DRC-2021-011701 - 0901a06880f36e21

7-1,7710ni.
and Racittion Controi
AliG 2 3 2021 2.02-l-oinoi
4E7/ _J NERGY FUELS
Energy Fuels Resources (USA) Inc.
225 Union Blvd. Suite 600
Lakewood, CO, US, 80228
303 974 2140
www.energyfuels.coni
August 17, 2021
Sent VIA E-MA1L AND EXPRESS DELIVERY
Mr. Doug Hansen
Director
Division of Waste Management and Radiation Control
Utah Department of Environmental Quality
195 North 1950 West
Salt Lake City, UT 84114-4880
Re: Transmittal of Q2-21 Data Quality Report ("DQR") for the White Mesa Cell 2 Cover Test
Section Monitoring
Dear Mr. Hansen:
In accordance with the Stipulation and Consent Agreement ("SCA") dated February 23, 2017, between the
Division of Waste Management and Radiation Control ("DWMRC") and Energy Fuels Resource (USA) Inc.
("EFRI"), EFRI constructed a cover performance monitoring test section on Cell 2 in 2016 and initiated
performance monitoring. This letter transmits the data quality report for monitoring data collected during the
second quarter of 2021. Please note that this report is for quality assurance only and does not provide
interpretive information. Interpretive information is provided in annual reports.
For your convenience, two hard copies of the report and two CDs, each containing a word searchable electronic
copy of the files, will be mailed to DWMRC.
If you should have any questions regarding this transmittal please contact me at 303-389-4134.
Yours very truly,
-Orty
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel
Quality Assurance Manager
CC: David Frydenlund
'Terry Slade
Garrin Palmer
Logan Shumway
Scott Bakken
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Q2-21 DATA QUALITY REPORT FOR THE
111 PRIMARY TEST SECTION
II WHITE MESA MILL TAILINGS MANAGEMENT
CELL 2
ENERGY FUELS RESOURCES (USA) INC.
SAN JUAN COUNTY, UTAH
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8 August 2021
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1.0 INTRODUCTION
This data quality report (DQR) was prepared to record data quality assurance for the White
Mesa Mill cover performance monitoring test section (Primary Test Section) for second
quarter 2021 (Q2-21). This report is documentary and not interpretative. The annual report
includes interpretation of the monitoring data.
The Primary Test Section was constructed in August — September 2016 over tailings
management Cell 2 at Energy Fuels Resources (USA) Inc.'s White Mesa Mill in San Juan
County, Utah. Hydrological monitoring was initiated on 29 September 2016. A large-scale
"ACAP" drainage lysimeter monitors the test section. The lysimeter is equipped to monitor
water balance components and meteorological data.
Fig. 1 shows a profile of the final cover being evaluated at White Mesa (minimum
thickness). Fig. 2 shows a cross-sectional schematic of the lysimeter. The test section is
instrumented with two nests of vertically stacked and co-located sensors to monitor soil
temperature and soil water content, as illustrated in Figs. 1 and 2. The nests are on the
centerline of the test section at the upper and lower third points. Probes in the lower nest
are odd numbered and probes in the upper nest are even numbered. The water content
probes were calibrated with on-site soils collected during construction. Temperature
compensation was incorporated into the calibrations.
Flows from runoff, lateral flow (interflow), and percolation collection points in the test
section are routed via pipe (Fig. 2) to collection basins in a subsurface vault downslope
from the test section. Flow into each basin is monitored by tipping buckets and a pressure
transducer. Flows reported by the tipping bucket are described in terms of "tips," whereas
water elevations reported by the transducers are reported as "stage." Flows are reported
in mm of water per unit area. The tipping buckets and pressure transducers were
calibrated initially in September 2016, and re-calibrated on 10 May 2017, 14 November
2017, 27 June 2018, 11 September 2019, and 14 July 2020.
2.0 WATER BALANCE DATA
Data in this DQR were collected during Q2-21 from 24 March 2021 to 24 June 2021. These
dates align with automated data downloads and do not correspond precisely to the start
and end of Q2-21. Data for 25 June 2021 and onward will be included in the Q3-21 report.
Fig. 3 shows the water balance graph for the test sections and Table 1 summarizes the
water balance quantities. Fig. 4 shows cumulative percolation and daily precipitation for
both test sections. Figs. 5-31 show data from each sensor collected during Q2-21. The
quality assurance summary is on pg. 7.
Approximately 11 mm of precipitation was recorded in Q2-21, most of which occurred in
a storm in late March and as a series of small precipitation events throughout May (Fig.
7). No runoff or lateral flow was transmitted in response to these events (Figs. 23, 26).
Precipitation that infiltrated in response to the March event was stored at shallow depths
within the cover profile, as evinced by an increase in water content at the shallowest
probes (457 mm, Fig. 13). This increase in water content was followed by a gradual
decrease in water content throughout the remainder of Q2-21. At all other depths, the
water content remained nearly constant (Figs. 14-19). Soil water storage remains near the
all-time low (Fig. 3) and percolation was nil during Q2-21 (Fig. 29).
