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HomeMy WebLinkAboutDRC-2013-004483 - 0901a0688041698aDepartment of Environmental Quality Amanda Smith Executive Director State of Utah GARY R. HERBERT Governor DIVISION OF RADIATION CONTROL Rusty Lundberg Director GREG BELL Lieutenant Governor November 14, 2012 DRC-2013-004483 Harold Roberts Executive Vice President and Chief Operating Officer Energy Fuels Resources (USA) Inc. 225 Union Blvd., Suite 600 Lakewood, CO 80228 Subject: Dawn Mining Midnight Mine Alternate Feed Request dated April 27, 2011, Memorandum of Agreement (MOA) between Energy Fuels Resources (USA) Inc. and the Utah Division of Radiation Control. Utah Radioactive Materials License No. 1900479 Dear Mr. Roberts: The Division of Radiation Control (DRC) along with its consultant URS Corporation have reviewed the alternate feed license amendment application identified above. The DRC will engage the services of URS Corporation to accomplish review of the Dawn Mining Alternate Feed amendment request dated April 27, 2011 as prescribed in the MOA. This letter provides the licensee with a copy of the signed MOA. In addition, the MOA has been provided to you through electronic mail. If you have any questions concerning this letter or the MOA, please contact me at 801-536-4263. Sincerely, John Hultquist,' * LLW/Uranium Mills Licensing Manager Division of Radiation Control Enclosure Cc: Jo Ann Tischler, EFR, Inc. 195 North 1950 West 'Salt Lake City, UT Mailing Address: P.O. Box 144850 • Salt Lake City, UT 84114-4850 Telephone (801) 536-4250 • Fax (801) 533-4097 • T D D. (801) 536-4414 www.deq.utah.gov Printed on 100% recycled paper MEMORANDUM OF AGREEMENT BETWEEN UTAH DIVISION OF RADIATION CONTROL AND Energy Fuels Resources (USA) Inc. I. General The Utah Division of Radiation Control ("DRC") and Energy Fuels Resources (USA) Inc. ("EFR") hereby enter into this Memorandum of Agreement (MOA). A. EFR owns and operates a uranium mill tailings facility near Blanding, Utah. B. This MOA pertains to project tasks associated with an April 27, 2011 EFR Proposed License Amendment (PLA) for receipt and processing of alternate feed material from the Dawn Mining Corporation Midnight Mine located near Wellpinit, Washington. C. This agreement may be extended or modified to include other identified project tasks or phases of activity, if expressly agreed to in writing by both parties to this agreement at least 30 days prior to its expiration date. II. Duration This MOA will become effective immediately upon signature by EFR and DRC. This MOA will expire on December 31, 2013. The DEQ fee schedule allows for reimbursement of actual costs of special projects. III. Agreement DRC agrees to: A. Engage the services of URS Corporation to accomplish review of the project under the current contract (State Contract No. 116259), according to the agreed upon tasks and total costs found in Attachment A of this MOA, below. Said tasks and costs were provided in an URS email to DRC staff on June 22, 2011. B. Provide EFR with: 1) Periodic telephone conference calls with DRC and URS to share preliminary impressions and observations regarding review of the PLA, 2) One or more interrogatories regarding the PLA to request additional information needed to support review, and as deemed necessary by the DRC, and, 3) Any URS invoices for services rendered on this project, including hours expended, hourly rates and job classification of URS staff involved, and a breakdown of any other expenses incurred during project completion. C. Bill EFR for URS work efforts expended in completion of the total project, up to $82,901. These costs are based on the work element and