,439
hrs $1 35 480 $648
hrs $97 66 320 $31,251
hrs $21 51 320 $6,884
hrs $137 94 80 $11,035
hrs $25 75 80 $2,060
hrs $133 91 80 $10,713
hrs $27 26 80 $2,181
hrs $154 00 80 $12,320
hrs $27 26 80 $2,181
hrs $97 93 0 $0
hrs $28 41 0 $0
hrs $62 40 0 $0
hrs $28 41 0 $0
hrs $19 10 560 $10,695
sf $3 30 55,970 $184,701
$281,917
Denison Mines (USA) Corp
White Mesa Mill
MILL DECOMMISSIONING
CCD Circuit Removal
Resource Descnption Units Cost/Unit Task Units Task Cost
hrs $15 03 120 $1,803
hrs $15 25 60 $915
hrs $1 35 180 $243
hrs $97 66 120 $11,719
hrs $21 51 120 $2,582
hrs $137 94 30 $4,138
hrs $1721 30 $516
hrs $133 91 30 $4,017
hrs $20 65 30 $620
hrs $154 00 30 $4,620
hrs $20 65 30 $620
hrs $97 93 30 $2,938
hrs $15 76 30 $473
hrs $62 40 15 $936
hrs $15 76 15 $236
hrs $19 10 255 $4,870
sf $3 30 15,000 $49,500
Mechanics
Laborers
Small Tools
Cat 770 Haul Truck
Truck Dnvers
Cat 988 Loader
Cat 988 Loader Operator
Cat 365 Excavator
Cat 365 Excavator Operator
PC 300 w/metal Shears
PC 300 Operator
60 Ton Crane
60 Ton Crane Operator
30 Ton Crane
30 Ton Crane Operator
Equipment Maintenance (Butler)
Concrete Removal
Total CCD Circuit Removal $90,746
Sample Plant Removal
Resource Descnption Units Cost/Unit Task Units Task Cost
Mechanics
Laborers
Small Tools
Cat 770 Haul Truck
Truck Dnvers
Cat 988 Loader
Cat 988 Loader Operator
Cat 365 Excavator
Cat 365 Excavator Operator
PC 300 w/metal Shears
PC 300 Operator
30 Ton Crane
30 Ton Crane Operator
Equipment Maintenance (Butler)
Concrete Removal
Total Sample Plant Removal
hrs $15 03 32 $481
hrs $15 25 16 $244
hrs $1 35 48 $65
hrs $97 66 32 $3,125
hrs $21 51 32 $688
hrs $137 94 8 $1,104
hrs $1721 8 $138
hrs $133 91 8 $1,071
hrs $20 65 8 $165
hrs $154 00 8 $1,232
hrs $20 65 8 $165
hrs $62 40 0 $0
hrs $28 41 0 $0
hrs $19 10 56 $1,070
sf $3 30 4,200 $13,860
$23,408
Temporary Storage Building Removal
Resource Descnption Units Cost/Unit Task Units Task Cost
hrs $15 25 8 $122
hrs $1 35 8 $11
hrs $97 66 2 $195
hrs $21 51 2 $43
hrs $137 94 2 $276
hrs $25 75 2 $52
hrs $19 10 4 $76
sf $3 30 600 $1,980
Laborers
Small Tools
Cat 770 Haul Truck
Truck Dnvers
Cat 988 Loader
Cat 988 Loader Operator
Equipment Maintenance (Butler)
Concrete Removal
Total Temporary Storage Building Removal $2,755
12/17/2012 -11 07 AM-WMM Rec Plan Est December 2012 Rev 4 12 Denison Mines (USA) Corp
White Mesa Mill
MILL DECOMMISSIONING
Truck Shop Removal
Resource Descnption Units Cost/Unit Task Units Task Cost
Mechanics
Laborers
Small Tools
Cat 770 Haul Truck
Truck Dnvers
Cat 988 Loader
Cat 988 Loader Operator
Cat 365 Excavator
Cat 365 Excavator Operator
PC 300 w/metal Shears
PC 300 Operator
30 Ton Crane
30 Ton Crane Operator
Equipment Maintenance (Butler)
Concrete Removal
Total Truck Shop Removal
Boiler Demolition
Resource Descnption
Mechanics
Laborers
Small Tools
Cat 770 Haul Truck
Truck Dnvers
Cat 988 Loader
Cat 988 Loader Operator
Cat 365 Excavator
Cat 365 Excavator Operator
PC 300 w/metal Shears
PC 300 Operator
60 Ton Crane
60 Ton Crane Operator
30 Ton Crane
30 Ton Crane Operator
Equipment Maintenance (Butler)
Concrete Removal
Total Boiler Demolition
hrs $15 03 32 $481
hrs $15 25 16 $244
hrs $1 35 48 $65
hrs $97 66 24 $2,344
hrs $21 51 24 $516
hrs $137 94 8 $1,104
hrs $1721 8 $138
hrs $133 91 8 $1,071
hrs $20 65 8 $165
hrs $154 00 8 $1,232
hrs $20 65 8 $165
hrs $62 40 0 $0
hrs $28 41 0 $0
hrs $19 10 48 $917
sf $3 30 4,200 $13,860
Units Cost/Unit Task Units
$22,301
Task Cost
hrs $15 03 160 $2,405
hrs $15 25 80 $1,220
hrs $1 35 240 $324
hrs $97 66 160 $15,625
hrs $21 51 160 $3,442
hrs $137 94 40 $5,518
hrs $17 21 40 $689
hrs $133 91 40 $5,356
hrs $20 65 40 $826
hrs $154 00 40 $6,160
hrs $20 65 40 $826
hrs $97 93 0 $0
hrs $15 76 0 $0
hrs $62 40 0 $0
hrs $15 76 0 $0
hrs $19 10 280 $5,348
sf $3 30 2,900 $9,570
$57,308
Vanadium Oxidation Circuit Removal
Resource Descnption Units Cost/Unit Task Units Task Cost
Mechanics
Laborers
Small Tools
Cat 770 Haul Truck
Truck Dnvers
Cat 988 Loader
Cat 988 Loader Operator
Cat 365 Excavator
Cat 365 Excavator Operator
PC 300 w/metal Shears
PC 300 Operator
60 Ton Crane
60 Ton Crane Operator
30 Ton Crane
30 Ton Crane Operator
Equipment Maintenance (Butler)
Concrete Removal
Total Vanadium Oxidation Circuit Removal
12/17/2012 -11 07 AM-WMM Rec Plan Est December 2012 Rev 4 12
hrs $15 03 64 $962
hrs $15 25 32 $488
hrs $1 35 96 $130
hrs $97 66 64 $6,250
hrs $21 51 64 $1,377
hrs $137 94 16 $2,207
hrs $1721 16 $275
hrs $133 91 16 $2,143
hrs $20 65 16 $330
hrs $154 00 16 $2,464
hrs $20 65 16 $330
hrs $97 93 0 $0
hrs $15 76 0 $0
hrs $62 40 0 $0
hrs $15 76 0 $0
hrs $19 10 112 $2,139
sf $3 30 1,200 $3,960
$23,055
Denison Mines (USA) Corp
White Mesa Mill
MILL DECOMMISSIONING
Mam Shop/Warehouse Demolition
Resource Descnption Units Cost/Unit Task Units Task Cost
hrs $15 03 128 $1,924
hrs $15 25 64 $976
hrs $1 35 192 $259
hrs $97 66 128 $12,500
hrs $21 51 128 $2,754
hrs $137 94 32 $4,414
hrs $1721 32 $551
hrs $133 91 32 $4,285
hrs $20 65 32 $661
hrs $154 00 32 $4,928
hrs $20 65 32 $661
hrs $19 10 224 $4,278
sf $3 30 19,300 $63,690
