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HomeMy WebLinkAboutDRC-2016-001246 - 0901a068805eb1fcENERGYFUELS Energy Fuels Resources (USA) Inc. 225 Union Blvd. Suite 600 Lakewood, CO, US, 80228 303 974 2140 www.energvfuels.com January 11, 2016 Div of Waste Management and Radiation Control Sent VIA E-MAIL AND OVERNIGHT DELIVERY JAN 1 2 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 Chloroform Plume Reclamation Plan and Cost Estimate UDEQ Docket No. UGW20-01 White Mesa Uranium Mill Dear Mr. Anderson: Part 8 of the September 14, 2015 Stipulation and Consent Order ("SCO") UDEQ Docket No. UGW-20-01 between Energy Fuels Resources (USA) Inc. ("EFRI") and the Division of Waste Management and Radiation Control ("DWMRC") specified that on or before 120 days after the date of the order, EFRI shall submit a Chloroform Plume Reclamation Plan and Cost Estimate ("CPRP-CE") for Director approval. Enclosed are two copies of the CPRP-CE for review as required by the SCO. 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 S hum way Scott Bakken White Mesa Uranium Mill Chloroform Plume Reclamation Plan and Cost Estimate State of Utah Stipulation and Consent Order Docket No. UGW20-01 Prepared by: ENERGY FUELS Energy Fuels Resources (USA) Inc. 225 Union Boulevard, Suite 600 Lakewood, CO 80228 January 11,2016 TABLE OF CONTENTS 1.0 INTRODUCTION 1 2.0 PUMPING SYSTEM OPERATION 2 2.1 Corrimencement of Pumping 2 2.2 Pumping Data Collection 2 2.3 Water Level Measurements 3 2.4 Pumping Rates and Volumes 3 3.0 PUMPING SYSTEM MAINTENANCE 3 3.1 Winterization for Long-Term Operations 3 3.2 Maintenance Activities 4 4.0 CHLOROFORM MONITORING AND REPORTING 4 4.1 Chloroform Monitoring 4 4.2 Chloroform Reporting 5 5.0 PUMPING SYSTEM MODIFICATIONS 5 6.0 DECOMMISSIONING OF THE PUMPING SYSTEM 6 7.0 CERTIFICATION 7 LIST OF ATTACHMENTS Attachment A - White Mesa Mill Chloroform Project Reclamation Plan Cost Estimate LIST OF FIGURES Figure A-l Site Plan and Perched Well Locations White Mesa Site i 1.0 INTRODUCTION The presence of chloroform was initially identified in groundwater at the White Mesa Mill (the "Mill") as a result of split sampling performed in May 1999. The discovery resulted in the issuance of State of Utah Notice of Violation ("NOV") and Groundwater Corrective Action Order ("CAO") State of Utah Department of Environmental Quality ("UDEQ"), Division of Waste Management and Radiation Control ("DWMRC") Docket No. UGW20-01, which required that Energy Fuels Resources (USA) Inc. ("EFRI") submit a Contamination Investigation Plan and Report pursuant to the provisions of UAC R317-6-6.15(D). In response to the NOV, EFRI submitted a series of documents outlining plans for investigation of the chloroform contamination. This plan of action and preliminary schedule was set out in EFRI submittals dated: September 20, 1999; June 30, 2000; April 14, 2005; and November 29, 2006. EFRI submitted a draft Groundwater Corrective Action Plan ("GCAP") dated August 22, 2007. The draft GCAP was reviewed by the Director, who advised EFRI in 2013 that modifications were required. In an effort to expedite and formalize active and continued remediation of the chloroform plume, both parties have agreed to the GCAP found in Attachment 1, of the final Stipulation and Consent Order ("SCO") dated September 14, 2015. Part 8 of the September 14, 2015 SCO specified that: On or before 120 days after the date of the order, EFRI shall submit a Chloroform Plume Reclamation Plan and Cost Estimate ("CPRP-CE") for Director approval that will include: A. Specific details on how the Chloroform Plume remediation system will be: 1) Operated, maintained (including monitoring and reporting), modified (if needed) for at least a 6 year period, and 2) Decommissioned at the time of facility closure which will include, but is not limited to: well plugging and abandonment, and removal of pipelines from the pumping wells to tailing cells or the Mill process, and B. A cost estimate of all activities described above. Said cost estimate shall be prepared by or under the