schedule assumptions found in Attachment 1, below. This agreement may be amended, for any reason, after consent by both parties. November 9, 2012 Page 1 of 5 Rev. 0 EFR Agrees to: Provide DRC with timely payment of any invoice for URS Corporation consulting services related to completion of the activities, referenced above. SIGNATURES: Rusty Lundb^rJ, Director Division of Radiation Control /Harold R. Roberts Executive Vice President and COO Energy Fuels Resources (USA) Inc. Date Date F:\WORD\IUC2\Altemate Feeds\Dawn Mining_2011 \URS\MOA\Dawn Mining Alt Feed MOA_draft.doc November 9, 2012 Page 2 of 5 Rev. 0 Attachment A URS Cost Estimates for Review of the April 27, 2011 Denison Mines License Amendment Application For Receipt and Processing of Alternate Feed Material From the Dawn Mining Midnight Mine Near Wellpinit, Washington Cost Estimates by Major Activity and Staff Time From June 22, 2011 email from Bob Baird (URS) to Loren Morton (DRC) November 9, 2012 Page 3 of 5 Rev. 0 REVIEW OF DUSA REQUEST FOR LICENSE AMENDMENT TO ALLOW PROCESSING OF ALTERNATE FEED MATERIALS FROM DAWN MINING URS Safety Management Solutions (URS/SMS) has briefly reviewed the documents Denison Mining (USA) Corp. (DUSA) has supplied to the Utah Divisions of Radiation Control (UDRC) in requesting a license amendment to allow DUSA to receive and process alternate feed materials from Dawn Mining. We have developed an approach to the work and estimated the level of effort and costs to complete proposed activities. The review will address the items included in the interrogatory template developed by URS/SMS and UDRC (transmitted on May 27, 2009), as well as guidance issued by the US Nuclear Regulatory Commission (NRC) in SECY-95-211 (dated August 15, 1995). The review approach involves the following activities and deliverables: Activities: • Perform necessary Project Management & Administration functions • Review submitted documents for completeness • Perform detailed review of submitted documents • Prepare Round 1 Interrogatories • Review responses to Round 1 Interrogatories • Prepare Round 2 Interrogatories • Review responses to Round 2 Interrogatories • Prepare Safety Evaluation Report • Prepare License/GW Permit revisions • Participate in public hearings • Prepare Public Participation Summary Deliverables: • Completeness Review Letter Report • Draft Round 1 Interrogatories • Final Round 1 Interrogatories • Draft Round 2 Interrogatories • Final Round 2 Interrogatories • Draft Safety Evaluation Report • Final Safety Evaluation Report • Draft Amended License Conditions • Final Amended License Conditions • Draft Amended Ground Water Quality Permit Conditions • Final Amended Ground Water Quality Permit Conditions • Draft Public Participation Summary • Final Public Participation Summary The levels of effort and cost by major activity are summarized in Table 1. November 9, 2012 Page 4 of 5 Rev. 0 Table 1. Summary of Level of Effort and Cost by Major Activity Activity Effort (hr) Cost ($) Project Management & Administration 64 $7,315 Initial Review 82 $10,669 Round 1 Interrogatories 122 $15,593 Round 2 Interrogatories 60 $8,107 Draft License/Permit Documents 172 $20,542 Public Participation Summary 94 $11,103 Final License/Permit Documents 82 $9,571 TOTALS 676 $82,901 The levels of effort and cost by contributor are summarized in Table 2. Table 2. Summary of Level of Effort and Cost by Contributor. Contributor E Jennrich R. Baird G. Merrell B.Mason C.Brown Seiger - Webster J. Luellen J. Kelly Redden Hibbard TOTALS Effort (hr) 102 36 40 26 76 200 80 90 22 676 Cost ($) $898 $19,436 $5,451 $4,532 $3,401 $6,497 $30,282 $5,026 $5,655 $1,722 $82,901 URS/SMS will conduct the