Mechanics
Laborers
Small Tools
Cat 770 Haul Truck
Truck Drivers
Cat 988 Loader
Cat 988 Loader Operator
Cat 365 Excavator
Cat 365 Excavator Operator
PC 300 w/metal Shears
PC 300 Operator
Equipment Maintenance (Butler)
Concrete Removal
Total Mam Shop/Warehouse Demolition $101,880
Decon Pads (2) Demolition
Resource Descnption Units Cost/Unit Task Units Task Cost
hrs $15 03 64 $962
hrs $15 25 32 $488
hrs $1 35 96 $130
hrs $97 66 64 $6,250
hrs $21 51 64 $1,377
hrs $137 94 16 $2,207
hrs $1721 16 $275
hrs $133 91 16 $2,143
hrs $20 65 16 $330
hrs $154 00 16 $2,464
hrs $20 65 16 $330
hrs $19 10 112 $2,139
sf $3 30 1,350 $4,455
Mechanics
Laborers
Small Tools
Cat 770 Haul Truck
Truck Dnvers
Cat 988 Loader
Cat 988 Loader Operator
Cat 365 Excavator
Cat 365 Excavator Operator
PC 300 w/metal Shears
PC 300 Operator
Equipment Maintenance (Butler)
Concrete Removal
Total Decon Pads (2) Demolition $23,550
Office Building Demolition
Resource Descnption Units Cost/Unit Task Units Task Cost
Mechanics
Laborers
Small Tools
Cat 770 Haul Truck
Truck Drivers
Cat 988 Loader
Cat 988 Loader Operator
Cat 365 Excavator
Cat 365 Excavator Operator
PC 300 w/metal Shears
PC 300 Operator
Equipment Maintenance (Butler)
Concrete Removal
Total Office Building Demolition
hrs $15 03 96 $1,443
hrs $15 25 48 $732
hrs $1 35 144 $194
hrs $97 66 96 $9,375
hrs $21 51 96 $2,065
hrs $137 94 24 $3,311
hrs $1721 24 $413
hrs $133 91 24 $3,214
hrs $20 65 24 $496
hrs $154 00 24 $3,696
hrs $20 65 24 $496
hrs $19 10 168 $3,209
sf $1 25 12,100 $15,125
$43,768
12/17/2012 -11 07 AM-WMM Rec Plan Est December 2012 Rev 4 12 Denison Mines (USA) Corp
White Mesa Mill
MILL DECOMMISSIONING
Septic Tanks and Dram Fields
Resource Descnption Units Cost/Unit Task Units Task Cost
hrs $15 03 0 $0
hrs $15 25 16 $244
hrs $1 35 32 $43
hrs $97 66 16 $1,563
hrs $21 51 16 $344
hrs $137 94 8 $1,104
hrs $1721 8 $138
hrs $133 91 8 $1,071
hrs $20 65 8 $165
hrs $154 00 0 $0
hrs $20 65 0 $0
hrs $19 10 32 $611
Mechanics
Laborers
Small Tools
Cat 770 Haul Truck
Truck Dnvers
Cat 988 Loader
Cat 988 Loader Operator
Cat 365 Excavator
Cat 365 Excavator Operator
PC 300 w/metal Shears
PC 300 Operator
Equipment Maintenance (Butler)
Total Septic Tanks and Dram Fields $5,283
Misc Tankage & Spare Parts Removal
Resource Description Units Cost/Unit Task Units Task Cost
Mechanics
Laborers
Small Tools
Cat 770 Haul Truck
Truck Dnvers
Cat 988 Loader
Cat 988 Loader Operator
Cat 365 Excavator
Cat 365 Excavator Operator
PC 300 w/metal Shears
PC 300 Operator
Equipment Maintenance (Butler)
Total Misc Tankage & Spare Parts Removal
hrs $15 03 48 $721
hrs $15 25 24 $366
hrs $1 35 72 $97
hrs $97 66 48 $4,688
hrs $21 51 48 $1,033
hrs $137 94 12 $1,655
hrs $1721 12 $207
hrs $133 91 12 $1,607
hrs $20 65 12 $248
hrs $154 00 12 $1,848
hrs $20 65 12 $248
hrs $19 10 84 $1,604
$14,321
Alternate Feed Circuit and Reagent Storage Building
Resource Descnption Units Cost/Unit Task Units Task Cost
Mechanics
Laborers
Small Tools
Cat 770 Haul Truck
Truck Dnvers
Cat 988 Loader
Cat 988 Loader Operator
Cat 365 Excavator
Cat 365 Excavator Operator
PC 300 w/metal Shears
PC 300 Operator
Equipment Maintenance (Butler)
Concrete Removal
hrs $15 03 50 $751
hrs $15 25 50 $762
hrs $1 35 96 $130
hrs $97 66 50 $4,883
hrs $21 51 50 $1,076
hrs $137 94 34 $4,690
hrs $1721 34 $585
hrs $133 91 34 $4,553
hrs $20 65 34 $702
hrs $154 00 52 $8,008
hrs $20 65 52 $1,074
hrs $19 10 170 $3,247
sf $3 30 3,500 $11,550
Total Alternate Feed Circuit and Reagent Storage Building $42,011
12/17/2012 -11 07 AM-WMM Rec Plan Est December 2012 Rev 4 12 Denison Mines (USA) Corp
White Mesa Mill
MILL DECOMMISSIONING
Mill Yard Decontamination
Resource Descnption Units Cost/Unit Task Units Task Cost
hrs $215 65 274 $59,087
hrs $27 26 274 $7,470
hrs $137 94 68 $9,380
hrs $25 75 68 $1,751
hrs $98 69 68 $6,711
hrs $25 75 68 $1,751
hrs $83 49 68 $5,677
hrs $25 75 68 $1,751
hrs $115 79 68 $7,874
hrs $23 48 68 $1,597
hrs $73 28 68 $4,983
hrs $27 26 68 $1,854
hrs $19 10 614 $11,727
Cat 637 Scraper
Cat 637 Scraper Operator
Cat 988 Loader
Cat 988 Loader Operator
Cat D8N Dozer With Ripper
Cat D8N Dozer Operator
Cat D7 Dozer
Cat D7 Dozer Operator
Cat 651 Watenvagon
Cat 651 Watenwagon Operator
Cat 14H Motorgrader
Cat 14H Mptorgrader Operator
Equipment Maintenance (Butler)
Total Mill Yard Decontamination*
Ore Storage Pad Decontamination
Resource Descnption
$121,613
Includes Ammonimum Sulfate Storage Tank contamination
Units Cost/Unit Task Units Task Cost
hrs $215 65 189 $40,757
hrs $1931 189 $3,649
hrs $137 94 48 $6,621
hrs $1721 48 $826
hrs $98 69 48 $4,737
hrs $20 65 48 $991
hrs $83 49 48 $4,008
hrs $20 65 48 $991
hrs $11579 48 $5,558
hrs $18 16 48 $872
hrs $73 28 48 $3,517
hrs $20 62 48 $990
hrs $19 10 429 $8,193
Cat 637 Scraper
Cat 637 Scraper Operator
Cat 988 Loader
Cat 988 Loader Operator
Cat D8N Dozer With Ripper
Cat D8N Dozer Operator
Cat D7 Dozer
Cat D7 Dozer Operator
Cat 651 Watenvagon
Cat 651 Waterwagon Operator
Cat 14H Motorgrader
Cat 14H Motorgrader Operator
Equipment Maintenance (Butler)
