DRC-2014-005991 - 0901a0688049e048

ENERGY FUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO. US, 80228
303 974 2140
www.energvluels.cpm
September 9, 2014
Sent VIA OVERNIGHT DELIVERY DRC-2014-005991
Mr. Rusty Lundberg
Division of Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
P.O. Box 144850
Salt Lake City, UT 84114-4820
Re: State of Utah Radioactive Materials License No. UT1900479
Response to Division of Radiation Control ("DRC") Request for Information ("RFI") of
September 5, 2014 Regarding License Condition 9.5, Surety Update, White Mesa Mill
Dear Mr. Lundberg:
This letter transmits Energy Fuels Resources (USA) Inc.'s ("EFRrs") response to DRC's RFI
resulting from a teleconference with Mr. Russ Topham on September 5, 2014.
The RFI requested a comparison of the 2013 and 2014 Surety Estimates. Specifically, EFRI was to
provide clarification to DRC regarding the changes in the Surely Estimates for Cells I and 4B
relative to the cost modifications.
Included below and in Attachments 1 through 4, are details regarding the assumptions and
reclamation cost changes for Cells I and 4B.
The changes to 2014 Surety Estimate are based on the current conditions at the White Mesa Mill and
the expected conditions during the following 12-month period covered by the Surety Estimate.
Based on current and expected conditions at the White Mesa Mill, both Cells 1 and 4B would be
reclaimed as a "Clean Closure", thus eliminating the need for engineered covers. The specific basis
for the modification for each Cell is included below.
Cell 1
The specific Cell 1 modifications are:
J. Current capacities and conditions in Cells 3 and 4A allow for the disposal of reclamation
demolition debris into Cells 3 and 4A. Based on the disposal capacities available in Cells 3 and
4A, the 2014 estimate does not contemplate the disposal of debris within the Cell 1 footprint.
The change in debris disposal location, allows for the removal of engineered cover for Cell 1.
letter to Rusty Lundberg
September 9, 2014
Page 2 of 3
2. The quantity of crystals to be removed from Cell 1 was reduced from 3 feet in the 2013
estimate to 1.5 feet in the 2014 estimate. The reduction was based on observations regarding
crystal depth and location made during the 2010 through 2012 Cell 1 liner repair efforts.
3. The 23,188 cubic yards ("cy"). of material from the Cell 1 Channel construction was used as
slope reduction material in the 2014 estimate, therefore reducing the quantity of random fill
from stockpiles needed for the completion of grading activities.
In general the other items in the Cell 1 estimate stayed the same with minor adjustments to fuel costs,
labor rates, and equipment rental rates. For reference, the crystal removal unit cost in the 2013
estimate was $1.69/cy and was $1.75/cy in the 2014 estimate.
Cell 4B
Based on the current disposal capacity available in Cell 4A, tailings solids will not be placed in Cell
4B over the next 12 months. Because there will be no tailings solids placed in Cell 4B, the 2014
Surety Estimate was based on Clean Closure for Cell 4B and an engineered cover would not be
necessary. The specific Cell 4B modifications are:
1. In support of the Clean Closure of Cell 4B, the Cell 4B liner would be removed. For
conservatism, the 2014 estimate also includes the removal of 12-inches of soil under the liner,
over the 41-acre footprint of the Cell. The Cell 4B liner and any removed soils would be
placed in Cell 4A. These costs were added in the 2014 Surety Estimate to address the Clean
Closure of Cell 4B.
2. Due to the Clean Closure assumed for Cell 4B, the final grading to meet the Reclamation Plan
specifications was changed. Both quantities of soil and placement areas were changed to
reflect the Clean Closure and "removal" of Cell 4B. The specific changes to the soils and
grading are:
A. The south dike of Cell 4B would be removed. This excavation results in 61,000 cy of fill
material to be used during slope reduction within Cell 4B.
B. With the removal of the Cell 4B south dike, (see A above) the out slopes of the adjoining
areas of Cells 3 and 4A will be reduced to 5H:1V (i.e. the current north and east slopes of
Cell 4B). The quantity of material changed from 111,000 cy in the 2013 estimate to
131,240 cy in the 2014 estimate.
C. To accommodate the out slope changes, rock armoring on the slopes was increased from
7,800 cy in 2013 to 13,031 cy in 2014 to correspond to the increased length of slope
needing protection.
D. The 2014 Surety Estimate included topsoil for the 41-acre footprint of Cell 4B, at a depth
of 6-inchcs. No topsoil was included in the 2013 estimate because topsoil is not a
component of the engineered cover contemplated for Cell 4B in the 2013 estimate.