review and other activities and provide deliverable documents listed above on a schedule that satisfies UDRC and DUSA needs. This commitment is based on the assumption that both UDRC and DUSA will perform activities for which they are responsible and provide suitable feedback, guidance, responses, and other documents within timeframes compatible with the agreed schedule. November 9, 2012 Page 5 of 5 Rev. 0 State of Utah Mail - Requestfor Clarilication: Re. Draft SER for Davvn MinirE Alter1}Feed Material UDRC 1102.007 OUT John Hultquist <jhultquist@uta h.gov> Request for Clarification: Re. Draft SER for Dawn Mining Alternate Feed Material UDRC 1102.007 OUT i rnessago Luellen, Jon <Jon.Luellen@urs.com> wed, Jul 31,2013 at 3:48 pM To: "Jo Ann Tischler (JTischler@energyfuels.com)" <JTischler@energyfuels.com>, "John Hultquist (j hultqu ist@utah. gov)" <j hultq uist@utah. gor,> Cc: "Hibbard, Catherine" <catherine.hibbard@urs.com> Jo Ann: ln attempting to finalize the Draft SER for the LAR for the Dawn Mining Alt Feed Uranium Material, there is one item where additional clarification is requested. The following request for clarification (Questions below) applies to the discussion on the potentialfor beryllium exposure onp.21of 35 of the 6.14.13 pdf document receired fom Energy Fuels Resources, lnc.: Para's from the 6.14.13 document: ".... The following analysis eraluates public health limits from radioparticulates potentially deriwd fom wind transport of tailings particulates and assumed those ler,els of particulate transport with the beryllium concentrations in the Uranium Material and subsequent tailings. These public exposure lerels of aibome beryllium are compared to the EPA reference concentration (RE)to assess the potential for adwrse public health impact from the beryllium in windblown tailings or Uranium Material. The R0, i.e., the concentration that is "likely to be without an appreciable risk of deleterious efiects during a lifetime", for beryllium is 0.02 pgim3 (EPA 2013). Assuming a Thorium-23O concentration in the tailings of 1,000 pCi/g and a 10 CFR 20 effiuent limit of 2 x 10-14 pCi/ml, the maximum allowable oflsite airbome particulate concentration attributable to tailings would be 40 pg/m3. At the hypothetical maximum oftite airbome particulate concentration of 20 pg/m3, the maximum concentration of beryllium attributable to the Uranium Material in those airbome particulates would be 2 x 10 6 pg/m3, or a factor of 2,500 below the RCI. Therefore, processing the Uranium Material is not expected to present any significant risk to the general public fom beryllium in airborne particulates tom the Mill...' U. S. Environmental Protection Agency (EPA). 2013. lntegrated Risk lnformation System (lRlS). Beryllium and compounds (CASRM 744041-7). Accessed at http://www.epa.gov/iris/subst/0O12 htm on 4120113. Questions: 1. The statements on the airbome beryllium concentration are not clear. The statement is apparently calculating a beryllium concentration in air by scaling with Th-230 concentrations. Please reriff that this is the case. 2. Please confirm that the 10CFR20 effiuent limit of 2 x 10-14 micro-Ci/ml is for airbome concentration (not water). 3. lt is not clear what the concentration of 40 micro-g/m3 refers to - is it airbome dust, Th-230, or beryllium? 4. Please explain the basis of the "maximum offsite airbome particulate concentration of 20 microg/m3". How does this relate to the previously stated ralue of 40 microg/m3? https://rnail.goog le.con/npil/t /0/?ui=2&ikc7d1fT7414&r,iew=pt&q =Jon.Luellen%4ours.corn&qs=true&ssap6h=q u€ry&th= 14036b3eb7aaa35f 8r/1y13 State of Utah Uait - neCu! Clarification: Re. Draft SER for Dawn MininO Alternf Material UDRC '1102.007 OUT 5. The beryllium particulate concentration is stated to be 2 x 10-6 microg/m3. Please explain the basis for this number and how it was calculated. 