DRC-2013-001951 - 0901a068803670c2

Department of
Environmental Quality
Amanda Smith
Executive Director
DIVISION OF RADIATION CONTROL
Rusty Lundberg
Director
State of Utah
GARY R HERBERT
Governor
GREG BELL
Lieutenant Governor
April 3, 2013
CERTIFIED IVIAIL
RETURN RECEIPT REQUESTED
Ms. Jo Ann Tischler
Manager, Compliance and Licensing
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, 80228
m m
DP
m
IT m cr
a CD a
o to
J]
xr
• a
U.S. Postal Service™
CERTIFIED MAIL™ RECEIPT
(Domestic Mail Only; No Insurance Coverage Provided)
For delivery information visit our website at www.usps.com©
Certified Fee
Return Receipt Fee (Endorsement Required)
Restricted Delivery Fee (Endorsement Required)
Total Posta od
Senf To
or PO Box No.
owe'
City, state. ZIP+4
PS Form 3800. AucjiTSt 2006 See Reverse for Insti actions
Subject: Compliance - License Condition 9.5, Surety Update; Radioactive Materials License
UTl900479; White Mesa Mill: Request for Information
Dear Ms. Tischler: DRC-2013-001951
On March 5, 2013 the Utah Division of Radiation Control (DRC) received the captioned Surety Update,
which responds to Revision 3.2B of the Reclamation Plan for the White Mesa Mill that was approved by
the DRC on January 26, 2011. The Surety Update documents appear faithfully to reflect agreements
reached during review ofthe 2012 Surety Update. Thank you.
Upon review of the Surety Update, DRC Staff requests the following information:
1. The Reclamation Plan and Surety Estimate appear to present a comprehensive analysis of the work
required to decommission and close the facility. Review of this information led to several
schedule-related questions, on such topics as the 3-year coverage for utilities during
decommissioning, the 6-month rental period for mobile office facilities, and the provisions for
management and contract oversight.
To assist in answering these questions, please present the work breakdown stmcture in a graphical
format, such as a Gantt chart. This will assist the DRC to identify the relationships between tasks,
to evaluate resource conflicts, to estimate more accurately the project duration and the critical path,
and to analyze DRC staff resource needs during closure. In process of assembling the chart, EFR
can either substantiate or adjust the utility and office rental line items,
2. During decommissioning and closure of the facility, any monitoring wells not needed for the long
term must be abandoned. Please include a line item for abandonment of the monitoring wells.
Abandonment typically includes filling the casing with neat cement grout, concrete, or bentonite
slurry. If the wells have been logged with the Department of Natural Resources, provision for
preparing and filing appropriate forms should also be included. Inasmuch as insufficient
195 North 1950 West • Salt Uke City, UT
Mailing Address P O Box 144850 • Salt Lake City, UT 84114-4850
Telephone [phone] • Fax [phone] 'TDD [phone]
www deq Utah gov
Pnnted on 100% recycled paper
Jo Ann Tischler
April 3, 2013
Page 2
information exists at this time to determine which wells to keep, please include all monitoring
wells m the abandonment plan.
Please respond in writing within 30 calendar days of receipt of this letter with the requested information.
YOU may direct any questions you may have to Russ Topham at 801.536.4256.
Thank you for your continued cooperation.
Sincerely,
Rusty Lundberg
Director
RL/IUT:rjt
SENDER: COMPLETE THIS SECTION
• Complete items 1, 2. and 3. Also complete
item 4 if Restricted Delivery is desired.
• Print your name and address on the reverse
so that we can return the card to you.
• Attach this card to the bacl< of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
RFI UT1900479 RT
Ms. Jo Ann Tischler
Director, Compliance and Permitting
Energy Fuels Resources (USA) Inc.
225 Union Blvd., Suite 600
Lakewood, CO 80228
COMPLETL THIS SECTION ON DELIVERY
3. Service
^Certffii
• Regr
• Insured Mall
4. Restricted Delivery? (Extra Fi9e;
Merchandise
• Yes
2. Article Number
(Transfer from service label) 70m IbflD DODl =lB=il 3*^3E
PS Fonri 3811, February 2004 Domestic Return Receipt 102595-02-M-1540