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
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