6. ln comparing the beryllium concentration of 2 x 106 micro-g/m3 , it is said to be a factor of 2,500 below the RC of 0.02 micro-g/m3, when the actual ratio appears to be a factor of 10,000. Please explain the basis for the factor of 2,500. Thank you. Jon R. Luellen Principal Geoscientist URS Corporation, Energy & Construction GMOS Group, URS Professional Solutions, LLC 8181 East Tufts Arcnue, 2nd Floor Denrer, Colorado 80237 Wk: 303-7964738 (Direct) Wk: 303-694-2770, Ext. 4738 Cell: 716-225-3608 Jon. Luellen@urs.com Altemate e-mail address: jon.luellen@urs-ps.com This e-mail and any attachments contain URS Corporation confidential information that may be proprietary or privileged. lf you receile this message in enor or are not the intended recipient, you should not retain, distribute, disclose or use any of this information and you should destroy the e-mail and any attachments or copies. https://nuil.google.con/rnail/u/0/?ui=2?ttlec7d1lT7414&Veuept&q=Jon.Luellen%4Ours.con8qs=true&search=query&th= 14036b3eb7aa35f 212 ffir-GYFUELs Enerry Fuels Resources (USA) Inc. 225 Union Blvd, Suite 500 Lakewood, CO, US, 80228 303 9742t40 www.energyfuels.com YIA EMAIL AND OYERNIGHT DELIVERY August 7,2013 Mr. Rusty Lundberg Director of the Utah Division of Radiation Control State of Utah Department of Environmental Quality 195 North 1950 West P.O. Box 144850 Salt [^ake city, uT 84116-4850 Re: White Mesa Uranium Mill - RML UT1900479 April 27r20ll Request to Amend Radioactive Materials License to Allow Processing of Alternate Feed Materials from Dawn Mining Company's Midnite Mine Water Treatment Plant ("WT['') Response to July 3l,2Ol3 URS Email comments Dear Mr. Lundberg: This letter responds to an email from Jon Luellen of URS, lnc. regarding ("EFRI's") April 27, 20lt Request to Amend (the "April 201I Amendment Requesf') the White Mesa Mill's (he "Mill's") Radioactive Materials License UT1900479 (the "RML" or the "License") to allow processing of alternate feed material from Dawn Mining Company (the "Uranium Material") and June 14, 2013 Response to Comments letter. Mr. Luellen's email addressed EFRI's responses to Comment 7a, in the June 14, 2013 letter. For ease of review, each of URS's comments is provided verbatim below in italics, followed by EFRI's response. Question l. The statements on the airborne beryllium concentration are not clear. The statement is apparently calculating a beryllium concentration in air by scaling withTh-230 concentrations. Please verifi that this is tht case. EFRI Response The approach taken was to estimate the mass concentration of particulates in air to which the public could be exposed but still remain within the effluent limits set by 10 CFR 20, Appendix B, Table 2. The Th-230 effluent limit is the critical parameter as it has the lowest value for the radiological constituents of tailings. Therefore, it was used to estimate the maximum allowable particulate tailings mass concentration in air at the site boundary. N:\WMM\Alternate Feeds\Dawn Mining Midnight Mine\Response to URS 07.31.13 comments\Response to URS 07.31.13 comments Dawn Mining 08.l5.l3,doc lptter to Rusty Lundberg August 7,20t3 Page? of 4 Once the maximum allowable mass concentration of particulates from tailings at the site boundary was calculated, the known beryllium concentration of the feed material was used to calculate the mass concentration of beryllium in effluent air to which the public would be exposed if the Th-230 concentration was at the effluent