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HomeMy WebLinkAboutDRC-2024-007804Normal Normal Revised Final Groundwater Geochemical Modeling at the White Mesa Uranium Mill Report Contract No. 68HERC20D0029 Task Order No. 68HERC22F0178 Prepared for: U.S. Environmental Protection Agency Region 8 and Office of Research and Development Center for Environmental Solutions and Emergency Response Land Remediation & Technology Division Prepared by: 1701 Pearl Street Suite 200 Boulder, CO 80302 Under subcontract from: 505 King Avenue Columbus, OH 43201 November 22, 2024 Disclaimer: This document is a work prepared for the United States Government by Integral Consulting Inc. under subcontract from Battelle. In no event shall the United States Government, Battelle, or Integral have any responsibility or liability for any consequences of any use, misuse, inability to use, or reliance on any product, information, designs, or other data contained herein, nor does either warrant or otherwise represent in any way the utility, safety, accuracy, adequacy, efficacy, or applicability of the contents hereof. Revised Final White Mesa Mill Geochemical Modeling Report November 22, 2024 Integral Consulting Inc. ii CONTENTS LIST OF FIGURES .................................................................................................................................. iii LIST OF TABLES ..................................................................................................................................... iv ACRONYMS AND ABBREVIATIONS................................................................................................ v 1 Background ....................................................................................................................................... 1-1 2 Report Review .................................................................................................................................. 2-1 2.1 HYDRO GEO CHEM (2012) .............................................................................................. 2-1 2.2 INTERA (2012) ..................................................................................................................... 2-3 3 Geochemical Modeling .................................................................................................................. 3-1 3.1 CONCEPTUAL MODEL .................................................................................................... 3-1 3.2 QUALITY ASSURANCE .................................................................................................... 3-1 3.3 MODELING PLATFORM .................................................................................................. 3-2 3.4 MODEL INPUTS ................................................................................................................. 3-3 3.4.1 Wells Modeled ........................................................................................................ 3-3 3.4.2 Water Chemistry ..................................................................................................... 3-3 3.4.3 Equilibrium Phases ................................................................................................ 3-4 3.5 BASELINE RESULTS .......................................................................................................... 3-5 3.6 POST-BASELINE RESULTS ............................................................................................... 3-7 3.7 MIXING RESULTS .............................................................................................................. 3-8 4 Conclusions ...................................................................................................................................... 4-1 5 REFERENCES ................................................................................................................................... 5-1 Appendix A. Water Quality Time-Series Plots and Summary Statistics Appendix B. Baseline Model Runs Appendix C. Post-Baseline Model Runs Appendix D. Mixing Model Runs Revised Final White Mesa Mill Geochemical Modeling Report November 22, 2024 Integral Consulting Inc. iii LIST OF FIGURES Figure 1. Site and key well locations Figure 2. Observed changes in pH at the Mill (Intera, 2012) Figure 3. Conceptual model Figure 4. Model data flow schematic Figure 5. Carbon dioxide saturation in modeled wells, baseline and post-baseline conditions Figure 6. Baseline model run dashboard plot, MW-11, pyrite 0.8%, calcite 0% Figure 7. Baseline model run dashboard plot, MW-11, pyrite 0.8%, calcite 1.5% Figure 8. Post-baseline model run dashboard plot, MW-24, pyrite 0.8%, calcite 0% Figure 9. Post-baseline model run dashboard plot, MW-24, pyrite 0.8%, calcite 1.5% Figure 10. Post-baseline model run dashboard plot, MW-22, pyrite 0.1%, calcite 0% Figure 11. Post-baseline model run dashboard plot, MW-22, pyrite 0.8%, calcite 1.5% Figure 12. Mixing model run dashboard plot, MW-24, pyrite 0.45%, calcite 0%, leachate fraction 0.5% Figure 13. Mixing model run dashboard plot, MW-24, pyrite 0.45%, calcite 0%, leachate fraction 1 % Figure 14. Mixing model run dashboard plot, MW-24, pyrite 0.45%, calcite 1.5%, leachate fraction 1% Revised Final White Mesa Mill Geochemical Modeling Report November 22, 2024 Integral Consulting Inc. iv LIST OF TABLES Table 1. Summary of selected monitoring wells for geochemical modeling Table 2. Baseline and post-baseline water quality at modeled wells Table 3. Representative containment cell 1 leachate water quality Table 4. Summary of available calcite content data Table 5. Summary of baseline model run conditions Table 6. Summary of post-baseline model run conditions Table 7. Summary of leachate mixing model run conditions Revised Final White Mesa Mill Geochemical Modeling Report November 22, 2024 Integral Consulting Inc. v ACRONYMS AND ABBREVIATIONS CaCO3 calcite CO2 carbon dioxide EPA United States Environmental Protection Agency GWCL groundwater compliance levels H2SO4 sulfuric acid LLNL Lawrence Livermore National Laboratory NH3 ammonia NO3 nitrate O2 oxygen gas ORP oxidation-reduction potential QAPP quality assurance project plan SOW statement of work UDEQ Utah Department of Environmental Quality UMUT Ute Mountain Ute Tribe USGS United States Geological Survey XRD X-ray diffraction Revised Final White Mesa Mill Geochemical Modeling Report November 22, 2024 Integral Consulting Inc. 1-1 1 BACKGROUND The White Mesa Uranium Mill (Mill) is located in southeast Utah, just south of the town of Blanding, Utah (Figure 1). The Mill was constructed in 1979 and was permitted and began operation in 1980 (United States Geological Survey [USGS], 2011; Utah Department of Environmental Quality [UDEQ], 2023). The ore beneficiation process at the Mill is used for the production of uranium and vanadium concentrates (Energy Fuels, 2023; Hurst and Solomon, 2008). This process utilizes sulfuric acid (H2SO4) and ammonia, among other chemicals, as processing aids (USGS, 2011; Intera, 2009). Tailings and solutions from ore processing are, or have been, disposed of in five containment cells at the site (Figure 1). Samples of