DRC-2022-021142 - 0901a068810e9a41

September 15, 2022
Sent VIA OVERNIGHT DELIVERY
Mr. Doug Hansen
Director
s 2
Division of Waste Management and Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
Salt Lake City, UT 84116
Energy Fuels Resources (USA) Inc. 225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140 www .energyfuels.com
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. Hansen:
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 Division of Waste Management and
Radiation Control ("DWMRC") of a temporary outage in seven chloroform capture pumps, as
described in more detail below.
The Mill's Chloroform Pumping O&M Plan states that EFRI will notify DWMRC of system
failures that cannot be made operational within 24 hours of discovery. The outage was noted on
Monday September 12, 2022. It was determined on Tuesday September 13, 2022 that the failure
would require more than 24 hours to be repaired. Initial notice of this outage was given by
telephone via voicemail to Mr. Dean Henderson of the DWMRC at approximately 7:40 am on
September 13, 2022 (within 24 hours of the discovery). EFRI spoke with Mr. Dean Henderson
at approximately 9:35 am on Tuesday September 13, 2022.
1.Description of the Pumping System Failure
a)The Mill's Chloroform O&M Plan, Revision 2.6 dated May 18, 2022 states that EFRI
will notify DWMRC of system failures that cannot be "repaired and fully madeoperational within 24 hours of discovery."
b)During the weekly high volume air monitor filter exchange on Monday September 12,2022, EFRI Environmental Personnel noted that a power pole on the southern portionof the site had blown over and that power lines were severed.
DRC-2022-021142
Letter To Doug Hansen September 15, 2022 Page 2 of 3 c)Mill Environmental Personnel noted that there was no power to the high volume airmonitoring station and called in the outage to Mill Maintenance Personnel.Environmental Personnel began checking the chloroform pumping wells served by thatpower line and noted seven pumping wells were without power and not operating. Theseven pumping wells without power are:•MW-4;•TW4-1;•TW4-2;•TW4-4;•TW4-11;•TW 4-40; and•TW4-41.2.Root CauseThe root cause of the downed power pole was likely a high wind event at the Mill site. The wind likely caused swaying of the power lines and failure of the pole due to wind. 3.Steps Taken to Repair and Have the System Full OperationalUpon observing that the power pole and lines were downed, Mill Environmental Personnel did the following: a)The Mill Maintenance Department was contacted, and the area was secured for safetypurposes.b)Mill Environmental Personnel completed an assessment of what environmentalmonitoring and environmental management systems were affected by the loss ofpower.c)Mill Environmental Personnel contacted EFRI corporate personnel to report the outageof the chloroform pumping wells.d)Mill Maintenance Personnel contacted the Power Company, Rocky Mountain Power.Because the power poles are on EFRI property, EFRI then contacted an electricalcontractor to start replacement of the downed pole. EFRI has contracted with twoelectrical contractors on September 12, 2022 to replace the downed power pole andaddress recurrence as noted in Section 6 below.4.Period of Time the System Was Not in OperationBased on the data available from the high volume air station, the power pole failed the evening of September 9, 2022, therefore, the pumping system has not been operational since that time.
Letter To Doug Hansen September 15, 2022 Page 3 of 3
5.Date by Which the Pumping System Will be Repaired and Operational
Based on the estimates from the electrical contractor, the pole replacement and line work is
expected to be complete on or before September 19, 2022.
6.Steps Taken to Prevent a Recurrence of System Failure
EFRI has contracted with two electrical contract companies to address the downed power pole and lines. Recapture Drilling addressed the immediate concern of the downed power pole through replacement of the existing pole only. The span from the failed pole to the next pole is a somewhat long distance. The distance is acceptable, but in an effort to prevent recurrence by making the lines less subject to sway from wind events, two poles will be installed to shorten the span of power lines between the poles. Cache Valley Electric will shorten the span between poles at a future time when the power poles and wire become available. In addition, Cache Valley Electric will inspect the poles on the southern area of the site and replace any poles and power lines that they feel need to be replaced as part of a preventive maintenance strategy. Again, the replacement of additional poles will be completed as equipment becomes available.
If you should have any questions regarding this notice, please contact me.
Yours very truly, �Yrtiui
ENERGY FUELS RESOURCES (USA) INC.Kathy Weinel Director, Regulatory Compliance
CC: David Frydenlund Logan Shumway Scott Bakken Garrin Palmer Tanner Holliday Jordan App