direction of a Utah Licensed Professional Engineer. This is the CPRP-CE required by the Part 8 of the SCO. This CPRP-CE incorporates by reference documents previously approved by DWMRC, including but not limited to: • White Mesa Mill, Operations and Maintenance Plan, Chloroform Pumping System, (the "Chloroform O&M Plan") Revision 2.2, dated March 21, 2013. (Approved April 8, 2013) • White Mesa Mill, Operations and Maintenance Plan, Chloroform Pumping System, Revision 2.2, Errata sheets for updated field forms, dated June 9, 2015. (approved June 12,2015) • Chloroform Investigation Monitoring Quality Assurance Program (the "Chloroform QAP") attached as Appendix A to the White Mesa Uranium Mill Groundwater Monitoring QAP Revision 7.2, dated June 6, 2012. (Approved June 7, 2012). • Stipulation and Consent Order between Energy Fuels Resources (USA) Inc. and the Director of DWMRC, Docket no. UGW20-01, duly executed September 14, 2015. 1 • GCAP, for the EFRI Chloroform Plume at the White Mesa Mill Uranium Recovery Facility, included as Attachment 1 to the duly executed SCO. 2.0 PUMPING SYSTEM OPERATION Pursuant to Part 8 of the September 14, 2015 SCO, EFRI is required to submit this CPRP-CE which includes the details of how the remediation system will be operated. Specific details regarding the operation, maintenance, and system components are included in the Chloroform O&M Plan Revision 2.2, dated March 21, 2013 (Approved April 8, 2013). Additional details regarding the system operation are summarized below. Details regarding the costs to operate the remediation pumping system for a six year period are included in Attachment A to this CPRP-CE. 2.1 Commencement of Pumping As a part of the remediation of chloroform contamination at the Mill site, EFRI pumps 13 wells at the Mill. Long term pumping of MW-4 was started on April 14, 2003, followed by the start of long term pumping of TW4-19 on April 30, 2003, of MW-26 on August 8, 2003, of TW4-20 on August 4, 2005, and of TW4-4 on January 31, 2010. As required by the Nitrate CAP, dated May 7, 2012 and the nitrate SCO dated December 12, 2012 EFRI began long term pumping of TW4-22, TW4-24, and TW4-25 on January 26, 2013. Because wells TW4-22, TW4-24, and TW4-25 are chloroform program wells, they are included in the chloroform pumping program and any chloroform removal realized as part of this pumping is calculated and included in the chloroform quarterly reports. Beginning on January 14, 2015, EFRI began long term pumping of TW4-1, TW4-2, and TW4-11 and began long term pumping of TW4-21 and TW4-37 on June 9, 2015. The pumping program is expected to remove a significant amount of chloroform- contaminated water. 2.2 Pumping Data Collection Data collected during each quarter includes the following: • Measurement of water levels at MW-4, MW-26, TW4-1, TW4-2, TW4-4, TW4- 11, TW4-19, TW4-20, TW4-21, TW4-22, TW4-24, TW4-25, TW4-37 and TWN- 02, on a weekly basis, and at selected temporary wells and permanent monitoring wells on a monthly basis as described below. • Measurement of pumping history, including: pumping rates total pumped volume operational and non-operational periods. • Periodic sampling of pumped water for chloroform and nitrate/nitrite analysis and other constituents as described below in Section 4.1. 2 2.3 Water Level Measurements Weekly and monthly depth to groundwater measurements are taken in the chloroform pumping wells MW-4, MW-26, TW4-1, TW4-2, TW4-4, TW4-11, TW4-19, TW4-20, TW4-21, TW4-37, and the nitrate pumping wells TW4-22, TW4-24, TW4-25, and TWN-02. In addition, monthly water level measurements may be taken in non-pumping wells MW-27, MW-30, MW-31, TW4- 21, TWN-1, TWN-3, TWN-4, TWN-7, and TWN-18. In addition to the above, depth to water measurements are routinely observed in conjunction with sampling events for all wells sampled during quarterly and accelerated efforts, regardless of the sampling purpose. Water level monitoring will be documented on the Weekly Inspection Form and the Monthly Depth Check Form included as Attachments A and B to the O&M Plan. Water level contour maps of the data will be generated quarterly and included in the quarterly monitoring report. 