solutions from one of these cells (specifically, the cell 2 slimes drain) were reported as having a pH of 3, high metals concentrations (e.g., arsenic up to 26.9 mg/L or iron up to 2,900 mg/L), and elevated concentrations of sulfate (up to 74,000 mg/L), nitrate (up to 100 mg/L), and ammonia (up to 4,000 mg/L) (MWH, 2010). Trends of decreasing pH and increasing concentrations of metals have been observed in groundwater monitoring wells in the Dakota and Burro Canyon formations at the Mill (Intera, 2012). These changing conditions have been observed in wells hydraulically up-gradient of the Ute Mountain Ute Tribe’s (UMUT) White Mesa community. Members of the UMUT are concerned that contaminant releases from the Mill have the potential to impact local springs and possibly their public water supply. Springs fed by shallow groundwater from the Dakota and Burro Canyon formations provide water for livestock and wildlife. The public water supply for the White Mesa community is sourced from the deeper Navajo Sandstone aquifer. The UMUT community is concerned that the observed changes in groundwater quality may be associated with a Mill-related contaminant plume. However, the Mill attributes the changes in groundwater quality to oxidation of naturally-occurring pyrite (Hydro Geo Chem, 2012). This report presents the results of geochemical modeling performed to provide insight into the observed changes in groundwater quality at the Mill and the geochemical processes that affect these changes. A technical review and analysis of past geochemical modeling at the Mill is presented in Section 2 below. The data analysis, input preparation, and development of the geochemical model are described in Section 3 below. That section also presents, and discusses, the results of the modeling. The geochemical modeling and associated analyses were performed following the project quality assurance project plan (QAPP, Battelle 2023). Three separate tasks, and the results of each, are described in greater detail in the following sections. The tasks are briefly summarized below: • Task 1 Report review: This task was a technical review of reports prepared by Hydro Geo Chem (2012) and Intera (2012). Those reports include data analysis and geochemical modeling focused on evaluating the observed Revised Final White Mesa Mill Geochemical Modeling Report November 22, 2024 Integral Consulting Inc. 1-2 changes in groundwater quality, with a focus on changes in pH. This review identified key assumptions and limitations. • Task 2 Pyrite oxidation modeling: The purpose of this task was to simulate groundwater chemistry and associated dissolution, precipitation, and oxidation reactions that are likely to occur in the subsurface. Groundwater conditions at the site were divided into two temporal periods. The baseline period (1980–2005) is associated with anoxic groundwater conditions. The post-baseline (2005–present) is associated with the presence of electron acceptors (i.e., oxygen and/or nitrate) that have the ability to facilitate the oxidation of pyrite that naturally occurs in the aquifer matrix. • Task 3 Mixing modeling: The purpose of this task was to geochemically model the mixing of containment cell-associated water with different types and amounts of native groundwater and aquifer materials present at the Mill. Revised Final White Mesa Mill Geochemical Modeling Report November 22, 2024 Integral Consulting Inc. 2-1 2 REPORT REVIEW 2.1 HYDRO GEO CHEM (2012) Hydro Geo Chem (2012) concludes that the changes in groundwater quality at the Mill are driven by the oxidation of pyrite in the subsurface. This oxidation is explained as being driven by the introduction of oxygen to the subsurface as a byproduct of the pumping of groundwater monitoring wells. A field sampling program and a geochemical modeling effort were completed and the resulting data were interpreted by Hydro Geo Chem (2012) as supporting this mechanism. The field sampling program was focused on the mineralogical analysis of drill cuttings and core samples. This review found the Hydro Geo Chem (2012) report and sampling effort to be biased regarding the presence of pyrite, as demonstrated by three observations. First, the sample selection process was focused on analyzing only those samples that were found to, or believed to, contain pyrite—”samples were from depth intervals noted to have pyrite in the lithologic logs or from intervals likely to have pyrite” (p. 18). The consequence of this sampling methodology is that the samples are not representative of the overall characteristics of the aquifer formation; rather they represent pyrite-rich portions of the aquifer formation. Given the sampling bias, these data do not represent the pyrite occurrence across the geologic formation and should be used with caution. This sampling program likely overestimates the pyrite content of the subsurface. Second, the report also attempts to infer the presence of pyrite in samples where none is detected. “Although pyrite was not directly detected by XRD [X-ray Diffraction] in samples from MW-23, MW-25, or MW-29, the detected iron and sulfur in these samples is consistent with the presence of pyrite. While at least a portion of the detected sulfur may result from the gypsum or anhydrite detected in some of these samples, iron not in the form of pyrite would be expected to exist primarily in the form of iron oxides or perhaps iron carbonates. The absence of detected iron oxides or carbonates in samples from these borings suggests iron in the form of pyrite.” (pg. 20) This analysis concludes that one compound (pyrite) must be present even though it is not detected. Yet, Hydro Geo Chem reverses this logic by concluding that two other compounds (gypsum and iron oxides) must be absent since they are not detected. Third, the absence of pyrite is explained by such mechanisms as “oxidation of pyrite within the samples during storage will reduce detected pyrite concentrations, and possibly lead to non- Revised Final White Mesa Mill Geochemical Modeling Report November 22, 2024 Integral Consulting Inc. 2-2 detections in samples that originally contained small amounts of pyrite” (p 15). If oxidation of samples during storage was of concern, minimizing this sample alteration would have been a suggested portion of the sampling and analysis plan. The geochemical modeling performed by Hydro Geo Chem had two conclusions. The first conclusion was that, in the absence of oxygen, pyrite was stable and did not react. The second conclusion was that, in the presence of oxygen, pyrite was oxidized and resulted in decreasing pH and increasing sulfate concentrations. These conclusions are consistent with an understanding of pyrite oxidation mechanisms. However, there were several limitations of the modeling inputs and outputs identified during review of these results. First, it was found that the model input files for all scenarios fixed the pH. As such, the pH input to each model run was identical to the final pH. The report notes that the final pH of the oxygen-containing model runs was lower than the final pH of the oxygen-free model runs. As the pH were fixed these lower pHs are the result of model inputs