Letter to Rusty Lundberg
September 9. 2014
Page 3 of 3
3. Due to the Clean Closure of Cell 4B, no engineered cover for Cell 4B was included in the 2014
Surety Estimate.
Please contact me if you have any questions or require any further information.
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc: Scott Bakken
Frank Filas
David C. Frydenlund
Dan Hill Men
Harold R. Roberts
David E. Turk
ATTACHMENT 1
Cell 1 2013 Estimate
INTERNATIONAL URANIUM (USA) CORP.
COST ESTIMATE
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| 29.5647 Acres
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Description Cvu-i _..<r.'.fArtN*l- rfr.amrfn'V LZ.tsr't nAYi&"-\
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Job No JO>jy46 ._
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CELL 1 NORTHERN OUTSLOPE
TYPICAL CROSS-SECTION
TOP OF ET COVER
RANDOM FILL
CROSS-SECTIONAL
AREA: 324 SF
-RIP RAF
CROSS-SECTIONAL
AREA: 82 SF
'7
AVG. HEIGHT: 18 FT 11 7A
'A /.
RIP RAP BEDDING -
CROSS-SECTIONAL
AREA: 45 SF
WHTTE MESA MUX RECLAMATION
0ENISOL. MINES
Denison Mines (USA) Corp SLOPE AREA CALCULATIONS
CELL 1 fcs
MWH
SEP 2011 I
100ST40 SORROW
Franklin Drilling & Blasting, Inc.
P.O. Box 2246
Durango, CO 81392
Phone: [phone]
Fax: [phone]
Mobile: [phone]
Email: [e-mail]
February 10, 2012
Ms. Georgia VanReenen
Denison Mines
PO Box 809
Bianding, UT 84511
Re: Spillway Blasting in Bianding, Utah
We received your e-mail request for cost of drilling and blasting a spillway
at your Mine site in Bianding, Utah. The information we now have is an
area of approximately 150' wide by 1200' long with an average depth of
about 10', generating in the neighborhood of 67,000 cubic yards in place.
If this is currently correct, our price would be $2.25 per in-bank cubic yard
for dry conditions. In addition we would require your mine to furnish fuel
for our drills. Quantity of fuel would be estimated at less than 100
gallons/day for both drills. If water infiltrates into the bore holes and
requires wet hole explosive product, we will charge an additional fee. The
fee will be the invoice cost of wet hole product delivered, plus 25% mark up
to cover additional labor.
Our mobilization for 2 drills and supplies will be $7000. Payable when we
mob in and start.
Please call if you have any further questions and this quote will only be
good thru December 31, 2012.
Regards,
Jeff Franklin/President/Owner T*>*«**x &r
/, ~?H X /ft***'*
1
ATTACHMENT 2
Cell 1 2014 Estimate
Volume Calculation • Cell 1
Reviewed 5/16/14
1) Area of Cell 1 - 2,575,703 sq ft = 59.13 acres
2) Crystal and Liner Cover Removal
- Dewalermg estimated at 2 years based on the last time Cell 1 was dry and approximate duration
- Crystal thickness assumed as 1 5 feet.
- Soil Cover over the PVC Liner Is based on design and as-built -1.5 feel.
- Crystal and soil cover wHI be excavated at the same time and placed in Cell 4A.
- Crystal and soil cover will be wtndrowed with a dozer, and loaded into 3 trucks with a loader.
- The PVC Liner will cut into manageable pieces and loaded into a truck with a hydraulic excavator
- Road maintenance will be accomplished with a motorgrader and water wagon.
Volume to be removed = 2.575.703 x (1.5 ft + 1.5 ft)
27 frVcy
3) Removal of Contaminated Material Under Liner
- Estimated depth of contaminated soil required to be removed -1 foot
- Contaminated material wril be removed to Cell 4A.
- Contaminated soil wHI be wtndrowed with a dozer, and loaded into 3 trucks with a loader
- Road maintenance will be accomplished with a motorgrader and water wagon.
Volume to be removed •• 2.575.703
27 ft'/cy 95.396 CY
4) Construct Channel
- The channel will be constructed in the southwest corner of Cefl 1 and will daylight to an existing natural
channel.
- The channel requires blasting of the bedrock to achieve the design grade
- Approximate dimensions of the channel are 1.200 leet long by 150 feet wide by 10 feet deep.
Volume to be removed = 1.200 ft x 150 fix 10 ft
27 ft'/cy 66.667 CY
- The broken rock material will be loaded into 3 trucks with a hydraulic excavator.
