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Home My WebLink AboutDRC-2015-001001 - 0901a068804d6056ENERGY FUELS Energy Fuels Resources (USA) Inc. 225 Union Blvd. Suite 600 Lakewood, CO, US, 80228 303 974 2140 www.energyfuels.com January 5, 2015 VIA EMAIL AND OVERNIGHT DELIVERY Mr. Rusty Lundberg Director of the Utah Division of Radiation Control DRC-2015-001001 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 six chloroform capture pumping wells, as described in more detail below. The Mill's Chloroform Pumping O&M Plan states that EFRI will notify DRC of malfunctions or abnormal operations that cannot be made operational within 24 hours of discovery. It was determined on Monday, December 29, 2014 that unscheduled down time had occurred which would last more than 24 hours. The down time was the caused by frozen transfer lines resulting from system/water line upgrades necessary to add three more continuous pumping wells to the chloroform pumping network. The down time during construction caused six continuous pumping wells to be off (not pumping) until the completion of construction. Initial notice of this outage was given by telephone to Mr. Phil Goble of DRC at approximately 1:00 pm on Monday December 29, 2014 (within 24 hours of the discovery). 1. Description of the Pumping System Outage a) The Mill's Chloroform O&M Plan, approved by DRC on April 8, 2013 states that EFRI will notify DRC of malfunctions or abnormal operation that cannot be "repaired and fully made operational within 24 hours of discovery." b) Pursuant to the draft chloroform Corrective Action Plan ("CAP"), EFRI voluntarily began conversion of chloroform wells TW4-1, TW4-2, TW4-11, and from monitoring wells to continuously pumping wells. Letter to Rusty Lundberg January 5, 2015 Page 2 of 4 c) The conversion of TW4-1, TW4-2, and TW4-11 from monitoring wells to continuously pumping wells required that the discharge lines be up-sized from a 1-inch line to a 4-inch line in order to handle the additional pumped water. d) The up-sizing of the discharge line required that the old 1-inch lines be excavated while the 4- inch lines were connected. During the excavation the 1-inch lines, which were still connected to the existing pumping system, were exposed to the elements in the open trench. e) The Mill experienced below freezing temperatures for most of the week prior to December 29, 2014. f) Pumping wells MW-4, MW-26, TW4-4, TW4-20, TW4-22, and TW4-24 discharge into the line that was exposed during the construction. When the discharge line froze during the up- sizing, the pumping in these wells was temporarily stopped. g) Mill personnel discovered, at approximately 10:30 am on December 29, 2014, that pumping in MW-4, MW-26 and TW4-4 had stopped due to the discharge line freezing. h) Mill personnel notified the EFRI Quality Assurance Manager ("QAM") of the cessation of pumping. i) The EFRI QAM notified Mr. Phil Goble of DRC at approximately 1:00 pm on Monday December 29, 2014 of the cessation of pumping. j) Mill personnel notified the EFRI QAM at approximately 3:00 pm on Monday December 29, 2014 that three additional wells which discharge to the exposed line had also frozen. The three additional wells are: TW4-20, TW4-22, and TW4-24. k) All of the pumps stopped when the discharge lines froze. The pumps were manually disconnected to prevent damage to the pumps or flow measurement instrumentation. 1) Upon completion of the construction and thawing of the line (if necessary), the pumps will be reconnected and the system will be placed back into service. It is anticipated that the pumping system will be back in service on or before January 9, 2015. 2. Root Cause The root cause analysis is as follows: a) A frozen discharge line caused the temporary outage and cessation of pumping. b) Due to the length of the discharge line, cold weather challenges, and the additional piping needed for the three new pumping wells, the construction could not be completed within a 24 window. Letter to Rusty Lundberg January 5, 2015 Page 3 of 4 3. Period of Time the System Was Not in Operation The pumps ceased operation on December 29, 2014. It is anticipated that the pumping system will be fully operational on or before January 9, 2015. 4. Date By Which the Pumping System Will Be Repaired and Operational Pumping is expected to resume on or before January 9, 2015. This incident will be discussed in the appropriate quarterly chloroform reports as required by the Chloroform O&M Plan. 5. Steps taken to Repair and Have the System Fully Operational a) Construction and up-sizing activities are being completed with all of the resources available at the Mill. b) The system does not require repair and the temporary down time is the result of upgrades to the system and the addition of three pumping wells to the system. The three wells are being added prior to the final implementation of the chloroform CAP on a voluntary basis. 6. Steps Taken or That Will be Taken to Eliminate and Prevent Recurrence of System Failures Since the temporary outage was not the result of a system failure but due to upgrades a formal corrective action is unnecessary. EFRI will strive to complete future system upgrades and pumping system additions in warmer weather as regulatory deadlines allow. 7. 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 1:00 pm on Monday December 29, 2014 (within 24 hours of the discovery) and this written notice, EFRI has submitted notification as required by the EFRI chloroform O&M Plan. 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. c) EFRI has Taken Adequate Measures to Meet the Conditions of the Chloroform O&M Plan Mill personnel notified Corporate Compliance personnel within hours of the incident. DRC was notified on the same day as the incident, and within 24 hours. Mill personnel have dedicated all Letter to Rusty Lundberg January 5, 2015 Page 4 of 4 available resources to the completion of the system additions and upgrades to reduce the amount of time the system is temporarily down. 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 into waters of the 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, agricultural, industrial, 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) 389-4134. Yours very .truly, ENERGY FUELS RESOURCES (USA) INC. Kathy Weinel Quality Assurance Manager cc Phil Goble Dean Henderson, DRC Dan Hillsten Harold R. Roberts David E. Turk