2.4 Pumping Rates and Volumes As required by the GCAP, the quarterly monitoring report will summarize the recovered mass of chloroform by well per quarter and historically since the inception of the chloroform recovery program for the active pumping wells. The pumping wells do not pump continuously, but are on a delay device. The wells purge for a set amount of time and then shut off to allow the well to recharge. The pumping rates and volumes for each of the pumping wells will be calculated and reported in the quarterly monitoring report. Specific operational problems observed with the well or pumping equipment which occurred during the quarter will be reported for each well in the quarterly monitoring report. 3.0 PUMPING SYSTEM MAINTENANCE Specific details regarding the operation, maintenance, and system components are included in the Chloroform O&M Plan Revision 2.2, dated March 21, 2013 (Approved April 8, 2013). Details regarding the system maintenance are summarized below. Details regarding the costs to maintain the remediation pumping system for a six year period are included in Attachment A to this CPRP-CE. 3.1 Winterization for Long-Term Operations To provide continuous operations of the pumping well system at the White Mesa Mill during cold weather conditions protective boxes are placed around the wellheads. The protective boxes are lined with insulation and heat lamps are installed. The pump discharge line from each of the pumping wells is connected to a main drain line, which discharges to the Mill process or the tailings cells. Lines are protected from freezing by covering them with a minimum of 3 feet of soil to prevent freezing during the winter months. During winter weather with potentially 3 freezing conditions, the environmental department staff, observe the pumping daily to ensure that the heat lamps remain functional. 3.2 Maintenance Activities The operation of each of the pumping wells is monitored on a daily basis. Any malfunction or abnormal operation of the pumping wells is immediately reported to the EFRI Corporate Office. Environmental department staff will periodically inspect the pumps, flow meters and operational controls and perform preventative maintenance to reduce the frequency of unscheduled down time of the pumping system. Spare pumps are maintained in the Mill warehouse. When a system failure occurs and is not repaired and fully made operational within 24 hours of discovery, EFRI will follow the reporting procedure in the approved Operations and Maintenance Plan. In addition, all system failures will be reported in the following quarterly chloroform groundwater monitoring report. 4.0 CHLOROFORM MONITORING AND REPORTING 4.1 Chloroform Monitoring Quarterly chloroform samples and measurements collected pursuant to the GCAP are discussed below. Analytical methods, purging and sampling procedures are consistent with the requirements of the Chloroform Investigation Monitoring Quality Assurance Program (the "Chloroform QAP") attached as Appendix A to the White Mesa Uranium Mill Groundwater Monitoring QAP Revision 7.2, dated June 6, 2012. Details regarding the costs to monitor and complete the associated reporting for the remediation pumping system for a six year period are included in Attachment A to this CPRP-CE. Quarterly sampling for chloroform monitoring parameters is currently required in the following wells: MW-4 TW4-9 TW4-18 TW4-27 TW4-36 TW4-1 TW4-10 TW4-19 TW4-28 TW4-37 TW4-2 TW4-11 TW4-20 TW4-29 TW4-3 TW4-12 TW4-21 TW4-30 TW4-4 TW4-13 TW4-22 TW4-31 TW4-5 TW4-14 TW4-23 TW4-32 TW4-6 MW-26 (formerly TW4-15) TW4-24 TW4-33 TW4-7 TW4-16 TW4-25 TW4-34 TW4-8 MW-32 (formerly TW4-17) TW4-26 TW4-35 Wells are analyzed for the following constituents: • Chloroform • Chloromefhane • Carbon tetrachloride 4 • Methylene chloride • Chloride • Nitrate plus Nitrite as Nitrogen Depth to groundwater measurements are discussed in Section 2.3 above. Additional chloroform monitoring in response to exceedances will be conducted in accordance with SCO and GCAP requirements using the analytical methods, purging and sampling procedures are consistent with the requirements of the Chloroform QAP attached as Appendix A to the White Mesa Uranium Mill Groundwater Monitoring QAP Revision 7.2, dated June 6, 2012. 