Total Ore Storage Pad Decontamination $81,712
Equipment Storage Area Cleanup
Resource Descnption Units Cost/Unit Task Units Task Cost
Cat 637 Scraper
Cat 637 Scraper Operator
Cat 988 Loader
Cat 988 Loader Operator
Cat D8N Dozer With Ripper
Cat D8N Dozer Operator
Cat D7 Dozer
Cat D7 Dozer Operator
Cat 651 Watenwagon
Cat 651 Waterwagon Operator
Cat 14H Motorgrader
Cat 14H Motorgrader Operator
Equipment Maintenance (Butler)
Total Equipment Storage Area Cleanup
hrs $215 65 68 $14,664
hrs $19 31 68 $1,313
hrs $137 94 17 $2,345
hrs $1721 17 $293
hrs $98 69 17 $1,678
hrs $20 65 17 $351
hrs $83 49 17 $1,419
hrs $20 65 17 $351
hrs $115 79 17 $1,968
hrs $18 16 17 $309
hrs $73 28 17 $1,246
hrs $20 62 17 $351
hrs $19 10 153 $2,922
$29,210
12/17/2012 -11 07 AM-WMM Rec Plan Est December 2012 Rev 4 12 Denison Mines (USA) Corp
White Mesa Mill
MILL DECOMMISSIONING
Revegetate Mill Yard & Ore Pad
Resource Descnption Units Cost/Unit Task Units Task Cost
hrs $215 65 174 $37,523
hrs $19 31 174 $3,360
hrs $137 94 0 $0
hrs $1721 0 $0
hrs $98 69 33 $3,257
hrs $20 65 33 $682
hrs $83 49 33 $2,755
hrs $20 65 33 $682
hrs $115 79 0 $0
hrs $18 16 0 $0
hrs $73 28 33 $2,418
hrs $20 62 33 $681
Acre $322 50 50 $16,125
hrs $19 10 273 $5,214
Cat 637 Scraper
Cat 637 Scraper Operator
Cat 988 Loader
Cat 988 Loader Operator
Cat D8N Dozer With Ripper
Cat D8N Dozer Operator
Cat D7 Dozer
Cat D7 Dozer Operator
Cat 651 Watenvagon
Cat 651 Watenvagon Operator
Cat 14H Motorgrader
Cat 14H Motorgrader Operator
Seed MIX
Equipment Maintenance (Butler)
Total Revegetate Mill Yard & Ore Pad
Total Demolition and Decontamination
$72,695
$1,406,8711
CLEANUP OF WINDBLOWN CONTAMINATION
Scoping Survey
Resource Descnption Units Cost/Unit Task Units Task Cost
Soil Samples each $50 00 100 $5,000
Survey Crew hrs $14 46 752 $10,877
Sample Crew hrs $14 46 1,312 $18,977
Total Scoping Survey $34,854
Charactenzation Survey
Resource Descnption Units Cost/Unit Task Units Task Cost
Soil Samples each $50 00 472 $23,600
Sample Crew hrs $14 46 1,136 $16,431
Total Charactenzation Survey $40,031
Final Status Survey
Resource Descnption Units Cost/Unit Task Units Task Cost
Soil Samples each $50 00 300 $15,000
Sample Crew hrs $14 46 3,552 $51,377
Total Final Status Survey $66,377
12/17/2012 -11 07 AM-WMM Rec Plan Est December 2012 Rev 4 12 Denison Mines (USA) Corp
White Mesa Mill
MILL DECOMMISSIONING
Clancone Contaminated Soil Disposal
Resource Description
Cat 770 Haul Truck (3)
Truck Dnvers (3)
Cat 988 Loader
Cat 988 Loader Operator
Cat 651 Watenvagon
Cat 651 Watenvagon Operator
Cat 14H Motorgrader
Cat 14H Motorgrader Operator
Equipment Maintenance (Butler)
Units Cost/Unit Task Units Task Cost
hrs $97 66 20 $1,993
hrs $21 51 20 $439
hrs $137 94 7 $938
hrs $25 75 7 $175
hrs $115 79 7 $788
hrs $23 48 7 $160
hrs $73 28 15 $1,099
hrs $27 26 15 $409
hrs $19 10 49 $936
Total Clancone Contaminated Soil Disposal $6,937
Total Quantity 4.000 Cubic Yards* '
196 Cubic Yards per Truck per hour
20 Truck Hours
*Use 4 times estimated volume
Loose (in-truck) matenal unit weight assumed as 100 Ib/cubic foot
12/17/2012 -11 07 AM-WMM Rec Plan Est December 2012 Rev 4 12 Denison Mines (USA) Corp
White Mesa Mill
MILL DECOMMISSIONING
Alternate Feed Disposal
Cabot and FMRI Matenal
Resource Description Units Cost/Unit Task Units Task Cost
Cat 770 Haul Truck (3) hrs $97 66 33 $3,178
Truck Dnvers (3) hrs $21 51 33 $700
Cat 988 Loader hrs $137 94 11 $1,496
Cat 988 Loader Operator hrs $25 75 11 $279
Cat 651 Watenvagon hrs $115 79 11 $1,256
Cat 651 Watenvagon Operator hrs $23 48 11 $255
Cat 14H Motorgrader hrs $73 28 6 $440
Cat 14H Motorgrader Operator hrs $27 26 6 $164
Equipment Maintenance (Butler) hrs $19 10 60 $1,150
Total Cabot & FMRI Matenal $8,919
Total Quantity 6.379 Cubic Yards* (projected to 03/01/2013)
196 Cubic Yards per Truck per hour
33 Truck Hours
* Includes Cabot and FMRI
Cameco Barrels and Honeywell Barrels
Resource Descnption Units Cost/Unit Task Units Task Cost
Equipment Operators hrs $21 51 70 $1,510
Flat Bed Trailer and Tractor* hrs $55 00 70 $3,861
Fork Lift (2) hrs $18 00 140 $2,527
Equipment Maintenance (Butler) hrs $19 10 70 $1,341
Total Cameco and honeywell Barrels $9,240
* includes operator 7.020 Barrels (projected to 03/01/2013)
40 Barrels per load
0 4 Hours per load
70 Truck Hours
Tons lbs per barrel No Drums
CaF2 979 727 2,692
Calcined 435 320 2,719
Regen 31 406 153
KF 224 309 1,450
UF4 2 547 7
1.671 7,020
Sub-Total Alternate Feed Disposal
TOTAL MILL DECOMMISSIONING
1 $18.158]
I $2,139,4091
12/17/2012 -11 07 AM-WMM Rec Plan Est December 2012 Rev 4 12 Denison Mines (USA) Corp
White Mesa Mill
Clean
Page 1 of7
REVISED SUMMARY REPORT
PROPOSED EXCAVATION AT MILL DECOMISSIONING
TO REMOVE POTENTIALLY CONTAMINATED ADDITIONAL SOIL
Description of Previous Excavation
A sketch of the White Mesa Mill process area indicating the approximate location and boundanes of the April
2012 Claricone excavation are provided m Attachment 2A Contammated equipment, process matenal, and soil
was disposed in Cell 3