and not a result of the oxidation of pyrite. Hydro Geo Chem noted that higher sulfate was observed in oxygen- containing model runs. However, the initial model input sulfate for the runs with oxygen was higher than the input sulfate for the runs without oxygen. As with pH, the differences noted for sulfate between model runs are the result of model inputs and not geochemical processes. Second, none of the model input files included the presence of acid-neutralizing minerals such as calcite or dolomite. These minerals have the ability to buffer acidity generated by pyrite oxidation. The sampling presented in the Hydro Geo Chem report (2012) found calcite at concentrations from 0 to 14% and dolomite concentrations at 0 to 4.1%. These concentrations are consistent with more general geological descriptions of the Burro Canyon that found up to 6% calcite cement (Craig, 1982). Further, this is consistent with other mineralogical characterization at the Mill that found calcite present at concentrations from 0 to 18.2% (MWH, 2010). The Hydro Geo Chem report states that the presence of calcite is “accounted for in the simulations (pg. 31)”, yet review of the model input files did not indicate the inclusion of calcite. It should also be noted that the modeling assumed that all of the pyrite was available for immediate reaction. This is generally a reasonable assumption, however, it should be noted that real-world reactions are often limited by the rate of reaction and the physical availability of pyrite for reaction. For example, in some cases pyrite may be coated by reaction-limiting mineral films or located entirely within a second mineral as an inclusion. Third, the geochemical modeling by Hydro Geo Chem assumes that there is no groundwater flow and all generated acidity and sulfate would be retained in the same location. In fact, flow of groundwater in the subsurface would dilute and disperse any generated acidity and sulfate. Revised Final White Mesa Mill Geochemical Modeling Report November 22, 2024 Integral Consulting Inc. 2-3 2.2 INTERA (2012) The Intera report provides a statistical and geochemical analysis of the trends of pH in wells at the Mill site. That report concludes that, in all cases, decreases in pH at the site are explained as the “the result of natural influences and/or the improperly set GWCLs [groundwater compliance limits]”. That report utilizes Hydro Geo Chem (2012) as a buttress for many of its conclusions. Intera (2012) provides a map of pH trends at the Mill that demonstrate that the majority of wells with stable or increasing pH are located upgradient of the Mill, and the majority of wells with decreasing pH are located within or downgradient of the Mill (Figure 2). This observation suggests that conditions within and downgradient of the Mill are different than those observed upgradient. A primary support of Intera’s conclusions is an analysis of nitrate in groundwater. For example, at MW-27 Intera calculates that it would take approximately 11% tailings solution mixing with the groundwater to drive the observed change in nitrate concentrations. This is based upon a tailings nitrate concentration of 290 mg/L. However, nowhere in this analysis are the elevated concentrations of ammonia in tailings leachate discussed. Based upon EPA- provided data 1, the Cell 1 average ammonia and nitrate concentrations are 7,490 mg/L and 166 mg/L, respectively, which indicates approximately 45 times more ammonia than nitrate. The potential for nitrification of ammonia (conversion of ammonia to nitrite and then to nitrate) is ignored in the analysis—and this conversion would result in much smaller mixing ratios. Intera’s analysis is primarily based upon the analysis of chloride and, to a lesser extent, nitrate and fluoride. However, in many wells there is divergence in the trends for individual constituents. Consideration of the complexity of the subsurface, and the multiple potential mechanisms affecting fate and transport, indicates the need for an analysis of contaminant fate and transport utilizing a wider range of constituents to better elucidate patterns and trends. 1 The data provided by EPA is a compilation of publicly available data from the Mill. Data acquired from previous sampling events have been evaluated as part of those specific projects and their associated data quality objectives. These data have been compiled and provided by EPA. Work performed for this project did not include the evaluation of compiled data in a context of data usability or quality review. Revised Final White Mesa Mill Geochemical Modeling Report November 22, 2024 Integral Consulting Inc. 3-1 3 GEOCHEMICAL MODELING This section of the report provides a summary of the two geochemical modeling tasks completed for this project. It begins with a discussion of model setup and inputs and follows with a presentation and discussion of key results. 3.1 CONCEPTUAL MODEL A geochemical conceptual model is used to help develop a site understanding and identify key factors that control and affect the reactions and processes occurring at a site. These identified reactions and processes can then be included in modeling. Following the review of site documents, two key factors were identified. The first factor was the delineation of the model period into two phases—one phase, the ‘baseline’ phase where oxygen is not present and a second phase, the ‘post-baseline’ phase where oxygen is present. The second factor is that the groundwater at the Mill is flowing and not static. Past investigations at the Mill have demonstrated the presence of groundwater plumes of chloroform and nitrate that extend away from the Mill operations area (Hydro Geo Chem, 2014). These plumes are direct evidence of transport. Hydro Geo Chem (2014) also estimates that flow velocities at the facility range from 0.26 to 76 ft/year, which corroborate the observed transport. The geochemical conceptual model described in Figure 3 identifies transport as an important aspect of modeling the system. In this model, the system is divided into five cells (Figure 3). Upgradient water flows into model Cell 1, where water is equilibrated with the atmosphere in the vicinity of a borehole. This water is then subsequently transported downgradient through Cells 2 through 5. Once transported downgradient and past Cell 1, this water is no longer in equilibrium with the atmosphere; however, mineral phases (calcite and pyrite) are available for geochemical reactions. Conceptually, the key factor in this geochemical conceptual model is recognizing that beyond the immediate vicinity of a borehole, transport of oxygen into the subsurface is done through advective (flow-based) transport. 