4.2 Chloroform Reporting As required by SCO, GCAP, and the Chloroform QAP attached as Appendix A to the White Mesa Uranium Mill Groundwater Monitoring QAP Revision 7.2, dated June 6, 2012, quarterly reporting of the chloroform monitoring data is required. The quarterly data are reported to the DWMRC concurrent with the schedule for submission of Quarterly Groundwater Monitoring Reports, and according to the following schedule. First Quarter - June 1 Second Quarter - September 1 Third Quarter - December 1 Fourth Quarter - March 1 In addition to the quarterly sampling information, additional information as delineated in the GCAP is included in the quarterly reports. 5.0 PUMPING SYSTEM MODIFICATIONS If needed, the pumping system will be modified in accordance with and as required by the GCAP. Modification to the system may include but is not limited to the addition of wells or a change to well classification. Before any modifications to the procedures, methods, or equipment are completed, EFRI will obtain prior written approval from the Director as required by the GCAP. In the event that the Director provides written notification to EFRI that additional Performance Monitoring Wells, Compliance Monitoring Wells, Pumping Wells and/or other equipment or procedures are needed at the facility to monitor, control, contain and/or remove the Chloroform Plume in accordance with the GCAP, EFRI will install, modify, operate and maintain the required wells, equipment, or procedures in accordance with the requirements found in Part JJ of the GCAP. Where required, completion of public notice and comment period pursuant to Utah Administrative Code ("UAC") R317-6-6.15.E would be completed by DWMRC. Surety estimate changes resulting from system modifications will be incorporated in the annual surety updates due on or before March 4, of each year. 5 6.0 DECOMMISSIONING OF THE PUMPING SYSTEM Decornrnissioriing of the pumping system includes the removal of protective boxes placed around the wellheads, removal of transfer pipelines from the pumping wells, and abandonment of all chloroform system wells. Decommissioning is assumed after the end of the mill life and is assumed to be completed by a third party under DWMRC supervision. Removal of the protective boxes surrounding the wellheads will be accomplished using hand tools. Any resulting debris will be disposed of as specified in the approved Reclamation Plan. Removal of pumping system transfer lines will be completed using equipment that is on the site during the Mill decommissioning. Soil cover will be removed and the lines will be "pulled" using heavy equipment. Any resulting debris will be disposed of as specified in the approved Reclamation Plan. Performance Monitoring Wells, Compliance Monitoring Wells, Pumping Wells are constructed of PVC and are grouted in place. Wells will be abandoned in accordance with State of Utah Administrative Code R655-4 subsection 14.9 Abandonment of Gravel Packed Wells by a "currently licensed water well driller who shall be responsible for verification of the procedures and materials used". After removing any equipment present each abandoned well will be "pressure grouted throughout the perforated or screened section of the well. The remainder of the well will be filled with sand cement grout, neat cement grout, bentonite abandonment products, or bentonite grout. The uppermost ten (10) feet of the abandoned well casing shall consist of neat cement grout or sand cement grout." The casing of each abandoned well "shall be severed a minimum of two feet below the natural ground surface adjacent to the well or at the collar of the hole, whichever is the lower elevation. A minimum of two (2) feet of compacted native