limit. The calculation is provided below. Step 1: . Assuming a Th-230 activity concentration in the tailings of 980 pCi/g . The Th-230 effluent limit in air is 2 x10-14 uCi/ml; l0 Cm Part20, Appendix B, Table 2, Column l) . Estimated beryllium concentration in the ore/ feed materials and./or tailings of 0.1 ppm (mg/kg) . Beryllium RfC of 0.02 uglm' . Conversion factorso 1x106mUm3o 1x10-6uCi/pCio 1 xl06 ug/go 1x10-ekg/ug Step 2: Calculate the mass concentration of Th-230 in air to reach the l0 CFR 20 Appendix B effluent limit identifred in Step 1: .2.00x l0-rauCi/mlx I x 106mUm3x 1x106 tgtgl (980pCi/gxl x 106uCi/pCi) =20ug/m3 Step 3: Use the^Be concentration in ores, feed materials and/or tailings from Step I of 0.1 ppm (0.1 mg/kg=1x102uglkg) Step 4: Calculate the beryllium mass concentration in the airborne particulates given the beryllium concentration of the ores, feed materials and tailings in Step 3 and the air concentration of particulates from Step 2. .1x l02ugBe/kg feedx 20 ugfeed/m3 x lO-e kgfeed/ugfeed = 2x10'6 ug/m3 beryllium Step 6: Calculate the ratio of the beryllium RfC (0.02 ug/m3) to the beryllium mass concentration in the particulates from Step 5. .0.02 ug/m3 l2x 10-6 ug/m3 beryllium = 10,000. 2. Please confirm that the I0CFR20 effiuent limit of 2 x 10-14 miuo-Ci/ml is for airborne concentration (not water). EFRI Response The value of 2 x 10-14 microCuries/nrl is an airborne (not water) concentration, as specified in htp://www.nrc.gov/reading-rm/doc-collections/cfrlpart020lappb/Thorium-230.htrnl. Letter to Rusty Lundberg August 7,2013 Page 3 of 4 3. It is not clear what the concentration of 40 micro-g/m3 refers to - is it airborne dust, Th-2i0, or beryllium? EFRI Response The value should be 20 ug/m3 not 40 ug/m3. This is the mass concentration of airborne particulates (i,e., tailings) with an activity concentration of 980 pCilg Th-230 that would result in a potential Th-230 concentration in air at the 10 CFR 20 Appendix B effluent limit of 2.00 x l0-ra uCi/ml. 4. Please explain the basis of the "maximum offsite airbome particulate concentration of 20 micro- g/rn3", How daes this rehte to the previously stated value of 40 micro-g/m3 ? EFRI Response The value of 40 uCi/m3 is erroneous. It should be 2O uCi/m3. See response to Item l, Step 2 above for its derivation. 5. The beryllium particulate concentation is stated to be 2 x 10-6 micro-g/m3. Please explain the basis for this number and how it was calculated, EFRI Response Please see response to Question 1, above 6. In cornparing the beryllium concentration of 2 x 10-6 micro-g/m3, it is said to be afactor of 2,500 below the RfC of 0.02 rnicro-g/m3, when the actual ratio appears to be afactor of 10,000. Please explain the basis for the factor of 2,500. EFRI Response The commenter's observation is correct. The beryllium concentration in airbome particulates of 2 x 10- 6 ug/m3 is approximately 10,000 times below the RfC of 0.02 ug/m3. The recalculation is presented in response to Question 1. If you have any questions, please contact me at (303) 389-4132. Yours vcrv trulv.qfu'C*rL Emncv FuBr,s Rnsouncss (USA) Inc. Jo Ann Tischler Manager, Compliance and Licensing cc David C. Frydenlund Phil Goble, Utah DRC lrtter to Rusty Lundberg August 7,2013 Page 4 of 4 Dan Hillsten Ryan Johnson, Utah DRC Ronnie Nieves Harold R. Roberts David E. Turk Kathy Weinel #rtratnnents t\ xl,3 / 13 dan6,h sfP ? I ?o,Jw! (REV.3) TO TASK ORDER RK AUTIIORIZATION Coutrol (UDRC) PROJECT Infilration and Conlaminant Transport Modeling Repsrq Whit€ Mesa Mill; Blandin& Utah" (dated on Plan; Whitc M€8a Mill; Blanding, Utatr; Radioactive Materials Licensc No. [ITt900479", Rev. 5.0 (datcd September 201 l) (and