- 23,188 CY of this material will be used in Cell 1 to grade the side slopes from 3H.1 V to 5H:1V.
- The remainder of the excavated material will be hauled to Cell 4A South Slope and used as Random Fill • 43,479 CY
5) G'kde Side slopes
- Material needed to grade the side slopes of Cell 1 will be produced during the construction of the CeH
1 Drainage Channel
- The costs for staging the grading material at the base of the slopes is accounted for thin (he Channel
Construction Task.
- The slopes will be graded and shaped with a dozer.
- Cell 1 has 6,020 feet of slopes. The slopes are 8 feet high and currently at a 3H:1 V slope.
Volume needed for Grading = 6,020 ft x B ft x 26 ft Mite)
27 ft'/cy 23.188 CY
Cell 1 and 4B Backup.xlsx
6) Topsoil Application
• 29 acres of Cell 1 requires placement of 6 inches of topsoil.
• The remainder of Cell 1 will be covered with exposed Dakota Sandstone or Rip Rap.
- The topsoil will hauled from Topsoil pile W4.
- A scraper fleet will haul the topsoil and a dozer will assist with loading and final spreading.
- Road maintenance will be accomplished with a motorgrader and water wagon
Volume needed for be placed =* 29 acres x 43.560 ft2 /acre x 0.5 ft
7) Rock Armor and Rip Rap Filter Placement
- Rock for side armor, top armor and toe aprons will come from an off-site gravel source one (1) mile
north of Bianding. Rock will be produced through screening, stockpiled and trucked to the site at the time
of use. Belly dump trucks wHI dump gravel in windrows on the top and sides of the Cell.
- A dozer will spread the delivered rock
- Road maintenance will be accomplished with a motorgrader and water wagon
• 8.607 CY of rock will be placed.
Cell 1 and 48 Backupjtlsx
ATTACHMENT 3
Cell 4B 2013 Estimate
Volume Calculation - Cell 4B
Updated 02722/13 |
1) Area of Cell 4B - 1,785,960 sq ft = 41 acres
2) Assumptions
- Bridging layer Is placed using random fill from piles west of Cell 4B
- Cell will be graded to Design elevation utilizing finer materials in random fill stockpiles
and from "clay" stockpiles.
- Clay will be mined, blended, and hauled from borrow site location in Section 16 -
four miles south of the mill area, using belly dump trucks, clay layer on top of Cell only.
- The upper 1 foot of random fill will be placed utilizing the fine random fill and clay stockpiles
- Rock for side armor, top armor and toe aprons will come from an off-site gravel source
one (1) mile north of Bianding. Rock will be produced through screening, stockpiled and
trucked to the site at the time of use. Belly dump trucks will dump gravel in windrows
on the top and sides of the Cell.
3) Bridging Layer ( Platform Fill) Remaining to be placed
1,785,960 sq ft X 3 ft. / 27 cubic feet per cubic yard = 198,440 cubic yards
Use| 198,500 cubic yards
4) Bring Platform Fill up to Design elevation (Lower Random)
Assume full area of Cell X one (1) foot thick
1,785,960 sq ft X 1 ft. / 27 cubic feet per cubic yard = 66,147 cubic yards
Use | 66,000 cubic yards |
5) Placement of Clay Layer (One (1) foot thick on top of Cell only)
Assume full area of Cell X one (1) foot thick
1,785,960 sqft X 1ft. / 27 cubic feet per cubic yard = 66,147 cubic yards
Use | 66,000 cubic yards
Volume Calculation - Cell 4B (con't) page 2
6) Upper Random Fill Volume - Top of Cell area
Assume full area of Cell X one (2) foot thick
1,785,960 sq ft X 2 ft. / 27 cubic feet per cubic yard =
7) Armor Protection - Top of Cell
Assume full area of Cell X one-half (0.5) foot thick
1,785,960 sq ft X 05 ft. / 27 cubic feet per cubic yard =
8) Cell 4B South Dike. ( Slope #1 )
Average height 36 feet