3.2 QUALITY ASSURANCE The data analysis and modeling were performed following the project quality assurance project plan (QAPP, Battelle 2023). The management, handling, and reporting of data were subject to Integral’s Quality Management Program (Integral 2022). Per this guidance, model inputs and outputs were subject to a technical review. Revised Final White Mesa Mill Geochemical Modeling Report November 22, 2024 Integral Consulting Inc. 3-2 3.3 MODELING PLATFORM PHREEQC software version 3.0 was used for all geochemical modeling runs (USGS, 2013)2. After project discussions with the EPA, the Lawrence Livermore National Laboratory (LLNL) thermodynamic database (one of the databases provided with PHREEQC) was selected as the database to be used for all modeling runs. That database provides a well-vetted set of thermodynamic data governing the formation and reaction of a wide-range of elements and minerals. Utilization of the PHREEQC model requires the selection of how to implement mixing, reactions, input water chemistry, and input equilibrium phases. Consistent with the geochemical conceptual model, PHREEQC allows transport of solutions. For this process the ‘advection’ functionality was used for all runs. The ‘advection’ functionality simulates one- dimensional flow and allows for the implementation of all chemical processes modeled in PHREEQC. For the modeling described here, the advection functionality was defined to have five modeled cells and 100 shifts. During each shift, the following transport and reactions occur: • In Cell 1 upgradient water enters and reacts and equilibrates with the equilibrium phases present in that cell, • In Cell 2, water transported from Cell 1 enters and reacts and equilibrates with the equilibrium phases present in that cell, • The processes in Cells 3 through 5 are analogous to those in Cell 2, • Equilibrium phases, that is mineral and gas phases, are not transported and remain for reaction and equilibrium at the cell for which they are defined. Per the PHREEQC utilized methodology, this is the equivalent of transporting 20 pore volumes through the model. The ‘advection’ function does not account for dispersion or diffusion. Increasing grid density and larger numbers of shifts may be appropriate for detailed simulation of in-situ conditions. However, the relatively simple set-up used is sufficient for the evaluation of the key factors identified in the conceptual model—specifically the impact of pyrite, calcite, and oxygen transport in the vicinity of the wells on geochemical conditions. 2 PHREEQC version 3.7.3.15968 was the specific model version. The most-up-to-date version was downloaded aft the USGS website: https://www.usgs.gov/software/phreeqc-version-3 Revised Final White Mesa Mill Geochemical Modeling Report November 22, 2024 Integral Consulting Inc. 3-3 3.4 MODEL INPUTS This section provides a description of the development of model inputs. The overall flow of data through the model and the primary questions at each step are presented in Figure 4. 3.4.1 Wells Modeled Consistent with the statement of work (SOW) a total of five monitoring wells were included for baseline and post-baseline model runs. These wells are (in upgradient to downgradient order): MW-27, -24, -11, -3A, -22 (Figure 1, Table 1). For leachate mixing runs, consistent with the SOW, three wells (MW-27, MW-24, and MW-11) were included in the model. Those wells are located at or immediately downgradient of the Mill containment cells and would be the most likely to directly receive leachate. 3.4.2 Water Chemistry Water chemistry datasets were provided by EPA3. In a PHREEQC model, input water quality represents the initial conditions of the water phase in the model. This modeling effort focused on modeling primary water quality parameters and did not attempt to address a wider range of metals. These data were used to develop two characteristic water quality profiles for each modeled well—a baseline and post-baseline condition.. The constituents included in the model were: calcium (Ca), magnesium (Mg), potassium (K), sodium (Na), iron (Fe), chloride (Cl), fluoride (F), alkalinity, ammonia (NH3), nitrate (NO3), pH, and oxidation/reduction potential (ORP). Representative values were calculated as arithmetic means, with the exception of pH, which was calculated as the geometric mean of proton concentration ([H+]). The use of means as representative values can introduce uncertainty as these calculated values are not perfectly representative of conditions in any one sample. The form of this uncertainty may be shifts in charge balance or saturation indices. However, these representative values are useful in condensing large amounts of data to identify overall geochemical conditions at each well. This simplification is consistent with the conceptual model and intention of the model. Post-baseline ORP values were based upon field-measured ORP, and electron activity (pe) was calculated from the field ORP data using the Nernst equation. In the absence of measured ORP values pe values for baseline runs were set to –3. This assumption is consistent with the conceptual model of baseline conditions having both no oxygen and the presence of pyrite. 3 The data provided by EPA is a compilation of publicly available data from the Mill. Data acquired from previous sampling events have been evaluated as part of those specific projects and their associated data quality objectives. These data have been compiled and provided by EPA. Work performed for this project did not include the evaluation of compiled data in a context of data usability or quality review. Revised Final White Mesa Mill Geochemical Modeling Report November 22, 2024 Integral Consulting Inc. 3-4 Two profiles were developed for each well: baseline and post-baseline conditions. Baseline conditions are representative of groundwater conditions from the 1980-2005 period, characterized by the absence of oxygen and/or nitrate. Baseline conditions provide the initial water quality for all runs (baseline, post-baseline, and mixing; Figure 4). Post-baseline conditions are representative of conditions from the 2006-present period, characterized by the presence of oxygen and nitrate. Post-baseline conditions provide benchmarks for the evaluation of model results. Some well/constituent combinations did not have data prior to 2006; in this case, the first full year of available data was used to characterize the baseline period water quality. Representative water quality for each modeled well is presented in Table 2. Time-series plots of water chemistry for modeled wells are included in Appendix A. For mixing runs, leachate water quality data were provided by EPA. 4 These data were used to develop a water quality profile associated with Cell 1 leachate. Cell 1 leachate was selected as a representative leachate water quality for evaluating the interaction of leachate with different aquifer conditions and water-qualities. Utilization of the same leachate water-quality for all runs provided a basis for simple comparison. Additionally, a comparison of leachate water quality found that leachate from Cell 3 (which is located closest to MW-11) is generally comparable to the leachate in Cell 1. Based on this comparison, it is unlikely that additional runs with multiple leachate profiles would impact the results of the modeling. Representative values were calculated from all available data as arithmetic means with the exception of pH, which was calculated as the geometric mean of proton concentration ([H+]). Leachate water quality is presented in Table 3. Leachate was represented at mixing fractions of 0.1, 0.3, 0.5, 1, 3, 5, and 10%. 