As described in the May 4, 2012 Notice and Plan, after removal of Clancone equipment, associated structures,
and the pumpable portion of the spilled solutions, the April 2012 Clancone excavation was conducted as follows
The extent of soil removal addressed both chemical and radiological contamination All soils visibly wet,
stained or discolored were excavated until uncontaminated dry background soils remained
The bottom and sides of the excavation were scanned by microR meter (measuring residual gamma
contamination) When the bottom or sides of the excavation mdicate gamma levels greater than background
levels, the excavation was resumed, additional contaminated soil was removed, and the bottom and sides of the
excavation were re-scanned until all surfaces result in gamma levels less than or equal to cleanup background
(Cleanup background was defined as two times the average of four measured background readings taken as
described m Attachment 3 This approach accounted for the contnbution to background of gamma radiation
from other nearby process equipment such as the clanfier, thickener, and CCD impounds ) When the bottom
and sides of the excavation indicated gamma levels of less than cleanup background as defined above, the
excavation was considered complete, and the area was prepared for backfill and re-grading
The May 4, 2012 Notice and Plan mdicated that the total estimated volume removed from the excavation was
1,134 cubic yards Based on final drawings and the volume of clean replacement soil used to backfill the
excavation, the total estimated volume of material actually removed was 4,600 cubic yards as indicated in the
figure in Attachment 2B The excavated volume of 4,600 cubic yards was subsequently replaced with clean
backfill
Conservative Basis for Larger Excavation Volume
The previously completed excavation attempted to locate and remove all contaminants discharged during the
Clancone spill by
1 Removal of all material visibly stained or wet Any soil apparently wet, containing visible spilled
material (crystals, precipitates, lumps), discolored, or having an otherwise non-typical appearance, was
excavated
2 Removal of radionuclides based on delmeation by gamma detection A gamma survey was considered
to be suitable because the spilled Clancone solutions contained appreciable concentrations of gamma-
emitting radionuclides
3 Assumption that chemical constituents would be removed by removal of detectable radionuclides The
Clancone contained saturated solutions undergoing solid/liquid separation for recovery of solid
constituents, and did not contain gaseous or volatile constituents that would not be detected by either
visual examination or radiological scanning Although the transport of chemical constituents in
environmental media may differ substantially from the transport of those constituents identifiable by
radiological scanning, it was assumed that chemical constituents would be captured because the very
Page 2 of7
short duration between the Clancone spill and the completion of the removal action (15 days total) would
not allow for any appreciable migration of chemical constituents
The areal footprint of the excavation was determined by assuming the entire area up to adjacent equipment in
every direction around the 29 V2 foot diameter Clancone would be removed As indicated in Attachment 2B, an
area approximately 56 feet in its narrowest dimension and 80 feet in its longest dunension was excavated
After removal of all the visibly contaminated soil, the depth of the excavation was determined by locating the
deepest depth below ground surface at which any radiological (gamma) detection exceeded the background
determined as described above The entire footprint was then excavated to that maximum depth The excavation
was completed to a depth of 25 feet below ground surface ("bgs") across the entire footprint
Nonetheless, during discussions with DRC in August 2012, DRC indicated concem that due to the lack of
confirmatory radiological sampling, the gamma survey method may not have bounded the entire extent of the
contamination Although EFRI believes that the contamination has been removed in its entirety, EFRI agreed to
assess an additional area and depth that could be excavated at the time of Mill decommissionmg, as an extra
measure of conservatism
Justification for Calculated Soil Volume
Although EFRI believes the contamination has been removed, EFRI has agreed to removal of an additional soil
volume as indicated in Attachment 2B EFRI proposes to excavate an additional two feet in every direction
(around the penmeter and below the bottom of the existing excavation) The excavation of additional two feet m
each direction will result in an estimated 1,000 cubic yards of potentially contaminated soil to be excavated
For the purposes of developing a conservative estimate of additional cost for the reclamation surety, EFRI has
quadrupled the excavation volume from 1,000 to 4,000 cubic yards for the cost calculations for the reasons
discussed herem
