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Home My WebLink AboutDRC-2012-002550 - 0901a06880339544DRC-2G12-002550 ENERGYFUELS Energy Fuels Resources (USA) Inc 225 Union Blvd Suite 600 Lakewood, CO, US. 80228 303 974 2140 www energyfuels com VIA EMAIL AND OVERNIGHT DELIVERY December 21, 2012 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 Lake City, UT 84116-4850 Re: White Mesa Uranium Mill - Notice of Violation and Corrective Action Order UDEQ Docket No. UGW-20-01 Notice Pursuant to the Chloroform Pumping Well Operations and Maintenance Plan Dear Mr Lundberg Pursuant to the White Mesa Mill's (the "Mill's") Chloroform Pumping System Operations and Maintenance Plan ("Chloroform O&M Plan") Energy Fuels Resources (USA) Inc , ("EFRI") as operator of the Mill, is providing written Notice to the Utah Division of Radiation Control ("DRC") of a temporary outage in two chloroform capture pumps, as descnbed in more detail below The Mill's Chloroform Pumping O&M Plan states that EFRI will notify DRC of system failures that cannot be made operational withm 24 hours of discovery It was determined on Wednesday, December 19, 2012 that a transformer failure had occurred which would require more than 24 hours to be repaired The failure shut down electrical power to two chloroform continuous pumping wells which will be off (not pumping) until the transformer is replaced or an interim source of power is provided Imtial notice of this outage was given by telephone to Mr Dean Henderson of DRC at approximately 3 40 pm on Wednesday December 19,2012 (v^thm 24 hours of the discovery). 1. Description of the Pumping System Failure a) The Mill's Chloroform O&M Plan, submitted on October 25, 2010 and currently under review by UDEQ, states that Denison will notify UDEQ of system failures that cannot be "repaired and fully made operational within 24 hours of discovery " b) The Mill expenenced freezing temperatures for most of the week of December 17, 2012 Temperatures reached single digits on December 19, 2012 Letter to Rusty Lundberg December 21,2012 Page 2 of4 c) One of the power circuits to the Cell 1 area supplies power to MW-26 and TW4-20 This circuit includes a transformer near the Mill's truck shop d) Mill personnel discovered, at approximately 10*30 am on December 19, 2012, that the truck shop transformer had failed when power to several areas of the Mill, including the tailings area, failed. e) MW-26 and TW4-20 pumps stopped when power was lost There was no apparent damage to the pumps or flow measurement instrumentation; however pumping will cease until power can be restored to the affected circuit f) Dunng the mormng of December 20, 2012, Mill management determined that a replacement for the damaged transformer would require up to 2 weeks or longer for delivery to the Mill site g) On December 20, 2012, Mill management began moving gasoline dnven generators to supply the Cell 1 area and reactivate the well pumps until the replacement transformer amves and is installed Installation ofthe generators was completed dunng the night shift on December 20, 2012. The well heat lamps were tumed on to thaw any frozen well water h) Immediately following confirmation that no frozen areas remained in the pumping system, the well pumps were tumed back on at approximately 3 00 pm on December 21,2012 2. Root Cause The root cause analysis is as follows a) A failed transformer caused a loss of power to the circuit which includes MW-26 and TW4- 20 b) The replacement transformer could not be acquired and installed within 24 hours ofthe initial power loss c) The installation of the temporary generator and thawing of the well piping prior to resumption of pumping required longer than 24 hours 3. Period of Time the System Was Not in Operation At the time of wnting of this Notice, the pumps ceased operation for approximately 54 hours from December 19 to 21, 2012 Letter to Rusty Lundberg December 21, 2012 Page 3 of 4 4. Date By Which the Pumping System Will Be Repaired and Operational Pumping was resumed on December 21, 2012 5. Steps taken to Repair and Have the System Fully Operational a) Mill maintenance personnel isolated the failed electncal circuits on December 19, 2012 b) Mill maintenance personnel located on site several portable gasoline-dnven electnc generators throughout the day on December 20, 2012 c) Two generators were placed at the Cell 1 area on December 20, 2012 One generator was vsdred to supply both of the affected pumping well pump motors d) Maintenance personnel set up the heat lamps to thaw any potential frozen piping around the two affected well pumps e) The two affected well pumps were tumed on and resumed pumping at approximately 3 00 pm on the mormng of December 21,2012 f) The portable generator supplying the two affected well pumps will be left in place until the replacement transformer amves, is installed, and power is restored to the Cell 1 area electncal circuit 6. Additional Factors to Be Taken into Account Although this incident does not fall within UAC R317-6-6 16, EFRI believes that the following should be taken into account by DRC in evaluating this incident a) Notification By virtue of the initial oral notification given to DRC at 3 40pm on Wednesday December 19, 2012 (within 24 hours of the discovery) and this written notice, EFRI has submitted notification according within five days b) Failure was not Intentional or Caused by EFRI's Negligence The failure of the pumping system was not due to negligence on the part of EFRI or Mill personnel The failure resulted from an unavoidable condition, specifically, failure of a transformer occumng dunng continued freezing weather c) EFRI has Taken Adequate Measures to Meet the Conditions of the Chloroform O&M Plan EFRI has taken adequate measures to meet Permit conditions in a timely manner Mill personnel notified Corporate Compliance personnel within hours of the incident. DRC was notified on the same Letter to Rusty Lundberg December 21, 2012 Page 4 of 4 day as the incident, and within 24 hours. Mill personnel immediately located and ordered a replacement transformer. Mill personnel located and moved temporary generators to the Cell 1 and well pump area within hours of determining that delivery time for the replacement transformer Hookup ofthe generator for the two affected pumps, thawing ofthe line, and restart ofthe well pumps was performed within less than three days from the initial power loss. d) The Provisions of UCA 19-5-107 Have Not Been Violated The provisions of Utah Code 19-5-107 have not been violated There has been no discharge of a pollutant mto waters ofthe state EFRI has not caused pollution which constitutes a menace to public health and welfare, or is harmful to wildlife, fish or aquatic life, or impairs domestic, agncultural, industnal, recreational, or other beneficial uses of water, nor has EFRI placed or caused to be placed any waste in a location where there is probable cause to believe it will cause pollution If you have any questions, please contact me at (303) 389-4132 Yours very tmly. ENERGY FUELS RESOURCES (USA) INC. Jo Ann Tischler Manager, Compliance and Licensing cc David C. Frydenlund Phil Goble Dean Henderson, DRC Dan Hillsten Harold R Roberts David E Turk Kathy Weinel Attachments