material shall be placed above the abandoned well upon completion". With regard to placement of materials within the well, "neat cement grout shall be introduced at the bottom of the well" and "placed progressively upward to the top of the well. The sealing material shall be placed by the use of a grout pipe, tremie line, dump bailer, or equivalent in order to avoid freefall, bridging, or dilution of sealing materials or separation of aggregates from sealants". With regard to any bentonite-based abandonment products that may be used, "bentonite-based abandonment products shall be mixed and placed according to manufacturer's specifications and result in a seal free of voids or bridges. Granular or powdered bentonite shall not be placed under water. When placing unhydrated bentonite, a sounding or tamping tool shall be run in the sealing interval during pouring to measure fill-up rate, verify a continuous seal placement, and to break up possible bridges or cake formations". Details regarding the costs to decommission the remediation pumping system are included in Attachment A to this CPRP-CE. 6 7.0 CERTIFICATION This cost estimate has been prepared by a Utah Registered Professional Engineer as indicated below. 8893969-2202 No RYAN US 6 Ryan Ellis Utah Registered Professional Engineer No. 8893989-2202 7 Attachment A White Mesa Mill Chloroform Project Reclamation Plan Cost Estimate Cost Summary Chloroform Pumping System - Required Surety Estimate Task 1: Operation for a 6 year period. $ 94,469 Task 2: Maintenance for a 6 year period. $ 60,154 Task 3: Monitoring for a 6 year period. $ 283,130 Task 4: Reporting for a 6 year period. $ 97,152 Task 5: Chloroform System Abandonment $ 17,135 Direct Costs $ 552,040 Indirect Costs $100,747 Total $652,788 Profit Allowance Contingency Licensing & Bonding UDEQ Contract Administration Engineering Design Review Indirect Costs 10.00% $55,204 0.00% $0 2.00% $11,041 4.00% $22,082 2.25% $12,421 $100,747 Chloroform Pumping System - Required Surety Estimate Task 1: Operation for a 6 year period. Assumptions The full Chloroform pumping and monitoring system has already been installed. Operation will be performed by the Environmental Technician at $26.20 per hour. Daily operation checks take 0.5 hours for 2 Environmental Technicians. Weekly operation checks take 1.5 hours for 2 Environmental Technicians. Measure Depth to Water Monthly 3 hours for 2 Environmental Technicians. Power $0.07/KWH Average power of each pump motor = 0.75 hp. Average pumping time per day = 1.1 hr. Item Quantity Units Quantity Units Cost Daily Operation Checks - Labor 1 Hrs/Day 365 hrs/Yr 9,563 Weekly Operation Checks - Labor Hrs/Wk 156 hrs/Yr 4,087 Measure Depth to Water Monthly Hrs/Month 72 hrs/Yr 1,886 Pumping hours per well per quarter 1.1 Hrs/Day 401.5 hrs/Yr 16.00 Total per year Total 6 years 15,745 94,469 Task 2: Maintenance for a 6 year period. Assumptions Maintenance will be performed by the Environmental Technician at $26.20 per hour. 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. Labor Hours / Item Quantity Units Year Pump Replacement Replaced / year 24 Material Cost per year Cost 6600 7,229 Flow Meter Replacement Replaced / year 16 980 1,399 Heat Lamp Replacement 14 Replaced / year 140 140 Frozen Pipeline Clearing Clearing / year 48 Total Total 6 years 1,258 10,026 60,154 Page 1 of 2 Task 3: Monitoring for a 6 year period. Assumptions Analytical cost per sample = $169 45 samples per quarter Sample collection will be performed by the Environmental Technician at $26.20 per hour. 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 640 Hrs/year | $ 26.20 $/hr $ 16,768 Total 47,188 Total 6 years $ 283,130 Task 4: Reporting for a 6 year period. Assumptions Reporting will be performed by the Environmental Technician at $26.20 per hour. 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 |Report Preparati ion I 160 I Hrs/year | $" Cost 26.20 $/hr 4,192 Contamination Analyisis per year $ 3,000.00 $/Quarter 12,000 Total 6 years 97,152 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 $26.20 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. 