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Home My WebLink AboutDRC-2013-001083 - 0901a0688033fc8cENERGYFUELS -2013-00 108? Energy Fuels Resources (USA) Inc. 225 Union Blvd. Suite 600 Lakewood, CO, US, 80228 303 974 2140 www energvfuels com January 8,2013 Sent VIA E-MAIL AND OVERNIGHT DELIVERY 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: Status Update and Follow-up to Notification Regarding Cell 2 Slimes Drain Freeze Dear Mr Lundberg* This letter is a follow-up to Energy Fuels Resources (USA) Inc 's ("EFRFs") telephone calls to the Utah Division of Radiation Control ("DRC") on January 3, 2013 regarding the effects of freezing weather conditions on the Cell 2 slimes dram transfer pipeline at theWhite Mesa Mill (the "Mill") The Mill's Tailings Management System program commits that EFRI will repair the slimes drain pumping system within 15 days, if it is observed not to be working properly As discussed below, the Mill expenenced an abnormally extended penod of cold conditions during the last two weeks of December and first week of January, which resulted in freeze damage to a number of areas at the Mill, including power transformers supplying Cell 2 Dunng the period of ongoing low temperature, the slimes drain pump and monitoring equipment remained intact, and power was available to the area via a portable generator However, the transfer line to Cell 4A became frozen on December 19, 2012, and due to the extended period of freezing weather, could not be thawed and retumed to operation until January 7, 2013. Although not required by the Tailings Management System program applicable to Cell 2, EFRI has chosen to make the telephone notifications and this follow-up letter for information purposes, to keep DRC apprised of the Mill's efforts to restore the transfer line to operation, and to inform DRC that the line has been thawed and the system has been retumed to service Letter to R Lundberg January 8, 2013 Page 2 1. Facts and Background a) The Mill's Tailings Management System Plan revision 2 1 states that "Cell 2 slimes drain pump is checked weekly to observe that it is operating and that the water level probe and float mechanism are working properly, which is noted on the Weekly Tailings Inspection Form If at any time the pump is observed to be not working properly, it will be fixed or replaced within 15 days " b) The Cell 2 slimes drain solutions are transferred through a 3-inch pipeline to Cell 4A Pnor to December 19, 2012, the pipeline was above ground atop the dikes and/or sands of Cell 2 and Cell 3, discharging into Cell 4A near the dike of Cell 4 A c) Mill personnel conducted the Cell 2 slimes drain quarterly pump test, required by Part ID 3 of the GWDP, from December 11 to December 17, 2012 The pump and transfer line operated properly until after the test was concluded Following shutdown of the pump test, the line froze dunng the evening of December 17, 2012 d) Mill personnel thawed the line with heating torches and retumed it to service during December 18 and 19, 2012 On December 19, 2012, Mill personnel buned the horizontal sections of pipe in 12 inches of borrow soil atop Cell 3 for insulation against potential future freezing weather e) The Mill experienced an extended penod of abnormally cold weather beginning on December 19, 2012 Dunng the evening of December 19, 2012, the Cell 2 shmes drain transfer pipeline froze, even though it had been buned in 12 inches of soil It remained frozen through January 3, 2013 despite additional efforts to thaw the line with heating torches during that period 2. Action Taken a) EFRI contacted Mr Phil Goble of DRC on January 3, 2013 to advise DRC that due to the persistence of the abnormally cold weather and the Mill's inability to thaw the Cell 2 slimes drain pipe, EFRI was unable to perform the Cell 2 slimes drain pump check tests, required by the Tailings Management System program applicable to Cell 2, durmg the weeks of December 21 and 28, 2012 and January 4, 2013 b) Ef^I committed to advise DRC as soon as weather conditions supported thawing of the discharge pipeline c) EFRI comnutted to resume the weekly testing as soon as the pipeline was thawed Letter to R Lundberg January 8,2013 Page 3 d) Mr Goble instmcted EFRI to document the efforts to date, and to advise DRC when a more definitive date for retuming the system to service was known e) EFRI successfully thawed the discharge pipeline and retumed the slimes dram pumping system to service on January 7, 2013 f) EFRI has deterrmned that for future potential freeze situations, a backup transfer procedure involving pumping the Cell 2 slimes drain fluids a shorter distance to exposed tailings sands areas in Cell 3, could be used if weather conditions may prevent performance of the weekly slimes drain pump check The shorter length of transfer line may permit easier thawing and maintenance of slimes drain fluid flow 3. Root Cause The slimes dram transfer pump operates on a float system which tums the transfer pump on when sufficient fiuid has accumulated in the slimes drain system. As a result, the pump, and transfer line, expenence intenmttent, not constant, flow Dunng most of the year, and dunng typical winters, the intemuttent flow is sufficient to prevent freezing of the 3-inch transfer line During the prolonged cold penod in which the ambient temperature remained below freezing dunng the day and as low as single digits dunng some nights, the intenmttent flow was not sufficient to keep the line from freezing, even below the 12 inches of insulating soil 4. Actions Taken to Maintain Compliance EFRI has taken the following steps to retum the Cell 2 slimes drain transfer system to compliance in as short a time as possible a) Notification By virtue of the initial oral notification given to DRC at on Thursday, January 3, 2013, and this written status letter, EFRI has made good faith efforts to keep DRC appnsed of the situation resulting m loss of three rounds of pump checks, as well as efforts to restore the system to operation b) Failure was not Intentional or Caused by EFRI's Negligence The failure to conduct the three missed weekly slimes drain pump checks was not due to EFRI's negligence, either in action or m failure to act The prolonged cold did not afford any opportunity to get the slimes drain discharge line thawed and keep it thawed long enough to put the pump system back m service c) EFRI Has Taken Adequate Measures to Meet Requirements of the Tailings Management System Program Letter to R. Lundberg January 8, 2013 Page 4 EFRI immediately thawed and retumed the slimes drain transfer line to service when it fkst froze During December 18, and 19, 2012 When it became evident that it would not be possible to maintain the system in a thawed and operative condition, EFRI advised DRC and sought DRC's mput on what DRC would require EFRI complied with DRC's requirements as enumerated in Section 2, above If you should have any questions regarding this status report please contact me Yours very tmly. ENERGY FUEMS RESOURCES (USA) INC. Ds^mCj. Frydenlund Senior Vice President, General Counsel and Corporate Secretary CC Scot Chnstianson Jo Ann Tischler Dan HiUsten N Tanner HoUiday Gamn Palmer Harold R Roberts David E. Turk Kathy Weinel