3.4.3 Equilibrium Phases In a PHREEQC model, equilibrium phases represent the gas or mineral phases that are available for reactions. The modeling presented here included both mineral and gas phases. Two mineral phases were utilized for reactions in this geochemical modeling5. Pyrite (FeS2) was modeled at concentrations of 0, 0.1, 0.4 and 0.8%. Those concentrations were set in the SOW. The range of pyrite concentrations from the SOW are consistent with those observed at the Mill (Hydro Geo Chem, 2012). The second mineral phase included in the model was calcite (CaCO3). Calcite was modeled at concentrations of 0, 1.5, and 5%. The range of calcite concentrations was 4 The data provided by EPA is a compilation of publicly available data from the Mill. Data acquired from previous sampling events have been evaluated as part of those specific projects and their associated data quality objectives. These data have been compiled and provided by EPA. Work performed for this project did not include the evaluation of compiled data in a context of data usability or quality review. 5 For the purposes of determining the amount of equilibrium mineral phases present, a porosity of 18.2 and a density of 2.47 g/cc were assumed. These values were based on data in MWH (2010) and UMETCO (1993). Revised Final White Mesa Mill Geochemical Modeling Report November 22, 2024 Integral Consulting Inc. 3-5 based on data reported in Hydro Geo Chem (2012) and MWH (2010, Table 3). For model runs, the saturation index control for pyrite was set to 0. The saturation index limit for calcite was set to 0.5; this was estimated based upon the calcite over-saturation observed in the modeled wells. It was assumed that both mineral phases were completely available for reaction. This assumption is consistent with the assumptions used by Hydro Geo Chem (2012, see Section 2.1). This is generally a reasonable assumption, however, it should be noted that real-world reactions are often limited by the rate of reaction and the physical availability of mineral phases for reaction. For example, availability of a mineral phase for reaction may be limited due to coating of a mineral or its occurrence as an inclusion in a larger mineral phase. Two gas phases were utilized for reactions in this geochemical modeling. In those model runs that were oxic (i.e., post-baseline runs), oxygen gas (O2) was included at a partial pressure of 0.2 atm (logarithm of O2 partial pressure {pO2} of -0.67). Both baseline and post-baseline runs utilized carbon dioxide (CO2) as an equilibrium phase. The partial pressure for the baseline and post-baseline conditions was based on the input water quality (Table 2). The input water quality was speciated in PHREEQC to determine the partial pressure at each well under each condition. Under baseline conditions, the PHREEQC-calculated logarithm of CO2 partial pressure (pCO2) in the five modeled wells varied from -1.84 to -2.52 with an average of -2.1 (Figure 5). Under post-baseline conditions, the PHREEQC-calculated pCO2varied from -1.27 to -2.05 with an average of -1.62. Based upon these analyses, baseline runs utilized a pCO2 of - 2.1 and post-baseline runs an index of -1.6. These analyses demonstrate that under both baseline and post-baseline conditions, the groundwater at the Mill is over-saturated with respect to atmospheric CO2 (typical historical pCO2 at sea level is -3.5). For leachate model runs, mid-range pyrite (0.4%) and calcite at 0 and 1.5% concentrations were chosen to represent likely subsurface conditions. For these leachate runs, oxygen was not included. 3.5 BASELINE RESULTS The baseline runs are based upon an anoxic condition that assumes the presence and stability of pyrite. Conceptually, this condition is intended to represent an earlier period of Mill operations, defined in the SOW as 2005 and before, when little or no oxygen was available to the subsurface. Water quality for the five modeled wells was developed as described in Section 3.3.2. A total of 12 runs were completed for each well, with each run defined by a combination of calcite and pyrite concentrations as described in Section 3.3.3 (Table 5). Input, output files, and plots of model results are presented in Appendix B. Under some runs, minimal amounts of calcite may dissolve or precipitate to reach equilibrium. However, this does not substantially affect the resulting water quality. An example of this is for Revised Final White Mesa Mill Geochemical Modeling Report November 22, 2024 Integral Consulting Inc. 3-6 MW-11 where no change is seen in pyrite (Figure 6).6 In some cases, small amounts of calcite may dissolve or precipitate to reach equilibrium between these phases and the surrounding system; however, these subtle shifts do not drive reductions in pH (as an example, see Figure 7 for MW-11). Key species that can indicate reactions and changes in geochemical conditions in this geochemical system include sulfate, fluoride, nitrate, and ammonia. The concentrations of sulfate are unchanged during these runs as no pyrite is oxidized. Further, most wells (with the except of MW-22) are undersaturated with respect to gypsum and so this is unlikely to be a solubility control. Fluorite is over-saturated in MW-22 and may be a likely concentration- controlling phase for fluoride; however, for the other wells, fluorite is undersaturated. Under baseline conditions, all the wells were observed to have concentrations of both nitrate and ammonia (Table 2). Under the reducing conditions that characterize the baseline runs, the modeled equilibrium results in the conversion of any nitrate to ammonia. This result is in contrast to the observed conditions (under both baseline and past-baseline conditions)—where the presence of both nitrate and ammonia in groundwater indicates a redox disequilibrium in this system. This observed disequilibrium is likely the result of biologically mediated reactions (or lack thereof) and are unlikely to be well represented by geochemical modeling of this type. These findings are consistent with those of Hydro Geo Chem (2012), which also found that pyrite was stable under anoxic conditions. In the absence of oxygen, there is no acidity or sulfate generated by the oxidation of pyrite and water quality is unchanged over the course of the simulation (Figures 6 and 7). Variations in the amounts of pyrite or calcite do not affect the results. These results indicate that in the absence of oxygen, pyrite is stable in the subsurface at the Mill. That is consistent with the fact that pyrite does, in fact, occur in the subsurface as documented by Hydro Geo Chem (2012). Further, it is observed that the water quality at wells MW-27, MW- 24, MW-11, and MW-3A are over saturated with respect to calcium carbonate. This is consistent with the observations of calcite in some wells and the occurrence of calcite as a cementitious phase in the Burro Canyon formation (Craig, 1982). 