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 Quantity Units Labor Hrs Equipment Hours Total Cost Pull pumps and remove enclosures 13 Pumping Wells 13 13 $ 1,055.61 Abandon All Wells - Labor 38 Wells 38 995.62 Abandon All Wells - Materials 38 Wells $ 9,120.00 Excavate and Backfill Pipeline Trench 12900 Linear Feet 39.34 31.34 $ 5,963.92 Total $ 17,135.14 Page 2 of 2 Labor Costs LABOR COSTS Specified Wages Energy Fuels and WMI Rates 2014 Estimated Labor Rates'* Labor Rates increased by 3% In 2015 103% 15.65% 7 00% Base Rate * Labor Burden Company (FICA, SUI, Benefits (medical, Mandated Fringe Fill, etc. life insure, etc) Labor Classification Boiler Makers Millwrights Ironworkers Carpenters Cement Masons Electricians Ironworkers - Reinforcing Laborers (including pipe layers) Pipefitters POWER EQUIPMENT OPERATORS Backhoes Cranes Dozers Graders Loaders Scrapers Trackhoes Tractors Truck Drivers Note: base rates do not Include FICA, worker comp, unemployment, or company benefits which Increase the cost per hour $4.07 $25.98 $18 76 no added cost $3.36 no added cost $21.44 14.28 $9.92 $3.52 no added cost $22.50 $3.03 $2.38 no added cost $15.19 $14 42 $0 56 $2.26 $0 45 $2.34 no added cost $14.96 $2.71 $21.23 $3.32 $1.49 $0.00 $2.14 $0.96 $13.65 $3.28 $1.47 $20.95 $2.65 $1.19 $16.94 $3.53 $1.58 $22.57 $18 93 $2.96 $1 33 $3.28 $1.47 $20.94 $2 96 $18.93 $1.33 $3.28 $20.94 $1.47 $3.28 $1.47 $20.94 $2.65 $1.19 $16.94 $2.65 $1.19 $16.94 15.05% Fringe Costs - Labor on Overtime Labor Cost/HR - Cost/HR - 50 Fringe Costs Labor Cost/HR hours Overtime hour week $22 83 $7.64 $13.44 $5.41 $3.27 $5.05 $4 81 $3 09 $4.75 $3.84 $5 11 $4.29 $4.74 $4.29 $4 74 $4.74 $3 84 $3 84 $48.80 $29.08 $35.94 $20.60 $17.69 $20.01 $26 04 $16.74 $25.70 $20.78 $27.68 $23.22 $25.68 $23 22 $25.68 $25 68 $20.78 $20.78 $22.23 $7.04 $12.84 $4.81 $2 67 $4.45 $4.21 $2 49 $4.15 $3.24 $4.51 $3 69 $4.14 $3.69 $4.14 $4.14 $3 24 $3.24 $72.30 $42 72 $53 00 $30 00 $25.63 $29.11 $38 15 $24.21 $37.64 $30.27 $40 62 $33.93 $37.62 $33.93 $37.62 $37 62 $30.27 $30 27 $53.50 $31.81 $39.35 $22.48 $19.27 $21.83 $28.46 $18.23 $28.08 $22.68 $30.27 $25.36 $28.07 $25.36 $28.07 $28.07 $22.68 $22.68 Payroll Taxes WC Ul % of employee pay 7.65 7.4 0 60 15.65 State of Utah - General Decision - Current Update UT130043, attached, 5 pages, 02/27/2014. ( For comparison only, not used) 1/5/2016 - 9:53 AM - WMM Chloroform Reclamation Dec 2015 xbx Energy Fuels Resources (USA) Inc White Mesa Mill LABOR COSTS Base Rate" Mandated Fringe Nonspecified Wages Survey Crew Member Sample Crew Member Mechanic (Demolition) Manager/Engineer Radiation Safety Officer Secretary Clerk Engineer Environmental Technician Safety Engineer Maintenance Foreman Security Personnel Chemist ' Labor rates based on the 2014 White Mesa Mill Operating Budget. "* Reflects 0 0% cost of living raise for 2014 Labor Burden (FICA, SUI, FUI, etc Company Benefits (medical, life insure, etc) 512 15 $1.90 $0.85 SO.OO $12 15 $1 90 $0.85 SO 00 $12.62 $0.00 $1.98 $0.88 $44 44 $6.95 $3 11 $0 00 $34.72 $5 43 $2.43 $0 00 $14.04 $0.00 $2.20 $0.98 $11.55 $0 00 $1.81 $0 81 $34.72 $5 43 $0.00 $2.43 $19.55 $3.06 $1.37 $0.00 $19 55 $3.06 $1 37 $0.00 $25.48 $0.00 $3.99 $1.78 $7.53 $0.00 $1.18 $0.53 $20.44 $3 20 $1.43 $0 00 Fringe Costs Labor Cost/HR Fringe Costs - on Overtime hours Labor Cost/HR Overtime Labor Cost/HR - 50 hour week $2.75 $2.75 $2 86 $10.07 $7.86 $3.18 $2.62 $7.86 $4.43 $4.43 $5.77 $1.70 $4.63 $14.90 $14.90 $15.48 $54.51 $42.59 $17.22 $14.17 $42.59 $23.98 $23.98 $31 25 $9.23 $25.07 $2.15 $2.15 $2 26 $9.47 $7.26 $2.58 $2.02 $7.26 $3.83 $3.83 $5.17 $1 10 $4.03 $21.45 $21.45 $22.32 $80.86 $62.98 $24.94 $20.36 $62.98 $35 07 $35.07 $45.97 $12 94 $36.71 $16.21 $16.21 $16.85 $59.78 $46.67 $18.77 $15.41 $46.67 $26.20 $26.20 $34.19 $9.97 $27.40 1/5/2018 - 9-53 AM - WMM Chloroform Reclamation Dec 2015 xbx Energy Fuels Resources (USA) Inc. White Mesa Mill Equipment Costs EQUIPMENT COSTS WHITE MESA MILL RECLAMATION COST HOURLY EQUIPMENT COSTS 2014 DOLLARS Actual equipment