DRC-2019-003322 - 0901a06880a16282

State of Utah
GARY R. HERBERT
Governor
Spencer J. Cox
Lieutenant Governor
Department of
Environmental Quality
Alan Matheson
Executive Director
DIVISION OF WASTE MANAGEMENT
AND RADIATION CONTROL
Ty L. Howard
Director
7izt-20/9-003322_
MEMORANDUM
TO: File C-2019-35
THROUGH: Phil Goble, Section Manager PE 4c).-53
FROM: Russell J. Topham, P.E.
DATE: April 10, 2019
SUBJECT: Engineering Module 70, Annual Surety Review, Energy Fuels Resources (EFRI), White
Mesa Mill, Blanding, Utah.
On March 6, 2019 the Utah Division of Waste Management and Radiation Control (DWMRC) received the
2019 surety update for the White Mesa Mill (dated March 1, 2018, eDocs # DRC-2019-002245). The
proposed surety represents an increase of $416,044 from the approved 2018 surety value of $19,759,960.
I recommend approving the 2019 surety in the amount of $20,176,004.
Comments
No new issues or items of work were introduced in the 2019 surety, and no decommissioning took place
during 2018. The approach to the surety mirrors the approved 2018 surety, with no change in methods or
breadth of coverage. The principal changes to the surety from 2018 include adjustments to fuel, labor and
equipment rental costs.
During the 2018 surety review the Division found an error in Haul Route J-J which the surety showed
canying material to Cell 4B which was supposed to go to Cell 4A. Correcting the destination point for this
haul route and re-mapping resulted in a slightly longer haul, but the resulting adjustment in cost was
negligible, and so correction was deferred. The 2019 submittal reflects this adjustment.
No conventional ore runs are anticipated in 2019. The company has included funds to handle the
maximum quantities of alternate feed the licensee expects to see on site.
Unit costs have been updated, partly through applying the CPI-U deflator to costs actually experienced
during the 2017 Cell 2 radon barrier installation, where applicable. All vendor bids but one were updated
in 2018. With the 2019 update, all vendor bids have been updated within the required 3 year window.
The breadth of coverage provided is consistent with that required of other licensees. Items of work include
mobilization, demolition and disposal of office facilities, mill decommissioning and disposal,
decommissioning of all tailings and fluid management impoundments with Impoundment 1 used for
195 North 1950 West • Salt Lake City, UT
Mailing Address: P O. Box 144880 • Salt Lake City, UT 84114-4880
Telephone [phone] • Fax [phone] • T D.D. [phone]
www.deq.utah.gov
Printed on 100% recycled paper
C-2019-35
Memorandum: 2019 Surety Review
Page 2
uncontaminated waste and Impoundment 4B cleaned up for unrestricted release. The licensee has included
budget allowances for project management and legal support, 10 years of active post-closure monitoring,
long-term care, contractor's profit, licensing and bonding, contract administration, redesign, automobile
and general liability insurance, and equipment rental.