Analysis Working Sesaion). CONTRACI AGREEMENT NO.: tt625, TASK ORDER NO.; UTI 1.1 102.004 REVISIONNO.:3 EITECTM START DATE: September 19,2013 PROJECTED LATESIT ITRMINATION DATEr Iune 30,2014 BASISI fOR PAYMENT/COST ESTIMATE: Additional tunds authorized for this task includc an increase of $4,179 to the authorized furdg included in the "l\demorandum of Agreement (MOA) between Utah Division of Radiation Control and Denison Minas (USA) Corp." Attachment 5 to this TasI Ordcr Work Authorizarion (TOWA), defines the basis for payrrcnt and cost estimqt€ for accomplishing the additional scope of work defined in this TOWA Revision. With the authorization of tho additional funds provided by this revision to he curent MOA as shown in Attachment 5, thc toul amounr of transferre4 previously authorizcd, and additional funds authorized for 0ris task will total $16s,40?. SCOPE OF SERVICE$DELMRABLES: This authorizatioo providcs additional tuuds for LIRS to tpview an additional document and data submitted or to be submitted to the LIDRC by EFRJ subseguent to an Analysis Working Session hcld on the Revised Infiltration and Contaminsnt Transport Modcling Roport and the Rev 5.0 RectamationPlanfortheWhitcMesaMillsiteinthelastweekofApril 2013. AttashmentSlo'Memorandumof Agrecment bctween Utah Dvision of Radiation Control and Dcnison Mines (USA) Corp.'i attached to tbis TOWA Rcvision, defincs thc cstimatcd co6t for completing the additional wotk covered by this TOWA Revision. Any subsequent URS work following URS's review of the additio,nal document and data dcscribcd in this TO1VA Revision will bc funded through sepErate moditications to this TOWA and the associaod MOA' PERFORMANCE SCHEDT LE OI'DELMRABLES: URS will complctc revicw and submit written commQnts on the documents rc,viewcd to UDRC within l0 working days of reccipt of approval from IJDRC to rpview each document. CUSTOMER RESBONSIBLE C\)NTACT PERSONS: Phil Goblc; E0l-5364250; D8s&lggIuthAar John Hultquisq E0l-5364350i jlslEldsl@-UhAqy T'RS/WASEINGTON DIVISION NESPONSIBLE CONTACT PERIION:,, Jon Luetlen; Senior Project Manager; 3O3-79H738; je0JCellgl](!$0.c4tr TERMS AND CONDmONST This Work Authorization shau bc govorned by the terms and conditions set forth in thc Statc of Utah Contract between thc Utah Department of Environnpntal Qualiry/Division of Radiation Conrol and URS Safcty Managcrnent Solutions, effective January l' 2Ol l. llPage By: SIGNATIJBES: CUSIIDMER AIITEORIZATTONT Brrcrgr Firols Rasourccs, IDc. Authorizcd Rcprerntative URS - hofcssional Solutions ,a \,,a \ t3 Date RMLNo.UTl9m{79 2lPage APPENDTX A REVISION 3 TO MEMORANDI.]M OF AGREEMENT BETWEEN urAH DryIsIoN oF RADIATION CONTROL (UDRC) AND EIIERGY F'UELS RESOT RCES (USA) fNC. (formerly Denison Mines ruSA) Corp.) [Consisting of this TOWA Revision document and ttre associated Attachment 5 to "Mcmorandum of Agreenrcnt between Utah Division of Radiation Control urd EI.IERGY FLTELS RESOLTRCES (USA) INC. [fonrprly Denison Mines (USA) Corp.]", Relating to review of 'tevised Infiltration and Contaminant Transport Modeling Report; White Mosa Mill; Blanding Utah" (dated March 2010) ud "Reclarnation Plaq Whia Mesa Mill; Blanding, Utah; Radioactive Marcrials License No, fIIl90O479", Rev. 5.0 (dated September 201l) and Analysis Working Session, Aprit 30, 20131 Doted Septcmber 19, 2013 Description ofi, and basis for, required additiorul ldor costs and/or etcpenses: Tbis additional scope and cost authorization provides additional funds to allow URS rpview of an additional docunpnt and drta, as rcquested by the UDRC, that have been or that will be fansmittcd to tho UDRC by Encrgy Hrcls Resources (USA) Inc., that are relatcd to thc Revised