6 These ‘dashboard’ plots show six individual sub-figures. Each sub-figure presents model results for each of the five model cells over the first 50 advection steps. The top two figures are pH and sulfate concentrations. For post- baseline and leachate mixing runs lines are included that represent average conditions in these wells for the post- baseline period as a model results benchmark. The middle two figures represent the change in calcite or pyrite at each model step. These changes are presented as millimoles; positive values represent precipitation (increases in mineral mass) and negative values represent dissolution (decreases in mineral mass). The bottom two plots present saturation indices for gypsum and fluorite. These two minerals represent likely primary solubility controls for sulfate and fluoride. Values of the saturation index greater than zero indicate over-saturation; values less than zero indicate under-saturation. Revised Final White Mesa Mill Geochemical Modeling Report November 22, 2024 Integral Consulting Inc. 3-7 3.6 POST-BASELINE RESULTS The post-baseline runs are based upon oxic conditions. Conceptually, this condition is intended to represent a more recent period, defined in the SOW as after 2005, when oxygen was available in the subsurface. In these runs, Cell 1 of the model is equilibrated with the atmosphere; Cells 2 through 5 are equilibrated with pyrite and/or calcite. Water quality for the five modeled wells was developed as described in Section 3.3.2. A total of 12 runs were completed for each well, with each run defined by a combination of calcite and pyrite concentrations as described in Section 3.3.3 (Table 6). Input, output files, and plots of model results are presented in Appendix C. The key findings from the post-baseline runs are: • Pyrite oxidizes to an extent concomitant to the provision of oxygen. • The downgradient transport of dissolved oxygen in water provides only limited oxygen transport and subsequently, only limited pyrite oxidation. • Pyrite oxidation from the transport of dissolved oxygen in water is unable to lower the pH due to alkalinity and/or the presence of calcite. • Pyrite concentrations are not the controlling factor and variation has limited impact on the results. • Upgradient inflow provides a continual source of high-alkalinity water that buffers pyrite-oxidation related pH decreases. The results of the individual wells are generally consistent. The groundwater at the Mill is associated with sufficient alkalinity to buffer any acidity generated by pyrite oxidation (Figure 8). The addition of calcite provides further buffering of pH (Figure 9). Most of the wells have relatively high alkalinity (more than 300 mg/L; Table 2). MW-22, in contrast to the other wells, has lower alkalinity (19 mg/L; Table 2). In the absence of calcite, the oxidation of pyrite is able to lower pH (Figure 10) at that well. However, the addition of calcite to the system at MW-22 stabilizes the pH (Figure 11). Key species that can indicate reactions and changes in geochemical conditions in this geochemical system include sulfate, fluoride, and nitrate/ammonia. The concentrations of sulfate in the baseline runs increase as a result of pyrite oxidation. This increase is directly proportional to the amount of pyrite oxidized. Given the high baseline sulfate concentrations (ranging from 365 mg/L in MW-27 to 6,400 mg/L in MW-22) the modeled increases in sulfate concentration are proportionately small. Fluorite is over-saturated in MW-22 and may be a likely concentration-controlling phase for fluoride; however, for the other wells, fluorite is Revised Final White Mesa Mill Geochemical Modeling Report November 22, 2024 Integral Consulting Inc. 3-8 undersaturated. The modeled changes in pH are small and do not notably affect fluorite saturation of the system for any wells. Under baseline conditions, all the wells show concentrations of nitrate and ammonia (Table 2). Nitrogen reactions, such as nitrification and denitrification, are most commonly and rapidly mediated biologically. Under the modeled post-baseline conditions, pyrite controls the oxidation-reduction potential of the modeled solutions. As a result, the post-baseline runs are consistent with the baseline runs with respect to nitrogen speciation—with nitrate converted to ammonia. Under conditions where all the pyrite is consumed, such as if the model was allowed to run for very many steps or additional oxygen is provided to the system, ammonia is then oxidized to nitrate. However, it should be noted that observed conditions in site groundwater are in dis-equilibrium with respect to nitrogen species. Hydro Geo Chem (2012) also found that when oxygen was provided to the geochemical system, pyrite was oxidized and generated acidity. In those runs, from 1 to 10 L of air was provided as an equilibrium phase for reaction. As a result, substantially more pyrite was oxidized and this oxidation continued until the oxygen was completely consumed. However, once water travels away from the aerated environment in the vicinity of a monitoring well, the ability to transport oxygen is driven solely by the flow of water. Based upon this modeling, the reduction of pH driven by pyrite oxidation is possible under only very limited conditions. Specifically, multiple conditions must be satisfied: alkalinity must be low, no calcite can be present, reactions are not kinetically inhibited; wells are equilibrated with the atmosphere; and pyrite is present within the aquifer at the depth of the well screens (where the oxygen would be present if from wells). 3.7 MIXING RESULTS The mixing runs are based upon the mixing of baseline period water with leachate from the tailings ponds. The purpose of these model runs was to better understand the geochemical conditions and water quality results from the mixing of leachate water into the aquifer at the Mill. These mixing runs were performed using conditions consistent with those of the baseline runs. Water quality for the three modeled wells was developed as described in Section 3.3.2. A total of 14 runs were completed for each well, with each run defined by a combination of calcite concentration, pyrite concentration, and leachate mixing ratio (Table 7). Input, output files, and plots of model results are presented in Appendix D. The key findings from the mixing runs are: • Decreases in pH from mixing at low mixing ratios are generally consistent with those observed. Revised Final White Mesa Mill Geochemical Modeling Report November 22, 2024 Integral Consulting Inc. 3-9 • Increases in sulfate from mixing are larger than observed. An example of these results can be seen in Figure 12 for MW-11. In the absence of calcite, small amounts of additional leachate can rapidly consume alkalinity and drive pH very low. For MW-11 at 1% leachate the system drops to near pH 3 (Figure 13) versus near pH 6.5 at 0.5% leachate (Figure 12). The effective buffering capacity of calcite is seen in Figure 14, which includes calcite at the same mixing conditions. However, at higher leachate concentrations the calcite can be entirely consumed, resulting in rapid pH drops. In all results, gypsum and fluorite are over-saturated. Further, it can be observed that sulfate concentrations increase much more rapidly than observed in the monitoring wells. These lines of evidence suggest that additional reactions and alteration of the leachate occur in the subsurface beyond those modeled