Length 1600 feet
a) Random fill to reduce slope from 3:1 to 5:1
First Wedge [36 X 36 X 5)/2 - (36 X 36 X 3)/2] X 1600
2,073,600 cubic feet/27 =
Remaining Random Fill
[39 X 39 X 5)/2 - (36 X 36 X 5)/2] X 1600
900,000 cubic feet/27 =
Total Random Fill South Slope
b) Rock Armor 8" thick - 0.67 feet
(39.67 X 39.67 X 5)/2 - (39 X 39 X 5)/2] X 1600
210,836 cubic feet/27 =
132,293 cubic yards
Use | 132.000 cubic yards |
33,073 cubic yards
Usej 33,000 cubic yards-]
76,800 cubic yards
Use} 77,000 cubicyardT"|
33,333 cubic yards
Use | 34,000 cubic yards J
111.000 cubic yards \
7,809 cubic yards
Use 1 7,800 cubic yards \
Volume Calculation - Cell 4B (con't) page 3
c) Rip Rap Filter 6' thick - 0.5 feet
(39.5 X 39.5 X 5)/2 - (39 X 39 X 5)/2] X 1600
157,000 cubic feet/ 27 = 5,815 cubic yards
Use 6,000 cubic yards
d) Rock Apron at toe of slope (2ft X 7ft wide X 1600 long] / 27 = 830
Use | 850 cubic yards |
Total Rock Armor South Slope | 8,650 cubic yards""]
9) Cell 4B West Slope ( Slope #2 )
Average height 8 feet
Length 1200 feet
a) Random fill to reduce slope from 3:1 to 5:1
First Wedge [8 X 8 X 5)/2 - (8 X 8 X 3)/2] X1200
76,800 cubic feet/27 = 1185 cubic yards
Use | 1,200 cubic yards |
Remaining Random Fill
111 X 11 X 5)/2 - (8 X 8 X 5)/2] X 1200
171,000 cubic feet/27 = 6,333 cubic yards
Use | 6,500 cubic yards |
Total Random Slope ff3 | 7,700 cubic yards |
b) Rock Armor 8" thick - 0.67 feet 14.52 cubic feet per linear foot of dike
14.52 cubic foot per linear foot X1200 / 27
= 645 cubic feet/ 27 = 24 cubic yards
Use | 25 cubic yards |
Volume Calculation - Cell4B (con't) page 4
c) Rip Rap Filter 6" thick - 0.5 feet
10.84 cubic toot per linear foot X 1200 / 27
Volume Calculation - Cell 4B (con't) page 4
482 cubic feet/ 27 = 18 cubic yards
Use 20 cubic yards
c) Toe Apron Not required
Total Rock Armor Cell 4B West Slope | 25 cubic yards""]
Volume Summary - Cell 48
Top of Cell
South (Slope «1)
West (Slope #3 )
Totals
Bridging Layer
198,500
198,500
Lower
Random
66,000
77,000
1,200
144,200
Clay
66,000
66,000
Upper
Random
132,000
34,000
6,500
172,500
Rock
Armor
33,000
8,650
25
41,675
Rip[ Rap
Filter
6,000
20
6,020
Volume Calculation - Cell 46 (con't) page 5
Cell 4B Reclamation
Cat 837 Resource Requirements
Volume Route Yds/hr % Equip. Mr.
Cell 4B Bridging Lift
Tailings Surface 198,500 303 100% 654.6
Cell 4B Lower Random Fill
Tailings Surface
Slope 1
Slope 2
Total
66,000
77,000
1,200
303
303
303
100%
100%
100%
217.6
253.9
4.0
475.5
Cell 4B Upper Random Fill
Tailings Surface
Slope 1
Slope 2
Total
132,000
34,000
6,500
303
303
303
100%
100%
100%
435.3
112.1
21.4
568.8
Cell 4B Rock Armor - use Highway Trucks
Volume Calculation - Cell 4B (con't) page 6
Clay Volume •
Clay Production Cell4B
(use same assumptions as Cell 2 )
66,000 Bank Cubic Yards (BCY)
0.8 Swell Factor
82,500 Loose Cubic Yards (LCY)
Trucking 475 LCY/hr 8 trucks plus one (1) Loader
85,000 LCY / 475 LCY/hr =
czz:
174 hours
use 180 hours
180 X 8 Trucks = 1,440 hours
Machine Hours
980 Loader
08N w/ ripper
Cat 651 WW
Cat 825 Comp
14C Patrol
5000 gal WW
180
180
180
200
200
150
Rock Armor and Filter Layer Production Cell 4B
47,695 cubic yards (cy)
38 cy per hour times 8 trucks
304 cy per hour delivered
Assume 25% extra time for spreading, loading and screen waft
304/1.25 243.2 cy per hour 196 Hours
ATTACHMENT 4
Cell 4B 2014 Estimate
1) Area ot Cell 4B
Volume Calculation - CeIMB
1,785,960 sqft = 41 acres
| Updated 5/1g14 ]
2) Assumptions
• Since there will be no tailings in Cell 4B in the next year, the south Dike will be breached for closure
- Dewatering is estimated at 1 year due to no restrictions from tailings.