Rpclamstion Plut (Rov 5.0) and Revised Ilrfiltration and Contaminant Transport Mo&ling Report The docurrcnt and data to be rcviewed provide additional information EFRI intends to addrcss in EFRIs future responses to two TechnicalMemoranda issued by the LJDRC based on IJDRC's and URS's previous roviow of the 'Bevis€d Infilbation and Contaminant Transport Modeling Reporq \Mhite Mesa Mill; Blanding Utah" (dated March 20lO) Erd'Rpclamation Plan; White Mesa Mill; Blarding, Utatr; Radioactivo Matcrials License No. UT1900479', Rev. 5.0 (dated September 201l) and/or in responsc to issues or cotutrents discussed at an associated April 30, 2013 Analysis Working Session. The cpecific document and datE to be reviewed by IIRS include: l. Ecrt761fion olsharWave Velocity, Wite Mesa MiU tDtfil- EFRI docurnent datcd July 17, 20t32. The followiug tailings characterization data to be acquired by EFRI Pursuant O npthods and nreans describod in ttre Tailings Characterization and Analysis Work Plan, datcd Junc 2013: Gcorcchnlcal Leboretory Tcrr Ertlmltad No. olTlltr ASTItl Standard Nalural t{oleture frntont and Demitv 24 ASTM D221e and D2937 Padlcle Stss (slet€ and Mrcmeler 12 ASTM TX22 Pert6'le Slzo (8le\r€ and No. zo0 wash) 12 ASTM D6913 Soeclfic Gravttv o ASTM D854 AtteltamLlmlb ASTM D.1218 Pemeabllltv Tect ASru DSOA' Consolldalon Teat 6 ASru D2'ft]5 URS understands that the tailings characterization data are being obtained to help clarify the tailings stratigraphy and rmasure the physical propertix associated with tailings consolidation, settlernent, and pore waterdrainage. According to the Tailings Characterization and Analysis Work Plan, the characterization methods will include Cone Penetration Test (CP$ soun.linp, direct push saryling and geotechnical laboratory tcsting on selected representative tailings samples. Following cornpletion of the rcview of the Draft Bstimation of Shear lVave Velocity document and rcview of the fututt tailings characterization data, URS wilt ptovide a Technical Memorandum documenting each neview task including ury wriuen comments or questions arising ftom the rcviews. The cost estirnate provided here includes: (l) costs for a IJRS rcviewer - Ivan Wong, seismologist, to rcview and provide written comrnents on thc proposed approach fordetermining shear wave velocities in on-sito zubsurface materials as described in the draft Shear Wave Velocity docurnent (9 pagps); (2) costs for URS rcviewers - a geotechnical engineer (Wade Narin Van Court), and lvan Wong, to rcview the tailings charactedzation data and provide comnrcnts based on that review; and (3) costs for hoject Managernent support for the URS reviows. The total estimated cost for completing the above activities is $ 4,179. Details pertaining to this cost estimate are provided in Attachment 5. This TOWA Revision (Rev. 3) and associated Attachrnent 5 requests an incrcase in the total authorized cost for the work done under the existing MOA by this additional dollar arnount. Depending on the specific characteristics of the tailings characterization data, actual hours incuned by individuals in completing the data rcview described in this TOWA Revision might vary frrom the estirnated hous shown in Attachrpnt 5; however, the total additional budget of 94,179 authorized by this TOWA revision will not be exceeded witbort prior authorization from the tJDRC. € 8U E E5fl o a \o e,.tae{q (aI a (r\Fq 3 ? eE E 6E -fl 6 N sf t(\I L.oe 6rlFl (l)cx €t:oma u') Noolq (f)\o fd 4 U,trtr 6 oF g 62 oE,cl B E tro EaoU EIcl E ctz blEo B trt) a) 5 6Fr.{I (.i 6t.E- E* Eoo EF{ E'i < !r E.ocaA E6i {r;rr EEBEgEg !€EEg EEg{EEE ? E EE'SIE gEE5EEE i E {B#fiE EEBSBgE E H.f ?r eE E EE;E TgE EBsEflEE;u