in these runs. Such reactions are likely to include the formation of iron and aluminum hydroxy-sulfate minerals (Nicholson et al., 2003) as an important process. While the modeling handles the direct mixing of the leachate with the subsurface, in the actual subsurface leachate would interact with substantial amounts of vadose-zone material before reaching the aquifer—which is likely to substantially alter the released leachate. Further understanding of the leachate alteration is needed to further elucidate the likelihood of the leachate release hypothesis. Revised Final White Mesa Mill Geochemical Modeling Report November 22, 2024 Integral Consulting Inc. 4-1 4 CONCLUSIONS Groundwater at the White Mesa Mill has been observed to be undergoing shifts in water quality. These changes generally include lowering of pH, increases in sulfate, and increases in the concentrations of some metals. In past reports, these changes in groundwater geochemistry have been hypothesized to be the result of the oxidation of pyrite in the subsurface. Geochemical modeling described in this report found that pyrite is stable in the subsurface at baseline, or anoxic, conditions. When oxygen is provided to the geochemical system, pyrite dissolves in an amount proportional to the amount of oxygen added to the system. Past geochemical modeling indicated that this pyrite oxidation is a potential driver of the observed changes in subsurface water quality. However, that modeling ignored the presence of acid- buffering minerals such as calcite. Further, that modeling did not account for transport in the subsurface and the associated dilution and transport of reaction products. The modeling described in this report found that the amount of oxygen that is likely transported in the subsurface is insufficient to result in substantial changes to groundwater quality. This is explained by the presence of buffering phases and the in-flux of upgradient water to dilute and disperse reaction products. Past studies over-estimated the likely influence of pyrite oxidation in the subsurface by over-emphasizing the presence of acid generating pyrite and ignoring the presence of buffering phases. Additional modeling investigated the potential for leachate water from the tailings cells to impact groundwater quality. Leachate water quality is characterized by low pH, high sulfate, high nitrate and ammonia, and high metals concentrations. Mixing of low percentages of leachate, on the order of 1% or less, was found to lower pH and increase sulfate concentrations. However, the increases in sulfate were larger than those observed at the Mill. The scope of this modeling effort did not take into account the alteration of leachate solutions by the soils and rock of the vadose zone. It is likely that reactions between the leachate and the materials of the vadose zone and aquifer would further reduce sulfate concentrations. Groundwater quality is the result of the interaction of multiple processes in a complex subsurface. The existence of chloroform and nitrate plumes at the Mill are direct evidence that transport from the surface to the subsurface has occurred over the period of operation of the Mill. The geochemical modeling presented here suggests that oxygen transport in the subsurface is unlikely to drive substantial pyrite oxidation in the subsurface outside of areas immediately influenced by monitoring wells. The decreases in pH and increases in sulfate and metals observed in some wells are generally consistent with the mixing of leachate water. However, the limited scope of the modeling effort presented herein was insufficient to fully elucidate the mechanisms driving changes in the groundwater quality at the Mill. The materials reviewed and the result of geochemical modeling has identified a number of additional steps Revised Final White Mesa Mill Geochemical Modeling Report November 22, 2024 Integral Consulting Inc. 4-2 that would help better detail the processes impacting and driving changes in water quality at the Mill. These additional steps include: • Inverse geochemical modeling of leachate to better understand the alteration of leachate that would occur due to interactions with the aquifer matrix. • Geochemical forensics analyses investigating trends and patterns in a range of Mill- specific parameters to better identify and differentiate the processes affecting individual wells. • Hydrologic modeling to quantify flow paths and flow rates to better understand the physical transport of solutes and water at the Mill. Revised Final White Mesa Mill Geochemical Modeling Report November 22, 2024 Integral Consulting Inc. 5-1 5 REFERENCES Battelle 2023. Quality assurance project plan, groundwater geochemical modeling at the White Mesa Uranium mill. February 9. Craig L.C. 1982. Uranium potential of the Burro Canyon formation in Western Colorado. USGS Open-File Report 82-222, United States Department of the Interior, Geological Survey, 1982. Energy Fuels 2023. https://www.energyfuels.com/white-mesa-mill. Accessed 3/16/2023. Hurst and Solomon 2008. Summary of work completed, data results, interpretations and recommendations for the July 2007 sampling event at the Denison Mines, USA, White Mesa Uranium Mill. May 2008. Hydro Geo Chem 2012. Investigation of pyrite in the perched zone, White Mesa Uranium Mill site. December 7. Hydro Geo Chem 2014. Hydrogeology of the White Mesa uranium mill. June 6. Intera 2009. Nitrate contamination investigation report. December 30. Intera 2012. pH report, White Mesa uranium mill, Blanding, Utah. November 9. MWH 2010. Revised infiltration and contaminant transport modeling report, White Mesa Mill Site, Blanding, Utah. March. Nicholson, A., A. Davis, and S. Helgen. 2003. Elements influencing cost apportionment in the Pinal Creek Aquifer, Arizona USA. Part II: Identification of Geochemical Controls on Remediation Time. Environ. Forensics 4:271–286. United States Geological Survey (USGS) 2011. Assessment of potential migration of radionuclides and trace elements from the White Mesa uranium mill to the Ute Mountain Ute Reservation and surrounding areas, Southeastern Utah. SIR 2011-5231 USGS 2013. Description of input and examples for PHREEQC Version 3—A computer Program for speciation, batch-reaction, one-dimensional transport, and inverse geochemical calculations. TM6-A42. UMETCO 1993. Groundwater study White Mesa facility, Blanding UT. January. Utah Department of Environmental Quality (UDEQ). 