The proposed excavation will require the removal of the 4,600 cubic yards of clean backfill m order to reach the
additional two feet of potentially contaminated soil around the perimeter and bottom of the former excavation
The removed 4,600 cubic yards would theoretically be set aside for reuse in refilling the excavation, and would
not need to be placed in the tailings area
For conservatism, the cost estimate has assumed that up to 2,000 cubic yards of the 4,600 removed clean fill could
potentially be contaminated and would also be disposed m the tailings system rather than replaced in the
excavation as backfill
In order to address the possibility that workers may need to remove some additional contamination outside the
mtended two feet excavation perimeter as drawn m the figure in Attachment 2B, the volume estimate assumes an
additional 1,000 cubic yards may potentially be excavated outside the proposed perimeter Since the presence of
any theoretical contamination outside the perimeter has not been demonstrated, a precise location for the removal
ofthe additional 1,000 cubic yards has not been drawn on the figure
Therefore, the volume estunate of disposed contaminated soils has been tripled from 1,000 to 4,000 cubic yards
Surface Map and Cross Sections
As mentioned above, a surface map of the Mill indicating the area of the proposed additional Clancone
excavation is provided in Attachment 2A A detail of the proposed excavation area is provided in Attachment 2B
• Pa^e3of7
The removal resulted in an excavation with a flat floor at 25 feet bgs and vertical sidewalls throughout the "hole"
Based on information from well logs at the nearest wells (MW-27, TWN-2, and TW4-25), the top of the low
permeability Mancos shale in the vicinity of the excavation varies from less than 5 feet to approximately 9 or
more feet The top of the lower permeability Dakota sandstone varies from approximately 16 feet to over 27 feet
EFRI agrees to perform the additional excavation at the time of decommissioning consistent with the previously
completed excavation, that is, to excavate a vertical-walled flat bottomed excavation 2 feet wider in each
dimension than the completed and backfilled excavation Excavated soil would be disposed in the tailings cells
Surety Estimate
A revised surety estimate including line items for work associated with excavation, removal and disposal of the
additional volume of soil to be removed is provided in Attachment 3 As discussed above, for conservatism, the
revised surety estimate assumes triple the 1,000 cubic yard volume indicated m the drawings, that is it assumes a
3,000 cubic yard additional excavation
The assumption of an additional 3,000 cubic yard excavation resulted in an additional line item under the Mill
Decommissioning costs entitled "Claricone Contaminated Soil Disposal" of $6,937 This addition to the surety
estimate results in a revised total surety estimate of $20,309,858
Pag^4of7
ATTACHMENT lA
Location of Former Claricone Area
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Page 5 of7
ATTACHMENT IB
Mill Decommissioning
Planned Soil Removal m Claricone Area
ROBEF
NOTES
• 4,600 cuyds of soil was removed at the time of the
removal of the Claricone
• The excavation proposed at the time of mill decomission
totals 1,000 cuyds
• The proposed area includes a two foot extension to the
boundary of previously excavated soils
• The surface elevation is taken as 5625 5 ft above msl as
referenced from mill survey monument MILL 101
SIONS
1 iSS
By
Project Clancone Excavation Project
County San Juan County | State Utah
Location White Mesa Mill
Mill Decommissioning
Planned Soils Removal
in Clancone Area
SS 10/4/12 Drafted By gg
Page 6 of7
ATTACHMENT IC
Cross Sectional Dimensions of Clancone Excavation
ATTACHMENT IC
CROSS SECTIONAL DIMENSIONS OF CLARICONE EXCAVATION
The Apnl 2012 excavation of contaminated and additional soil associated with the Claricone spill
consisted of an excavation footpnnt as shown in the plan drawing in Attachment IB, with
• Excavation to a flat bottom depth of 25 feet below ground surface ("bgs ") ali the way across the
blue hatched area of excavation, and
• Approximately vertical side walls around the entire penmeter as mdicated by the blue hatched
area in Attachment IB
The proposed excavation of potentially-contaminated additional soil at Mill decommissioning would
consist of
• Excavation to a flat bottom depth of an additional 2 feet, that is 27 feet bgs, all the way across
the area of excavation, and
• A perimeter of an additional 2-foot width as indicated by the red hatched area in Attachment
IB, with approximately vertical side wails
• Potential excavation of an additional 1,000 cubic yards of soil contamination theoretically
outside the proposed 2-foot width The location ofthis volume has not been depicted in
Attachment IB
Page 7 of 7
ATTACHMENT 2
Reclamation Cost Estimate Revision 4 12
WHITE MESA MILL RECLAMATION COST ESTIMATE
December 2012
Revision 4.12
Mobilization $437,800
Office Facilities $58,500