rates quoted from North Central Rental & Leasing, LLC, 12 month rental penod February 18, 2014 637G Scraper D8T Dozer D7E Dozer 825H Compactor 980 H/K Loader 986 H Loader 770 Haul Truck 365CL Excavator 651 Water Wagon 5000 gal Water Truck 14H/Ripper Motor Grader HOflTHLY | HOURLY | Etc—«Hourt | MHourW to EXPENDABLES USAQE 31,200 18,950 13,150 13,800 13,900 21,450 14,100 20,300 14,450 8,200 10,850 177.27 107 67 74.72 78 41 78 98 121 88 8011 115 34 82.10 46.59 61 65 89 00 45 00 38 00 40 00 38.00 40 00 40 00 58 00 41 00 24 00 31 00 15962 95 14 67 37 70 73 70 78 105 50 72 09 103 87 73 88 42 07 55 52 11 00 6 25 5 75 5 75 6 20 8.00 9 10 9 25 760 4 45 5.20 FUEL a 23 5 85 70 130 90 11 0 85 130 170 100 55 73 91 26 73 22 02 40 89 28.31 34 60 26 73 40 89 53 47 31 45 17 30 5 25 1 05 1 05 0.50 5 25 5 25 4 10 1 05 2 10 2.10 5 25 $249 78 $12917 $9819 $117.66 $110 54 $153 35 $112 02 $155 06 $137 05 $80 07 $83 27 Mob/Demob per machine Totals $35,350 $25,900 $20,750 $21,700 $19,750 $25,800 $21,150 $39,900 $24,400 $10,750 $15,650 Mob/Demob Operating Hrs per Month $141,400 $25,900 $20,750 $21,700 $19,750 $25,800 $84,600 $39,900 $24,400 $10,750 $15,650 $430,6001 880 220 220 220 220 220 880 220 220 220 220 3,740 | Replacement Cost 1,940,000 650,000 550,000 250,000 300,000 345,000 2,000,000 425,000 250,000 175,000 265,000 Equipment Rental Rate Quoted by Worldwide Rental Services (02/26/2013) for PC 300 Excavator with Shear Rental Rates increased by 2013 and 2014 CPI-u Rate of 1 50% and 0 80% respectively PC 300 w/Shear 25,578 00 145 33 59.00 128 06 Small tools allocation - Demolition - $1 35/mechanic labor hour for oxyoen/acetylene, expendables Butler Equipment Maintenance Cost Monthly Maintenance Flat Rate $78,400 Butler Maintained Equipment Planned Operating Hours/month 3,740 Planned Operating hours/month (other equipment 570 Total Operating hours per month 4,310 Fuel Usage per day, gal, Fuel Cost per month, 21 days 10 $ 660 48 $185 961 S1 35 Maintenance Cost per Operating Hour Mob/Demob $21 14 91.200 Mob/Demob $4884 Crane Rental Rates 60 ton Hydraulic Crane 30 ton Hydraulic Crane 10,947 6,650 EXPENDABLES 62 20 37 79 218 2 18 FUEL Q 15 0 100 47.18 31 45 COST $111 56 $71 42 ?Z500 $ 900 250,000 175,000 Rental Rates updated from Honnen Equipment, 02/26/2013 Rental Rates increased by 2013 and 2014 CPI-u Rate of 1 50% and 0.80% respectively Power Motive - Screen deck and conveyors, Replacement Cost 2013 Crane Monthly Rental Rates 60 ton | $10,700" $6,500 200,000 $ 8,225,000 $ 82,250 1I5T2D16 - 9 S3 AM - VIMM Chloroform Radsmatjon Doc 2D15 xtot Energy Fuela RMOUCM (USA) Inc Wflrto MM Mill Equipment Productivity Equipment Productivity Dozer (D-8) Productivity Determination -100' Push Distance Work Efficiency, %: 0.83 Assumes 50 minutes/hour Average Dozing Distance, FT: 100 Ideal Dozer Productivity LCY/HR 825 CAT Handbook Adjusted Dozer Productivity LCY/HR 685 Wheel Loader (988) Productivity Determination loading 3 fl> 30 C.Y. Trucks Work Efficiency, %: 0.83 Assumes 50 minutes/hour Bucket Capacity (C.Y) 10.0 Load Time, 3 loads / truck (min) 1.65 Ideal Loader Productivity LCY/HR 1091 Adjusted Loader Productivity LCY/HR 905 Haul Truck (770) Productivity Determination - 3.310' haul (Haul Route M) Work Efficiency, %: 0.83 Assumes 50 minutes/hour Average Distance, FT: 3,310 Haul Route M Average Travel Speed 20 Miles per Hour Truck Capacity (C.Y) 30.00 Load Time (min) 1.65 Haul Time (min) 3.76 Dump Time (min) 1.00 Cycle Time (min) 5.25 Ideal Truck Productivity LCY/HR 343 Adjusted Truck Productivity LCY/HR 285 Equipment Productivity Hydraulic Excavator (365) Productivity Determination loading 313> 30 C.Y. Trucks Work Efficiency, %: 0.83 Assumes 50 minutes/hour Bucket Capacity (C.Y) 6.0 Mass Excavation Boom, pg. 18 Time per Pass (min) 0.35 Cat Handbook, V 42 pg. 4-204 Load Time, 5 passes / truck (min) 1.75 Truck Capacity (CY) 30.0 Ideal Loading Productivity LCY/HR 1029 Adjusted Loading Productivity LCY/HR 854 Hydraulic Excavator (365) Productivity Determination Digging a Trench Work Efficiency, %: 0.83 Assumes 50 minutes/hour Bucket Capacity (C.Y) 6.0 Mass Excavation Boom, pg. 18 Time per Pass (min) 0.35 Cat Handbook, V 42 pg. 4-204 CY per Linear Foot of Trench 1 7 ft wide 4 ft deep Ideal Excavating Productivity CY/HR 1029 Efficency in uncovering pipe 50% Linear feet per hour 412 Haul Truck (770) Productivity Determination - 3120' haul (Haul Route E) Work Efficiency, %: 0.83 Assumes 50 minutes/hour Average Distance, FT: 3,120 Haul Route E Average Travel Speed 20 Miles per Hour Truck Capacity (C.Y) 30.00 Load Time (min) 1.75 Haul Time (min) 3.55 Dump Time (min) 1.00 Cycle Time (min) 6.30 Ideal Truck Productivity LCY/HR 286 Adjusted Truck Productivity LCY/HR 237 Haul Truck (770) Productivity Determination - 2680' haul (Haul Route C) Work Efficiency, %: 0.83 Assumes 50 minutes/hour Average Distance, FT: 2,680 Haul Route C Average Travel Speed 20 Miles per Hour Truck Capacity (C.Y) 30.00 Load Time (min) 1.75 Haul Time (min) 3.05 Dump Time (min) Cycle Time (min) 1.00 5.80 Ideal Truck Productivity LCY/HR 311 Adjusted Truck Productivity LCY/HR 258 Equipment Productivity Haul Truck (770) Productivity Determination - 2.470' haul (Haul Route D) Work Efficiency, %: 0.83 Assumes 50 minutes/hour Average Distance, FT: 2,470 Haul Route D Average Travel Speed 20 Miles per Hour Truck Capacity (C.Y) 30.00 Load Time (min) 1.00 Haul Time (min) 2.81 Dump Time (min) 1.00 Cycle Time (min) 4.81 Ideal Truck Productivity LCY/HR 374 Adjusted Truck Productivity LCY/HR 311 Haul Truck (770) Productivity Determination - 2.810' haul (Haul Route L) Work Efficiency, %: 0.83 Assumes 50 minutes/hour Average Distance, FT: 2,810 Haul Route L Average Travel Speed 20 Miles per Hour Truck Capacity (C.Y) 30.00 Load Time (min) 1.65 Haul Time (min) 3.19 Dump Time (min) 1.00 Cycle Time (min) 5.84 Ideal Truck Productivity LCY/HR 308 Adjusted Truck Productivity LCY/HR 256 Haul Truck (770) Productivity Determination - 3960' haul (Haul Route K) Work Efficiency, %: 0.83 Assumes 50 minutes/hour Average Distance, FT: 3,960 Haul Route K Average Travel Speed 20 Miles per Hour Truck Capacity (C.Y) 30.00 Load Time (min) 1.75 Haul Time (min) 4.50 Dump Time (min) 1.00 Cycle Time (min) 7.25 Ideal Truck Productivity LCY/HR 248 Adjusted Truck Productivity LCY/HR 206 Equipment Productivity Haul Truck (770) Productivity Determination - 2010' haul (Haul Route A) Work Efficiency, %: 0.83 Assumes 50 minutes/hour Average Distance, FT: 2,010 Haul Route A Average Travel Speed 20 Miles per Hour Truck Capacity (C.Y) 30.00 Load Time (min) 1.75 Haul Time (min) 2.28 Dump Time (min) 1.00 Cycle Time (min) 5.03 Ideal Truck Productivity LCY/HR 358 Adjusted Truck Productivity LCY/HR 297 Haul Truck (770) Productivity Determination - 2.570' haul (Haul Route B) Work Efficiency, %: 0.83 Assumes 50 minutes/hour Average Distance, FT: 2,570 Haul Route B Average Travel Speed 20 Miles per Hour Truck Capacity (C.Y) 30.00 Load Time (min) 1.75 Haul Time (min) 2.92 Dump Time (min) 1.00 Cycle Time (min) 5.67 Ideal Truck Productivity LCY/HR 317 Adjusted Truck Productivity LCY/HR 263 Haul Truck (770) Productivity Determination -1.150' haul (Haul Route N) Work Efficiency, %: 0.83 Assumes 50 minutes/hour Average Distance, FT: 1,150 Haul Route B Average Travel Speed 20 Miles per Hour Truck Capacity (C.Y) 30.00 Load Time (min) 1.75 Haul Time (min) 1.31 Dump Time (min) 1.00 Cycle Time (min) 4.06 Ideal Truck Productivity LCY/HR 444 Adjusted Truck Productivity LCY/HR 368 Haul Truck (770) Productivity Determination - 2.030' haul (Haul Route O) Work Efficiency, %: 0.83 Assumes 50 minutes/hour Average Distance, FT: 2,030 Haul Route B Average Travel Speed 20 Miles per Hour Truck Capacity (C.Y) 30.00 Load Time (min) 1.65 Haul Time (min) 2.31 Dump Time (min) 1.00 Cycle Time (min) 4.96 Ideal Truck Productivity LCY/HR 363 Adjusted Truck Productivity LCY/HR 301 LL O CO O (0 o Ill O O ON Lu oz O Q OZ < cn So 9i eg 0_ 4S LU OZ CD SO LU OZ CO •3 LU •3 »z < •3 LU DC = 3 •3 •3 LU 0-LU •3 •3 5 •3 CD E •3 a* , 3* c •3 •3 •3 2 C Si •3 v .--•./'• o.ir: E5 3 c\ •1« o _ •»-„ El O o 03 P £ O T3 a. m El o — Q. 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