DRC-2014-004224 - 0901a06880462d29

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ENERGYFUELS JUL 20U
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Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www,energyfuels.com
July 2, 2014
Sent VIA OVERNIGHT DELIVERY
Mr. Rusty Lundberg
Division of Radiation Control
Utah Department of Environmental Quality
195 North L 950 West
P.O. Box L44850
Salt Lake City, UT 84L L4-4820
DRC-2014-004224
Re: Energy Fuels Resources (USA) Inc. Monitoring Well Repair Notification for MW-28
at White Mesa Uranium Mill, Blanding Utah
Dear Mr. Lundberg:
On May 28, 2014, Energy Fuels Resources (USA) Inc. ("EFRI") notified Utah Division of Radiation
Control ("DRC") personnel of damage noted to Monitoring Well 28 ("MW-28"). The damage was
noted by EFRI Environmental Staff during routine, quarterly sampling activities. This letter
documents the investigation into the cause of the damage and the repairs completed.
Incident Description
• On May 28, 2014, during routine, quarterly, sampling activities, EFRI Environmental Staff
noted damage to MW-28. Upon arrival at MW-28, EFRI Environmental Staff noticed that the
there was evidence that a vehicle had struck the outer protective metal casing of MW-28 and it
was slightly bent and leaning to the west (see Photograph Number 1). Inspection of the inner,
10-inch PVC protective casing and the 4-inch well casing also showed signs of damage. The
concrete seal between the 10-inch casing and the 4-inch casing was cracked and EFRI
Environmental Staff noted that the 2 inner PVC casings were likely cracked and/or broken.
• The Environmental Staff noted that the metal casing lid was broken off (see Photograph 1) and
a portion of the dedicated pump tubing had slipped into the well. The tubing was retrieved.
When the static water level was measured, approximately 2 feet of the probe and tape were
covered with mud and debris.
Letter to Rusty Lundberg
July 2, 2014
Page 2
• Upon discovery of the damage on May 28, 2014, EFRI Environmental Staff contacted the
EFRI Quality Assurance Manager ("QAM") via text message. The EFRI QAM notified DRC
personnel in person, while at the DRC offices in Salt Lake City.
• An incident investigation was started on May 28, 2014 in response to the damage to MW-28.
Incident Investigation Results
• There was an incident on the weekend on May 17, and May 18, 2014 that involved a pickup
truck. The pickup truck was found with damage to the right passenger side bumper and rear
right tire on May 19, 2014. The bumper was dented and the fiberglass broken. The employee
in possession of the pickup truck stated that a rock had done the damage.
• Immediately upon discovery of the damage to MW-28 on May 28, 2014, the Operation
Superintendent took the damaged truck out to the well and the damage on the bumper matched
the damage on the casing. The employee was contacted for further details to discuss the latest
findings and observations.
• The employee again stated that the damage resulted from hitting a rock. Surveillance video
from May 17 through May 19, 2014 was reviewed. The video confirmed the timeframe of the
damage and indicated that the source of the damage was not a rock. The employee was
terminated.
Summary of Repairs
• On Monday, June 2, 2014 Environmental Staff and Bayles Exploration examined MW-28 to
assess the damage and determine if the well could be repaired.
• On June 2, 2014, a backhoe was used to excavate the perimeter of the well casings to expose
any damage. Damage to the outer steel protective casing, the 2-inner PVC casings, and the
sealing concrete between the 2 PVC casings was noted at approximately 3.5 feet below ground
surface ("bgs"). The broken section of all three casings was removed during the excavation
(see Photograph 2 and Photograph 3).
• Concrete chips and PVC debris fell into the well during the excavation and wedged the
dedicated pump in place.
• The dedicated pump lines were attached to the backhoe bucket in an effort to retrieve the
pump. The pump was successfully retrieved with no additional damage to the well. The pump
and all sampling lines were discarded (see Photograph 2).
Letter to Rusty Lundberg
July 2, 2014 '
Page 3
• After the pump was removed, the well opening was covered to prevent any further debris from
falling into the well (see Photograph 4).
• The 2 PVC casings and the sealing concrete were cut with a utility saw to provide a straight
edge for the repairs (see Photographs 5 and 6).
• The inner 4-inch casing was repaired using a "slip cap" to join the old casing and the new
casing (see Photographs 7 and 8). Glues and adhesives were not used when joining the casings
• A new piece of 10-inch outer PVC casing was added to the well (see Photograph 9). The new
casing was joined to the old casing using a "bell joint". Glues and adhesives were not used
when joining the casings.
• Well plug (cement) was added between the 4-inch and 10-inch casing (see Photograph 10).
• A new outer steel protective casing was added.
• On June 5, 2014, Bayles Exploration removed the debris in the bottom of the well resulting
from the damage. The Environmental Staff then overpumped the well and removed over 4
casing volumes to redevelop the well (Attachment A).
• The new measuring point on the top of the casing ("TOC") was surveyed by a Registered Utah
Land Surveyor (Attachment B).
• The well was sampled and the routine, second quarter sample was collected on June 18, 2014.
If you should have any questions regarding this submittal please contact me.
Yours very truly,
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
cc: David C. Frydenlund
Harold R. Roberts
David E. Turk
Dan Hillsten
and slip cap.
Photographs
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Attachment A
OVERPUMPING WELL DEVELOPMENT DATA
DTtO
"7£. SO
Well Number:
Initial Depth to Bottom (0.01ft): I OS Initial Depth to Bottom (0.01ft):.
Initial Depth to Water (0.01ft): 7^*-^"^ Final Depth to Bottom (0.01ft):_
Date Installed: Well Number: /ALO - Zg1
Pump Type: /> r^>^-
Date
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Time
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Volume of
Water Removed
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Pump Rate: \ I d-tV-^ Casing Volume: I^.ZS
pH
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7-^7 7,25
Specific
Conductance
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Temp
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Turbidity
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Notes (color, clarity,
particulates etc.)
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Casing Volume Calculation:
Volume (in gallons) = (h)(cf)
Where:
h = height of the water column in feet
cf = Conversion factor (2 inch = 0.1632, 3 inch = 0.3672, 4 inch = 0.6528, 6 inch = 1.4688)
Attachment B
fMe ENERGY FUELS
Energy Fuels Resources (USA) Inc.
850 East Highway 89A, PO Box 897
Fredonia, AZ 86022
928 643 6185, fax [phone]
www.energyfuels. com
June 12, 2014
Energy Fuels Resources (USA) Inc.
c/o Garrin Palmer
6425 South Highway 191
P.O. Box 809
Blanding, Utah 84511
Garrin,
Attached are the following:
1. Monitoring Wells May 2014
SURVEYOR'S CERTIFICATE
I, Michael W. Purdy a Registered Utah Land Surveyor do hereby certify that I hold a license in accordance
with title 58, chapter 22, professional engineers and land surveyors licensing act, Utah code annotated, 1953
as amended, certificate no. 334571.1 further certify that these reports correctly show a survey made under my
direct supervision.