Mill Decommissioning $2,139,409
CelM $1,776,448
Cell 2 $1,803,668
Cells $2,057,848
Cell 4A $1,435,844
Cell 4B $1,465,011
Management Support $2,297,613
Miscellaneous $869,063
Subtotal Direct Costs $14,341,205
Profit Allowance 10 00% $1,434,120
Contingency 15 00% $2,151,181
Licensing & Bonding 2 00% $286,824
UDEQ Contract Administration 4 00% $573,648
Engineenng Design Review 2 25% $322,677
Contractors Equipment Floater $82,250
Automobile and General Liability Insurance $284,600
Long Term Care Fund $833,353
Total Reclamation $20,309,858
Revised Bond Amount $20,309,858
12/17/2012 -11 07 AM - WMM Rec Plan Est December 2012 Rev 4 12
Denison Mines (USA) Corp
White Mesa Mill
MILL DECOMMISSIONING
MILL DECOMMISSIONING
Mill Building Demolition
Resource Descnption
Mechanics
Laborers
Small Tools
Cat 770 Haul Truck
Truck Dnvers
Cat 988 Loader
Cat 988 Loader Operator
Cat 365 Excavator
Cat 365 Excavator Operator
PC 300 w/metal Shears
PC 300 Operator
60 Ton Crane
60 Ton Crane Operator
30 Ton Crane
30 Ton Crane Operator
Equipment Maintenance (Butler)
Concrete Removal
Total Mill Building Demolition
Ore Feed Demolition
Resource Descnption
Mechanics
Laborers
Small Tools
Cat 770 Haul Truck
Truck Dnvers
Cat 988 Loader
Cat 988 Loader Operator
Cat 365 Excavator
Cat 365 Excavator Operator
PC 300 w/metal Shears
PC 300 Operator
30 Ton Crane
30 Ton Crane Operator
Equipment Maintenance (Butler)
Total Ore Feed Demolition
SX Building Demolition
Resource Description
Units Cost/Unit Task Units Task Cost
hrs $15 03 640 $9,618
hrs $15 25 320 $4,879
hrs $1 35 960 $1,296
hrs $97 66 640 $62,501
hrs $21 51 640 $13,768
hrs $137 94 160 $22,071
hrs $25 75 160 $4,120
hrs $133 91 160 $21,425
hrs $27 26 160 $4,362
hrs $154 00 160 $24,639
hrs $27 26 160 $4,362
hrs $97 93 160 $15,668
hrs $28 41 160 $4,545
hrs $62 40 80 $4,992
hrs $28 41 80 $2,273
hrs $19 10 1.360 $25,974
sf $3 30 37.500 $123,750
Units Cost/Unit Task Units
$350,244
Task Cost
hrs $15 03 64 $962
hrs $15 25 32 $488
hrs $1 35 96 $130
hrs $97 66 64 $6,250
hrs $21 51 64 $1,377
hrs $137 94 16 $2,207
hrs $1721 16 $275
hrs $133 91 16 $2,143
hrs $20 65 16 $330
hrs $154 00 16 $2,464
hrs $20 65 16 $330
hrs $62 40 0 $0
hrs $28 41 0 $0
hrs $19 10 112 $2,139
Units Cost/Unit Task Units
$19,095
Task Cost
Mechanics
Laborers
Small Tools
Cat 770 Haul Truck
Truck Dnvers
Cat 988 Loader
Cat 988 Loader Operator
Cat 365 Excavator
Cat 365 Excavator Operator
PC 300 w/metal Shears
PC 300 Operator
60 Ton Crane
60 Ton Crane Operator
30 Ton Crane
30 Ton Crane Operator
Equipment Maintenance (Butler)
Concrete Removal
Total SX Building Demolition
12/17/2012 -11 07 AM-WMM Rec Plan Est December 2012 Rev 4 12
hrs $15 03 320 $4,809
hrs $15 25 160 $2,439
hrs $1 35 480 $648
hrs $97 66 320 $31,251
hrs $21 51 320 $6,884
hrs $137 94 80 $11,035
hrs $25 75 80 $2,060
hrs $133 91 80 $10,713
hrs $27 26 80 $2,181
hrs $154 00 80 $12,320
hrs $27 26 80 $2,181
hrs $97 93 0 $0
hrs $28 41 0 $0
hrs $62 40 0 $0
hrs $28 41 0 $0
hrs $1910 560 $10,695
sf $3 30 55,970 $184,701
$281,917
Denison Mines (USA) Corp
White Mesa Mill
MILL DECOMMISSIONING
CCD Circuit Removal
Resource Descnption Units Cost/Unit Task Units Task Cost
hrs $15 03 120 $1,803
hrs $15 25 60 $915
hrs $1 35 180 $243
hrs $97 66 120 $11,719
hrs $21 51 120 $2,582
hrs $137 94 30 $4,138
hrs $17 21 30 $516
hrs $133 91 30 $4,017
hrs $20 65 30 $620
hrs $154 00 30 $4,620
hrs $20 65 30 $620
hrs $97 93 30 $2,938
hrs $15 76 30 $473
hrs $62 40 15 $936
hrs $15 76 15 $236
hrs $1910 255 $4,870
sf $3 30 15,000 $49,500
Mechanics
Laborers
Small Tools
Cat 770 Haul Truck
Truck Dnvers
Cat 988 Loader
Cat 988 Loader Operator
Cat 365 Excavator
Cat 365 Excavator Operator
PC 300 w/metal Shears
PC 300 Operator
60 Ton Crane
60 Ton Crane Operator
30 Ton Crane
30 Ton Crane Operator
Equipment Maintenance (Butler)
Concrete Removal
Total CCD Circuit Removal
Sample Plant Removal
Resource Description Units Cost/Unit Task Units
$90,746
Task Cost
Mechanics
Laborers
Small Tools
Cat 770 Haul Truck
Truck Drivers
Cat 988 Loader
Cat 988 Loader Operator
Cat 365 Excavator
Cat 365 Excavator Operator
PC 300 w/metal Shears
PC 300 Operator
30 Ton Crane
30 Ton Crane Operator
Equipment Maintenance (Butler)
Concrete Removal
Total Sample Plant Removal
Temporary Storage Building Removal
Resource Descnption
hrs $15 03 32 $481
hrs $15 25 16 $244
hrs $1 35 48 $65
hrs $97 66 32 $3,125
hrs $21 51 32 $688
hrs $137 94 8 $1,104
hrs $17 21 8 $138
hrs $133 91 8 $1,071
hrs $20 65 8 $165
hrs $154 00 8 $1,232
hrs $20 65 8 $165
hrs $62 40 0 $0
hrs $28 41 0 $0
hrs $19 10 56 $1,070
sf $3 30 4,200 $13,860
Units Cost/Unit Task Units
$23,408
Task Cost
Laborers
Small Tools
Cat 770 Haul Truck
Truck Dnvers
Cat 988 Loader
Cat 988 Loader Operator
Equipment Maintenance (Butler)
Concrete Removal
Total Temporary Storage Building Removal
hrs $15 25 8 $122
hrs $1 35 8 $11
hrs $97 66 2 $195
hrs $21 51 2 $43
hrs $137 94 2 $276
hrs $25 75 2 $52
hrs $19 10 4 $76
sf $3 30 600 $1,980
$2,755
12/17/2012 -11 07 AM-WMM Rec Plan Est December 2012 Rev 4 12
Denison Mines (USA) Corp
