DRC-2013-003475 - 0901a068803d4c8c

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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-2013-003475"
MEMORANDUM
TO:
THROUGH:
FROM:
DATE:
SUBJECT:
File C-2013-59
Phil Goble, Section Manager
Russell J. Topham, PE.
October 16,2013
Engineering Module 70, Annual Surety Review, Energy Fuels Resources (EFRI), White
Mesa Mill, Blanding, Utah.
On March 5, 2013 the Utah Division of Radiation Control (DRC) received the 2013 surety update for the
White Mesa Mill. The DRC sent a request for information (RFI) on April 3, 2013 and an extension of the
deadline for responding to the RFI on May 8, 2013. The DRC received EFRI's response to the RFI, which
bears the date of June 19,2013, on June 20, 2013. The RFI contained two items that the DRC asked EFRI
to address. Comments regarding EFRI's response follow.
1.0 Summary Findings and Recommendations
Recommendation: The DRC should accept the Gantt chart and the resulting adjustments to the cost
estimate as sufficient for this round of review.
Recommendation: The DRC should apply the revised project time line and sequencing of events to a DRC
oversight forecasting model (yet to be developed) to ascertain the sufficiency of the funding provided in the
surety for that task. This information should be used during the review of the 2014 surety.
Recommendation: The DRC should defer capturing well abandonment to the 2014 round of surety reviews.
In the interim, the DRC should craft a policy for valuing well abandonment in the surety.
Recommendation: In light of the above recommendations, the DRC should approve the 2013 surety update
at the proposed value of $21,126,149.
2.0 Evaluation of project timeline
The DRC requested that EFRI produce a Gantt chart, or other graphical means, to depict a logical
sequencing of decommissioning activities. The stated purposes were to evaluate the project time line and to
evaluate resource needs. EFRI produced the requested Gantt chart, and made several appropriate
adjustments to the cost estimate as a result.
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Page 2
• Mobile office rental was extended from 3 to 33 months, resulting in an increase of $45,000.
• Equipment selection for decommissioning was refined, resulting in a reduction of $12,500.
• Efficiencies in Cell 1 reclamation from better deployment of equipment led to a reduction of
$14,539.
• Reclamation of Cell 3 was scheduled during a time when a water truck was previously inactive,
resulting in the elimination of a second water truck originally destined for that work. The resulting
savings totaled $8,463.
• Cell 4A and Cell 4B reclamation activities were seen to require additional operator hours, resulting
in an increase of $1,926 each.
• After summing the above figures and applying indirect cost multipliers, the resulting increase in
surety from the initial 2013 submittal was $18,455.
Finding: The Gantt Chart exercise resulted in a better estimate of the work involved in decommissioning,
and provides the DRC with a better estimate of the project time line.
Recommendation: The DRC should accept the Gantt chart and the resulting adjustments to the cost
estimate as sufficient for this round of review.
Recommendation: The DRC should apply the revised project time line and sequencing of events to a DRC
oversight forecasting model (yet to be developed) to ascertain the sufficiency of the funding provided in the
surety for that task. This information should be used during the review of the 2014 surety.
3.0 Well Abandonment
The DRC requested inclusion of funding to abandon monitoring wells following decommissioning. EFRI
noted that post-closure monitoring would require a network of wells, and that the decision of which wells
to keep or which to abandon would not occur until closure of the facility.
Therefore, EFRI did not include funding for well abandonment.
Finding: Well abandonment still poses a financial risk to the DRC. However, that risk is small The DRC
can benefit from internal discussion about the process that might be used to select wells to remain,
considering all licensees' existing well networks, and, from that discussion, formulate a policy regarding
abandonment funding for surety.
Recommendation: The DRC should defer capturing well abandonment to the 2014 round of surety reviews.
In the interim, the DRC should craft a policy for valuing well abandonment in the surety.