2023. https://deq.utah.gov/waste- management-and-radiation-control/energy-fuels-resources-usa-inc. Accessed 3/16/2023. Figures ¯0 1,000 2,000 3,000 Feet Aerial Source: Esri, Maxar (2018) Figure 1. Site and key well locations N: \ G I S \ P r o j e c t s \ C 3 5 5 2 _ B a t t e l l e _ W h i t e M e s a \ P r o d u c t i o n _ M a p s \ L o c a t o r_ M a p \ L o c a t o r _ M a p . a p r x La y o u t N a m e : L a y o u t 1 3 / 1 7 / 2 0 2 3 3 : 1 9 P M Legend Key Well Locations Disposal Cell Locations Site Boundary Las Vegas Great Basin R o c k y M o u n t a i n s Utah Salt Lake City MW-27 MW-11 MW-24 MW-3A MW-22 Cell 1 Cell 2 Cell 3 Cell 4B Cell 4A Site Location Figure 2.Observed changes in pH at the Mill (Intera 2012) Figure 3. Conceptual model 1 2 534 O2CO2 PyriteCalcite PyriteCalcite PyriteCalcite PyriteCalcite Phases MW Downgradientcell Downgradientcell Downgradientcell DowngradientcellUpgradient inflow Conceptual Select MWwater quality Select MWwater quality Select MWwater quality Select MWwater quality Select MWwater quality Select MWwater quality Initial WQ Figure 4. Model data flow schematic Baseline Water Quality Input Data Model Runs Post-Baseline Runs Baseline Runs Leachate Mixing Benchmark Data Post- Baseline Water Quality Post- Baseline Water Quality Model Test Stability of Pyrite under anoxic conditions Evaluation of effects of oxygen on groundwater quality and pyrite stability Evaluation of leachate mixing with site groundwater Figure 5. Carbon dioxide saturation in modeled wells, baseline and post-baseline conditions Figure 6. Baseline model run dashboard plot MW-11, pyrite 0.8%, calcite 0% Figure 7. Baseline model run dashboard plot MW-11, pyrite 0.8%, calcite 1.5% Figure 8. Post-baseline model run dashboard plot MW-24, pyrite 0.8%, calcite 0% Figure 9. Post-baseline model run dashboard plot MW-24, pyrite 0.8%, calcite 1.5% Figure 10. Post-baseline model run dashboard plot MW-22, pyrite 0.8%, calcite 0% Figure 11. Post-baseline model run dashboard plot MW-22, pyrite 0.8%, calcite 1.5% Figure 12. Mixing model run dashboard plot MW-11, pyrite 0.45%, calcite 0%, leachate fraction 0.5% Figure 13. Mixing model run dashboard plot MW-11, pyrite 0.45%, calcite 0%, leachate fraction 1% Figure 14. Mixing model run dashboard plot MW-24, pyrite 0.45%, calcite 1.5%, leachate fraction 1% Tables Revised Final White Mesa Geochemical Modeling 10/26/2024 Table 1. Summary of selected monitoring wells for geochemical modeling Generalized Location Well Description Upgradient MW-27 At processing area, immediately upgradient of tailings cell 1 MW-24 Southwest (downgradient) corner of tailings cell 1 MW-11 Northern edge of tailings cell 4A MW-3A Approximately 600 m south of tailings cell 4/4A Downgradient MW-22 Approximately 1,600 m south of tailings cell 4A Integral Consulting Inc.Page 1 of 1 Revised Final White Mesa Geochemical Modeling 10/26/2024 Table 2. Baseline and post-baseline water quality at modeled wells NH3 Alkalinity Ca Cl F Fe Mg NO3-K Na SO4-2 mg/L mg/L as CaCO3 mg/L mg/L mg/L ug/L mg/L mg/L mg/L mg/L mg/L MW-27 0.06 330a 158 34.4 0.68a 30.0 69.6 28.0a 4.3 75.7 365a -3 7.65 MW-24 18.5 483 492 50.4 0.30 2176 176 0.62 20.2 438 2660 -3 7.36 MW-11 0.80 372 72.7 33.8 0.60 30.6 24.4 0.44 7.0 515 1043 -3 7.73 MW-3A 0.08a 347a 463 61.6 0.10 126 297 0.44 27.3 709 3420a -3 7.36 MW-22 1.1a 19.2a 489 62.0 12.7a 38.0 1035 11.2a 25.4 260 6423a -3 6.47 MW-27 0.1 330.1 152.6 39.8 0.68 36.9 66.1 28.0 4.3 73.8 365 7.1 7.16 MW-24 0.4 85.3 489.6 44.7 0.46 732 182 2.77 13.4 481 2778 7.2 5.82 MW-11 0.9 317.1 74.9 37.7 0.43 75.9 23.6 9.18 7.1 589 1173 5.4 7.41 MW-3A 0.1 346.9 469.7 59.4 0.92 30.3 297 4.08 28.4 797 3420 7.2 6.56 MW-22 1.1 19.2 432.0 57.1 12.7 76.6 1093 11.2 22.5 274 6423 8.4 5.03 Notes a due to data availability limitations post-baseline data used for baseline period. Baseline Post- baseline pe pHPeriodWell Integral Consulting Inc.Page 1 of 1 Revised Final White Mesa Geochemical Modeling 10/26/2024 Table 3. Representative containment cell 1 leachate water quality NH3 Alkalinity Ca Cl F Fe Mg NO3-K Na SO4-2 mg/L mg/L as CaCO3 mg/L mg/L mg/L ug/L mg/L mg/L mg/L mg/L mg/L Cell 1 7494 0 565 27161 3357 5912 11568 166 4128 32979 184604 1.46 Description pH Integral Consulting Inc.Page 1 of 1 Revised Final White Mesa Geochemical Modeling 10/26/2024 Table 4. Summary of available calcite content data Report Min.Max.Mean Hydro Geo Chem (2012)a 0.05b 14.0 1.68 MWH (2010)c 0.05b 18.2 1.38 1.5 Notes: a Based upon data presented in Table 4, for all wells b 0.05 represents non-detect values c Based on data presented in Table C4, for all wells. Calcite Content (%) average Integral Consulting Inc.Page 1 of 1 Revised Final White Mesa Geochemical Modeling   10/26/2024 Table 5. Summary of baseline model run conditions Well Calcite (%) Pyrite (%) CO2 (partial pressure) O2 (partial pressure) 00-2.1 0 00.1-2.1 0 00.4-2.1 0 00.8-2.1 0 1.5 0 -2.1 0 1.5 0.1 -2.1 0 1.5 0.4 -2.1 0 1.5 0.8 -2.1 0 50-2.10 5 0.1 -2.1 0 5 0.4 -2.1 0 5 0.8 -2.1 0 00-2.10 0 0.1 -2.1 0 0 0.4 -2.1 0 0 0.8 -2.1 0 1.5 0 -2.1 0 1.5 0.1 -2.1 0 1.5 0.4 -2.1 0 1.5 0.8 -2.1 0 50-2.10 5 0.1 -2.1 0 5 0.4 -2.1 0 5 0.8 -2.1 0 00-2.10 0 0.1 -2.1 0 0 0.4 -2.1 0 0 0.8 -2.1 0 1.5 0 -2.1 0 1.5 0.1 -2.1 0 1.5 0.4 -2.1 0 1.5 0.8 -2.1 0 50-2.10 5 0.1 -2.1 0 5 0.4 -2.1 0 5 0.8 -2.1 0 00-2.10 0 0.1 -2.1 0 0 0.4 -2.1 0 0 0.8 -2.1 0 1.5 0 -2.1 0 1.5 0.1 -2.1 0 1.5 0.4 -2.1 0 1.5 0.8 -2.1 0 50-2.10 5 0.1 -2.1 0 5 0.4 -2.1 0 5 0.8 -2.1 0 00-2.10 0 0.1 -2.1 0 0 0.4 -2.1 0 0 0.8 -2.1 0 1.5 0 -2.1 0 1.5 0.1 -2.1 0 1.5 0.4 -2.1 0 1.5 0.8 -2.1 0 50-2.10 5 0.1 -2.1 0 5 0.4 -2.1 0 5 0.8 -2.1 0 MW-27 MW-24 MW-11 MW-3A MW-22 Integral Consulting Inc. Page 1 of 1 Revised Final White Mesa Geochemical Modeling   10/26/2024 Table 6. Summary of post-baseline model run conditions Well Calcite (%) Pyrite (%) CO2 (partial pressure) O2 (partial pressure) 00-1.6 -0.67 0 0.1 -1.6 -0.67 0 0.4 -1.6 -0.67 0 0.8 -1.6 -0.67 1.5 0 -1.6 -0.67 1.5 0.1 -1.6 -0.67 1.5 0.4 -1.6 -0.67 1.5 0.8 -1.6 -0.67 5 0 -1.6 -0.67 5 0.1 -1.6 -0.67 5 0.4 -1.6 -0.67 5 0.8 -1.6 -0.67 0 0 -1.6 -0.67 0 0.1 -1.6 -0.67 0 0.4 -1.6 -0.67 0 0.8 -1.6 -0.67 1.5 0 -1.6 -0.67 1.5 0.1 -1.6 -0.67 1.5 0.4 -1.6 -0.67 1.5 0.8 -1.6 -0.67 5 0 -1.6 -0.67 5 0.1 -1.6 -0.67 5 0.4 -1.6 -0.67 5 0.8 -1.6 -0.67 0 0 -1.6 -0.67 0 0.1 -1.6 -0.67 0 0.4 -1.6 -0.67 0 0.8 -1.6 -0.67 1.5 0 -1.6 -0.67 1.5 0.1 -1.6 -0.67 1.5 0.4 -1.6 -0.67 1.5 0.8 -1.6 -0.67 5 0 -1.6 -0.67 5 0.1 -1.6 -0.67 5 0.4 -1.6 -0.67 5 0.8 -1.6 -0.67 0 0 -1.6 -0.67 0 0.1 -1.6 -0.67 0 0.4 -1.6 -0.67 0 0.8 -1.6 -0.67 1.5 0 -1.6 -0.67 1.5 0.1 -1.6 -0.67 1.5 0.4 -1.6 -0.67 1.5 0.8 -1.6 -0.67 5 0 -1.6 -0.67 5 0.1 -1.6 -0.67 5 0.4 -1.6 -0.67 5 0.8 -1.6 -0.67 0 0 -1.6 -0.67 0 0.1 -1.6 -0.67 0 0.4 -1.6 -0.67 0 0.8 -1.6 -0.67 1.5 0 -1.6 -0.67 1.5 0.1 -1.6 -0.67 1.5 0.4 -1.6 -0.67 1.5 0.8 -1.6 -0.67 5 0 -1.6 -0.67 5 0.1 -1.6 -0.67 5 0.4 -1.6 -0.67 5 0.8 -1.6 -0.67 MW-27 MW-24 MW-11 MW-3A MW-22 Integral Consulting Inc. Page 1 of 1 Revised Final White Mesa Geochemical Modeling   10/26/2024 Table 7. Summary of leachate mixing model run conditions Well Calcite (%) Pyrite (%) CO2 (partial pressure) O2 (partial pressure) Leachate Mixing Fraction (%) 0 0.4 -1.6 0 0.1 0 0.4 -1.6 0 0.3 0 0.4 -1.6 0 0.5 0 0.4 -1.6 0 1 0 0.4 -1.6 0 3 0 0.4 -1.6 0 5 0 0.4 -1.6 0 10 1.5 0.4 -1.6 0 0.1 1.5 0.4 -1.6 0 0.3 1.5 0.4 -1.6 0 0.5 1.5 0.4 -1.6 0 1 1.5 0.4 -1.6 0 3 1.5 0.4 -1.6 0 5 1.5 0.4 -1.6 0 10 0 0.4 -1.6 0 0.1 0 0.4 -1.6 0 0.3 0 0.4 -1.6 0 0.5 0 0.4 -1.6 0 1 0 0.4 -1.6 0 3 0 0.4 -1.6 0 5 0 0.4 -1.6 0 10 1.5 0.4 -1.6 0 0.1 1.5 0.4 -1.6 0 0.3 1.5 0.4 -1.6 0 0.5 1.5 0.4 -1.6 0 1 1.5 0.4 -1.6 0 3 1.5 0.4 -1.6 0 5 1.5 0.4 -1.6 0 10 0 0.4 -1.6 0 0.1 0 0.4 -1.6 0 0.3 0 0.4 -1.6 0 0.5 0 0.4 -1.6 0 1 0 0.4 -1.6 0 3 0 0.4 -1.6 0 5 0 0.4 -1.6 0 10 1.5 0.4 -1.6 0 0.1 1.5 0.4 -1.6 0 0.3 1.5 0.4 -1.6 0 0.5 1.5 0.4 -1.6 0 1 1.5 0.4 -1.6 0 3 1.5 0.4 -1.6 0 5 1.5 0.4 -1.6 0 10 MW-27 MW-24 MW-11 Integral Consulting Inc. Page 1 of 1