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Home My WebLink AboutDRC-2012-002583 - 0901a0688033fa63DRC-2012-002583 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 26, 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 Utah Ground Water Discharge Permit No. UGW3700004 White Mesa Uranium Mill - Notice Pursuant to Parts IE 8 c) and IG 3 of the Permit Dear Mr Lundberg Pjease take notice pursuant to Parts IE 8.c) and IG 3 of the White Mesa Mill's (the "Mill's") State of ^Utah Groundwater Discharge Permit No UGW370004 (the "Perimt"), that Energy Fuels Resources (USA) Inc ("EFRP'), as operator of the Mill and holder of the Permit, identified and repaired damage to the Cell 4A Liner System as descnbed in more detail below Repairs to the Imer were completed and tested on December 20 and 21, 2012, in accordance with Section 9 4 of the approved June 2007 Geosyntec Consultants Cell 4A Construction Quality Assurance Plan. The cell remained in service during and after the repairs 1. Facts and Background Information a) Part LE 8 c) of the Penmt requires that the licensee conduct daily inspections for each of the tailings cells and weekly inspections of Roberts Pond According to Part IE 8 c) " all repairs to the liner shall be completed in accordance with Section 9.4 of the approved June 2007 Geosyntec Consultants Cell 4A Construction Quality Assurance Plan as found in Table 5 of this Permit The Liner Repair Report shall be submitted to for [sic] Director approval m accordance with Part IF 3 of the Permit. Repairs shall be performed by qualified liner repair personnel and shall be reported in a Liner Repair Report, certified by a Utah licensed Professional Engineer Any leak, hole or other damage to the liner will be reported to the Director pursuant to the requirements found m part IG 3 " b) Although Part l.G 3 of the Penmt is stated to apply to circumstances where the Permittee Letter to Rusty Lundberg December 26, 2012 Page 2 of4 fails to maintain Discharge Minimization Technology ("DMT") or Best Available Technology ("BAT") standards. Part LE 8 c) requires that the notification provisions of Part IG 3 also apply to liner defects or damage, regardless of whether or not the liner defect or damage constitutes a failure of DMT or BAT. Under Part IG 3, the Permittee is required to subimt to the Director a notification and descnption of the defect or damage orally within 24-hours of the Permittee's discovery, followed by wntten notification within five calendar days." c) The Mill expenenced freezing temperatures for most of the week of December 17, 2012 Temperatures reached single digits on December 19, 2012 d) On December 19, 2012 a transformer supplying power to the Cell 1 area failed The imll managed this power interruption by temporary installation of two portable generators on December 20, 2012 This incident was descnbed in EFRI's telephone notification to DRC on December 19, 2012, and wntten notice of December 21, 2012 e) Several times on December 20, 2012, power to several of the tailings cells was temporanly interrupted and restored several times The interruptions, which were of bnef duration, did not last long enough to interrupt required monitonng activities or require reporting to DRC However the interruptions required considerable additional maintenance activity on and near the cell dikes to (i) inspect transformers, (u) inspect and replace power lines on and near the cells, (in) inspect momtonng devices and transfer lines for potential freezing dunng the bnef, recurring power outages. f) In the late afternoon of December 20, 2012, maintenance identified a minor tear in the Imer of Cell 4A near the center of the north dike, above the level of any tailings sands 2. Actions taken The following actions were taken following identification of the liner tear a) Mill maintenance personnel immediately repaired and tested the Cell 4A liner on December 20, 2012. b) On December 21, 2012, dunng the moming status update addressing power issues and repair activities in the tailings area. Mill maintenance advised Mill environmental personnel that a liner tear had been identified and had been repaired late on December 20, 2012 c) Dunng a regular update of Mill power loss response activities on December 21, 2012, Mill environmental personnel advised Corporate Environmental personnel of the liner tear and repair. Letter to Rusty Lundberg December 26, 2012 Page 3 of 4 d) Initial notice of this outage was given by telephone to Mr. Ryan Johnson of DRC at approximately 3 25pm on Fnday December 21, 2012 (within 24 hours of Corporate personnel receiving notice, and within 24 hours of Mill environmental personnel receiving notice) 3. Actions Taken to Prevent a Recurrence of This Incident The following actions will be taken to prevent a reoccurrence of this incident. As discussed above, the liner tear was identified, and likely occurred due to, the period of increased maintenance activity associated with response to freeze-related failures of older power equipment The older power transformers have been replaced with new and/or upgraded equipment. Affected older power lines installations have been upgraded by re-installing the power lines inside HDPE pipe conduit for additional protection from traffic and weather It is anticipated that these provisions will prevent a recurrence of the multiple simultaneous failures that required traffic on the liner dunng December 19 through 21, 2012 4. Required Reporting As required by Part I E.8 c) of the penmt and by the approved June 2007 Geosyntec Consultants Cell 4A Construction Quality Assurance Plan, a repair report will be submitted to the Director with the next quarterly DMT Report following completion of the repairs. Repairs were completed dunng the fourth quarter of 2012 The repair report will be submitted with the fourth quarter 2012 DMT Report on or before March 1, 2013 The repair report will contain, m addition to a root cause analysis, the following elements • Repair narrative descnbing the nature of the damage and the repair work completed to repair the damage Repair matenal type used to complete the repair Repair matenal descnption Post repairs test specifications Test Methods (ASTM or other) Daily reports dunng the repair work Repair test results Quality Assurance/Quality Control Information 5. Affirmative Defense EFR does not believe that identification of a defect or damage to the Cell 4A Imer caused by maintenance activities and repair of such defect or damage in accordance with the Mill's Liner Maintenance Provisions constitutes a failure of BAT under the Permit Further, the damage to the Cell 4A liner was above the level of any tailings contained m the cell As a result, EFR is not making a claim for an affirmative defense under Part LG 3 of the Permit Letter to Rusty Lundberg December 26, 2012 Page 4 of 4 If you have any questions, please contact me at (303) 389-4132 Yours very truly, ENERGY FUELS RESOURCES (USA) INC. Jo Ann Tischler Manager, Compliance and Licensing cc David C Frydenlund Phil Goble, DRC Dean Henderson, DRC Dan HiUsten Harold R Roberts David E Turk Kathy Wemel