- The liner wHI be removed and 1 foot of soil beneath the liner is also planned to be removed
- The side slopes will be reduced to 5H:1 V Slopes.
- The side slopes adjoining Cell 3 and Cell 4A till be capped with 3 feet of random fill and rock armored
3) Liner and Contaminated Soil Removal
- The triple liner will cut into manageable pieces and loaded into a truck with a hydraulic excavator.
-1 foot of Contaminated soli will be windrowed with a dozer, and loaded into 3 trucks with a loader
The contaminated soil will be hauled to Cell 4A.
Volume to be removed = 1,785,960 x (1 ft)
27 trVcv 66.147 CY
8) South Dike Breach
- Assume approximately 750 feet of dike will be breached with 5H:1 V Slopes.
- Excavation will extend to the southeast comer and will allow reclaimed Cell 4B area to naturally drain.
- The excavated material will be used to backfill a portion of the east and north slopes of Cell 48 to 5H:1 V.
• An excavator and 3 trucks will be used to load and haul the material and a dozer wrll used for final placement.
- A water truck and grader will be used for road maintenance
- Volume estimate based on AutoCAD model of excavation. 60.810 cubic yards
Use} 61,000 cubic yards |
9) Grade the north and east slopes from 2H:1 V to 6H:1 V.
- A portion of the required grading material will be produced during Cell 4B South Dike Breach (61,000 CY)
• The remainder of the material will com from the random fill stockpile west of Ceil 4B.
- The cost from loading, hauling and placing the material from the Dike Breach Is accounted for in the
Dike Breach Task
- The remainder of the material will be loaded with a loader and excavator and hauled with 4 trucks,
a) Random fill to reduce slope from 3:1 to 5:1
First Wedge [36 X 36 X 5)12 - (36 X 36 X 2)/2] X 2.670
s 5,190,480 cubic feet/ 27 = 192,240 cubic yards
- Portion obtained from Dike Breach (61.000) cubic yards
Use| 131,240 cubic yards \
Remaining Random Fill
[39 X 39 X 5)/2 - (36 X 36 X 5)/2] X 2,670
= 1.501.875 cubic feet/ 27 = | 55.625 cubic yards ~\
b) Rock Armor 8" thick - 0.67 feet
[39.67 X 39.67 X 5)/2 - (39 X 39 X 5V2] X 2670
351,832 cubic feet/ 27= I 13,031 cubic yards 1
Volume Calculation - CeJMB (coot) page 2
c) Rip Rap Fitter 6" thick - 0.5 feet
(39.5 X 39.5 X 5V2 - (39 X 39 X 5)/2| X2670
261.994 cubic feet/ 27 = | 9,703 cubic yards 1
d) Rock Apron at toe of slope [2ft X 7ft wide X 2,670 long] / 27 = j I.3W cubic yards 1
Total Rock Armor South Slope I 24.tl9 cubic yards"H
10) Grade the south and west slopes from 2H:W to 5H 1V
- A dozer will be used to push down the slopes.
[36 X 36 X 5)/2 - (36 X 36 X 2)/2) X 1.520
2,954,880 cubic feet/27 = | 109.440 cubic yards j
Volume Calculation • Cell 46 (conl) page 3
6) Topsoil Application
- 29 acres ot Cell 1 requires placement ol 6 inches of topsoil.
- The remainder of Cell 1 will be covered with exposed Dakota Sandstone or Rip Rap.
• The topsoil will hauled from Topsoil pile W4
• A scraper fleet will haul the topsoil and a dozer wiH assist with loading and final spreading.
- Road maintenance will be accomplished with a motorgrader and water wagon
Volume needed lor be placed = 41 acres x 43.560 tt2 /acre x 0.5 ft
27trVcy 33.073 CY
Coll 4B Reclamation
Cat 637 Resource Requvefrwnis
Volume Route Yds/hr per
Truck Equip. Hr
Celi4B Dike Breach
61.000 368 100% 166
Cell 4B Slope Grading
North and East Slope ###### 263 100* 498
Cell 4B Rock Armor - use Highway Trucks
Rock Armor and Filter Layer Production Cell 4B
24,119 cubic yards (cy)
38 cy per hour times 8 trucks
304 cy per hour delivered
Assume 25% extra time for spreading, loading and screen wait
304 /1.25 243.2 cy per hour 99 Hours