White Mesa Mill
MILL DECOMMISSIONING
Truck Shop Removal
Resource Description Units Cost/Unit Task Units Task Cost
hrs $15 03 32 $481
hrs $15 25 16 $244
hrs $1 35 48 $65
hrs $97 66 24 $2,344
hrs $21 51 24 $516
hrs $137 94 8 $1,104
hrs $17 21 8 $138
hrs $133 91 8 $1,071
hrs $20 65 8 $165
hrs $154 00 8 $1,232
hrs $20 65 8 $165
hrs $62 40 0 $0
hrs $28 41 0 $0
hrs $1910 48 $917
sf $3 30 4,200 $13,860
Mechanics
Laborers
Small Tools
Cat 770 Haul Truck
Truck Dnvers
Cat 988 Loader
Cat 988 Loader Operator
Cat 365 Excavator
Cat 365 Excavator Operator
PC 300 w/metal Shears
PC 300 Operator
30 Ton Crane
30 Ton Crane Operator
Equipment Maintenance (Butler)
Concrete Removal
Total Truck Shop Removal
Boiler Demolition
Resource Descnption Units Cost/Unit Task Units
$22,301
Task Cost
hrs $15 03 160 $2,405
hrs $15 25 80 $1.220
hrs $1 35 240 $324
hrs $97 66 160 $15,625
hrs $21 51 160 $3,442
hrs $137 94 40 $5,518
hrs $17 21 40 $689
hrs $133 91 40 $5,356
hrs $20 65 40 $826
hrs $154 00 40 $6,160
hrs $20 65 40 $826
hrs $97 93 0 $0
hrs $15 76 0 $0
hrs $62 40 0 $0
hrs $15 76 0 $0
hrs $19 10 280 $5,348
sf $3 30 2.900 $9,570
Mechanics
Laborers
Small Tools
Cat 770 Haul Truck
Truck Dnvers
Cat 988 Loader
Cat 988 Loader Operator
Cat 365 Excavator
Cat 365 Excavator Operator
PC 300 w/metal Shears
PC 300 Operator
60 Ton Crane
60 Ton Crane Operator
30 Ton Crane
30 Ton Crane Operator
Equipment Maintenance (Butler)
Concrete Removal
Total Boiler Demolition $57,308
Vanadium Oxidation Circuit Removal
Resource Descnption Units Cost/Unit Task Units Task Cost
Mechanics
Laborers
Small Tools
Cat 770 Haul Truck
Truck Dnvers
Cat 988 Loader
Cat 988 Loader Operator
Cat 365 Excavator
Cat 365 Excavator Operator
PC 300 w/metal Shears
PC 300 Operator
60 Ton Crane
60 Ton Crane Operator
30 Ton Crane
30 Ton Crane Operator
Equipment Maintenance (Butler)
Concrete Removal
Total Vanadium Oxidation Circuit Removal
12/17/2012 -11 07 AM-WMM Rec Plan Est December 2012 Rev 4 12
hrs $15 03 . 64 $962
hrs $15 25 32 $488
hrs $1 35 96 $130
hrs $97 66 64 $6,250
hrs $21 51 64 $1,377
hrs $137 94 16 $2,207
hrs $17 21 16 $275
hrs $133 91 16 $2,143
hrs $20 65 16 $330
hrs $154 00 16 $2,464
hrs $20 65 16 $330
hrs $97 93 0 $0
hrs $15 76 0 $0
hrs $62 40 0 $0
hrs $15 76 0 $0
hrs $19 10 112 $2,139
sf $3 30 1,200 $3,960
$23,055
Denison Mines (USA) Corp
White Mesa Mill
v»inio ivi«ba ivmi
MILL DECOMMISSIONING
Mill Yard Decontamination
Resource Descnption Units Cost/Unit Task Units Task Cost
Cat 637 Scraper
Cat 637 Scraper Operator
Cat 988 Loader
Cat 988 Loader Operator
Cat D8N Dozer With Ripper
Cat D8N Dozer Operator
Cat D7 Dozer
Cat D7 Dozer Operator
Cat 651 Watenvagon
Cat 651 Watenvagon Operator
Cat 14H Motorgrader
Cat 14H Motorgrader Operator
Equipment Maintenance (Butler)
Total Mill Yard Decontamination"
Ore Storage Pad Decontamination
Resource Descnption
hrs $215 65 274 $59,087
hrs $27 26 274 $7,470
hrs $137 94 68 $9,380
hrs $25 75 68 $1,751
hrs $98 69 68 $6,711
hrs $25 75 68 $1,751
hrs $83 49 68 $5,677
hrs $25 75 68 $1,751
hrs $115 79 68 $7,874
hrs $23 48 68 $1,597
hrs $73 28 68 $4,983
hrs $27 26 68 $1,854
hrs $19 10 614 $11,727
$121,613
Includes Ammonimum Sulfate Storage Tank contamination
Units Cost/Unit Task Units Task Cost
hrs $215 65 189 $40,757
hrs $19 31 189 $3,649
hrs $137 94 48 $6,621
hrs $1721 48 $826
hrs $98 69 48 $4,737
hrs $20 65 48 $991
hrs $83 49 48 $4,008
hrs $20 65 48 $991
hrs $115 79 48 $5,558
hrs $1816 48 $872
hrs $73 28 48 $3,517
hrs $20 62 48 $990
hrs $19 10 429 $8,193
Cat 637 Scraper
Cat 637 Scraper Operator
Cat 988 Loader
Cat 988 Loader Operator
Cat D8N Dozer With Ripper
Cat D8N Dozer Operator
Cat D7 Dozer
Cat D7 Dozer Operator
Cat 651 Watenvagon
Cat 651 Waterwagon Operator
Cat 14H Motorgrader
Cat 14H Motorgrader Operator
Equipment Maintenance (Butler)
Total Ore Storage Pad Decontamination $81,712
Equipment Storage Area Cleanup
Resource Description Units Cost/Unit Task Units Task Cost
Cat 637 Scraper
Cat 637 Scraper Operator
Cat 988 Loader
Cat 988 Loader Operator
Cat D8N Dozer With Ripper
Cat D8N Dozer Operator
Cat D7 Dozer
Cat D7 Dozer Operator
Cat 651 Waterwagon
Cat 651 Watenvagon Operator
Cat 14H Motorgrader
Cat 14H Motorgrader Operator
Equipment Maintenance (Butler)
Total Equipment Storage Area Cleanup
hrs $215 65 68 $14,664
hrs $19 31 68 $1,313
hrs $137 94 17 $2,345
hrs $17 21 17 $293
hrs $98 69 17 $1,678
hrs $20 65 17 $351
hrs $83 49 17 $1,419
hrs $20 65 17 $351
hrs $115 79 17 $1,968
hrs $18 16 17 $309
hrs $73 28 17 $1,246
hrs $20 62 17 $351
hrs $1910 153 $2,922
$29,210
12/17/2012 - 11 07 AM-WMM Rec Plan Est December 2012 Rev 4 12
Denison Mines (USA) Corp
White Mesa Mill
» N *
MILL DECOMMISSIONING
Revegetate Mill Yard & Ore Pad
Resource Descnption Units Cost/Unit Task Units Task Cost
hrs $215 65 174 $37,523
hrs $19 31 174 $3,360
hrs $137 94 0 $0
hrs $17 21 0 $0
hrs $98 69 33 $3,257
hrs $20 65 33 $682
hrs $83 49 33 $2,755
hrs $20 65 33 $682
hrs $115 79 0 $0
hrs $18 16 0 $0
hrs $73 28 33 $2,418
hrs $20 62 33 $681
Acre $322 50 50 $16,125
hrs $19 10 273 $5,214
Cat 637 Scraper
Cat 637 Scraper Operator
Cat 988 Loader
Cat 988 Loader Operator
Cat D8N Dozer With Ripper
Cat D8N Dozer Operator
Cat D7 Dozer
Cat D7 Dozer Operator
Cat 651 Watenvagon
Cat 651 Watenvagon Operator
Cat 14H Motorgrader
Cat 14H Motorgrader Operator
Seed MIX
Equipment Maintenance (Butler)
Total Revegetate Mill Yard & Ore Pad $72,695
Total Demolition and Decontamination I $1,406,871]
CLEANUP OF WINDBLOWN CONTAMINATION
Scoping Survey
Resource Descnption Units Cost/Unit Task Units Task Cost
Soil Samples each $50 00 100 $5,000
Survey Crew hrs $14 46 752 $10,877
Sample Crew hrs $14 46 1.312 $18,977
Total Scoping Survey $34,854
Charactenzation Survey
Resource Descnption Units Cost/Unit Task Units Task Cost
Soil Samples each $50 00 472 $23,600
Sample Crew hrs $14 46 1,136 $16,431
Total Characterization Survey $40,031
Final Status Survey
Resource Descnption Units Cost/Unit Task Units Task Cost
Soil Samples each $50 00 300 $15,000
Sample Crew hrs $14 46 3,552 $51,377
Total Final Status Survey $66,377
12/17/2012 -11 07 AM-WMM Rec Plan Est December 2012 Rev 4 12
Denison Mines (USA) Corp
White Mesa Mill
MILL DECOMMISSIONING
Windblown Cleanup
Resource Descnption Units Cost/Unit Task Units Task Cost
Cat 637 Scraper
Cat 637 Scraper Operator
Cat D8N Dozer With Ripper
Cat D8N Dozer Operator
Cat D7 Dozer
Cat D7 Dozer Operator
Cat 14H Motorgrader
Cat 14H Motorgrader Operator
Soil Samples
Survey Crew
Sample Crew
Equipment Maintenance (Butler)
Total Windblown Cleanup
Quality Control
Resource Descnption
hrs $215 65 680 $146,640
hrs $27 26 680 $18,538
hrs $98 69 170 $16,777
hrs $25 75 170 $4,378
hrs $83 49 170 $14,194
hrs $25 75 170 $4,378
hrs $73 28 170 $12,457
hrs $27 26 170 $4,634
each $50 00 500 $25,000
hrs $14 46 163 $2,358
hrs $14 46 83 $1,201
hrs $19 10 1,190 $22,728
Units Ck)st/Unit Task Units
$273,282
Task Cost
Quality Control Contractor
Total Quality Control
Total Cleanup Windblown Contamination
hrs $62 00 2.080 $128,960
$128,960
$543,503
Conventional Ore Disposal
Resource Descnption Units Cost/Unit Task Units Task Cost
Cat 770 Haul Truck (3)
Truck Dnvers (3)
Cat 988 Loader
Cat 988 Loader Operator
Cat 651 Watenvagon
Cat 651 Watenvagon Operator
Cat 14H Motorgrader
Cat 14H Motorgrader Operator
Equipment Maintenance (Butler)
Total Conventional Ore Disposal
Total Quantity
hrs $97 66 639 $62,374
hrs $21 51 639 $13,740
hrs $137 94 213 $29,368
hrs $25 75 213 $5,482
hrs $115 79 213 $24,653
hrs $23 48 213 $5,000
hrs $73 28 25 $1,832
hrs $27 26 25 $682
hrs $19 10 1,089 $20,808
125.185 Cubic Yards*
196 Cubic Yards per Truck per hour
639 Truck Hours
$163,939
* 169.000 tons maximum projected thru 2012 to March 2013
Loose (in-truck) matenal unit weight assumed as 100 Ib/cubic foot
12/17/2012 -11 07 AM-WMM Rec Plan Est December 2012 Rev 4 12
Denison Mines (USA) Corp
White Mesa Mill
MILL DECOMMISSIONING
Claricone Contaminated Soil Disposal
Resource Descnption Units Cost/Unit Task Units Task Cost
Cat 770 Haul Truck (3)
Truck Dnvers (3)
Cat 988 Loader
Cat 988 Loader Operator
Cat 651 Watenvagon
Cat 651 Watenvagon Operator
Cat 14H Motorgrader
Cat 14H Motorgrader Operator
Equipment Maintenance (Butler)
hrs $97 66 20 $1.993
hrs $21 51 20 $439
hrs $137 94 7 $938
hrs $25 75 7 $175
hrs $11579 7 $788
hrs $23 48 7 $160
hrs $73 28 15 $1,099
hrs $27 26 15 $409
hrs $19 10 49 $936
Total Clancone Contaminated Soil Disposal
Total Quantity 4,000 Cubic Yards*
196 Cubic Yards per Truck per hour
20 Truck Hours
$6,937
*Use 4 times estmated volume
Loose (in-truck) matenal unit weight assumed as 100 Ib/cubic foot
12/17/2012 -11 07 AM-WMM Rec Plan Est December 2012 Rev 4 12
Denison Mines (USA) Corp
White Mesa Mill
MILL DECOMMISSIONING
Alternate Feed Disposal
Cabot and FMRI Material
Resource Descnption Units Cost/Unit Task Units Task Cost
Cat 770 Haul Truck (3)
Truck Dnvers (3)
Cat 988 Loader
Cat 988 Loader Operator
Cat 651 Watenvagon
Cat 651 Watenvagon Operator
Cat 14H Motorgrader
Cat 14H Motorgrader Operator
Equipment Maintenance (Butler)
Total Cabot & FMRI Matenal
hrs $97 66 33 $3,178
hrs $21 51 33 $700
hrs $137 94 11 $1,496
hrs $25 75 11 $279
hrs $115 79 11 $1,256
hrs $23 48 11 $255
hrs $73 28 6 $440
hrs $27 26 6 $164
hrs $19 10 60 $1,150
$8,919
Total Quantity 6.379 Cubic Yards* (projected to 03/01/2013)
196 Cubic Yards per Truck per hour
33 Truck Hours
Cameco Barrels and Honeywell Barrels
Includes Cabot and FMRI
Resource Descnption Units Cost/Unit Task Units Task Cost
Equipment Operators hrs $21 51 70 $1,510
Flat Bed Trailer and Tractor* hrs $55 00 70 $3,861
Fork Lift (2) hrs $18 00 140 $2,527
Equipment Maintenance (Butler) hrs $19 10 70 $1,341
Total Cameco and honeywell Barrels
* includes operator
$9,240
7.020 Barrels
40 Barrels per load
0 4 Hours per load
70 Truck Hours
(projected to 03/01/2013)
Tons lbs per barrel No Drums
Sub-Total Alternate Feed Disposal
CaF2 979 727 2.692
Calcined 435 320 2,719
Regen 31 406 153
KF 224 309 1.450
UF4 2 547 7
1.671 7.020
TOTAL MILL DECOMMISSIONING I $2,139,409]
12/17/2012 -11 07 AM-WMM Rec Plan Est December 2012 Rev 4 12 Denison Mines (USA) Corp
White Mesa Mill