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3.0 CONCERNS
• Significant differences in water content exist between Probes 1 and 2 and between
Probes 3 and 4. These differences have existed since 2017 and are a response to
lateral water movement above the compacted layer associated with infiltration of
snowmelt in 2017. These differences are not a substantive concern. Comparison of
water contents reported by these probes will continue during future quality control
activities.
• The reed switches on the lateral flow basin reported different tip counts in Q3-20,
suggesting that one or both switches was malfunctioning. These switches are on
watch, and will be repaired or replaced if necessary, during the annual maintenance
and calibration exercise in Q3-21.
• The modem was inoperative intermittently in Q4-20. A temporary software patch was
deployed in Q4-20, which returned the modem to operability. The modem will be
replaced during the calibration and maintenance activity in Q3-21.
4.0 RESOLVED ISSUES
• The software patch on the modem resolved the intermittent telecommunications issue
first encountered in Q4-20. This is an interim measure until the modem is replaced in
Q3-21.
5.0 ACTION ITEMS
• Continue comparing water content Probes 1 and 2 and Probes 3 and 4.
• Continue monitoring reed switches on lateral flow tipper to confirm both are
functioning. No flow reported to the lateral basin in Q2-21, precluding an assessment
of these switches. These switches will be repaired or replaced, if necessary, during
the annual calibration and maintenance event in August 2021.
• Replace the modem during the annual calibration and maintenance event in August
2021.
2
0.5 ft Erosion Layer
3.5 ft Growth Medium
3.0 ft Compacted Cover
2.5 ft Interim Layer
WCR or thermocouple
Fig. 1. Schematic of cover profile evaluated at White Mesa.
3
1 64 ft 10.
Runoff
Berm
\414Y—N Runoff rosion Layer (0 5 ft) Berm
60 mil LLDPE GM Growth Medium (3 5 ft)
Pipe ".Root Ban ter Interim Cover (2.5 ft) Interflow Pipe
Runoff Compacted Cover (3.0 ft)
60 mil
GM

Sump
Percolation Pipe
Compacted
subgrade
60 mil U.DPE GM Geocomposite Drain Compacted
Subgracle
Fig. 2. Schematic of lysimeter used for the White Mesa Primary Test Section.
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Table 1. Water balance quantities for the final cover test section at White Mesa from 09/29/16 to
06/24/21.
Calendar
Year
Water Balance Quantities (mm)
Precipitation Runoff Lateral
Flow ET A
Storage Percolation
2016 59.9 0.03 0.00 34.6 16.9 0.00
2017 222.7 0.06 0.00 324.8 39.4 0.65
2018 163.4 0.09 0.00 124.6 37.9 0.90
2019 309.1 0.28 0.00 325.9 0.9 1.01
2020 130.4 0.04 0.00 175.6 -64.5 0.89
2021 57.7 0.02 0.00 52.2 5.9 0.00
*damage from vault flooding precluded measuring flows from 7 February 2017 - 25 March
2017.
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5
1200
0 •• " E1000 E
'E5 c a) 0
.ca 800
c
E °- 600
ai‘ 0) • >
400 u) g
cts 0 -0 = c 200 o (13
White Mesa, UT
Soil Water
Storage
5
On-Site ET
NWS
Precipitation 4
- 3
- 2
Percolation Surface
Runoff
On-Site
Precipitation
nyLateral Flow , IP.. l i 0
11/26/19 9/12/20 6/30/21 9/20/16 7/7/17 4/24/18 2/9/19
Fig. 3. Water balance quantities for the final cover test section at White Mesa from
09/29/16 to 06/24/21.
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DATA QUALITY REPORT SUMMARY: Q2-21
White Mesa Primary Test Section
03/24/21 through 06/24/21
Water Balance Summary
• Table 1 summarizes the water balance of the test section since inception.
• Fig. 3 presents the water balance graph for the test section since inception.
• Fig. 4 shows graphs of daily precipitation and cumulative percolation for the test section
since inception.
Meteorology
• The battery and solar panel are working properly (Fig. 5).
• All meteorological sensors are working properly (Figs. 6-12).
• The on-site precipitation data are generally consistent with, but slightly larger than, the
NWS data recorded at the Blanding station (KBDG, 37.62° N, 109.47° W, Elev.: 6001
ft) (Fig.7). Independent precipitation measurements recorded by the Geonor gage and
the tipping bucket are also in good agreement (Fig. 8).
• Solar radiation data are consistent with data recorded at the NWS Blanding station
(Fig. 12).
Test Section
• The WCR probes to measure water content are functioning properly (Figs. 13-19).
Differences in water content of approximately 0.12 are reported by Probes 3 and 4 in
the compacted layer at 2134 mm bgs (Fig. 18). Differences in water content of
approximately 0.10 are reported by Probes 1 and 2 in the interim layer at 2743 mm
bgs (Fig. 19). These differences in water content are real and reflect spatial variations
in water content that remain from the deep penetration of a wetting front in Q1-17.
These differences are diminishing slowly over time.
• The thermocouples used to measure soil temperature are functioning properly (Fig. 20).
• Flows reported by the transducer and tippers for runoff, lateral flow, and percolation
are reasonably consistent (Figs. 21-29). The runoff basin stage has been decreasing
gradually (Fig. 22). The gradual drop in stage reflects thermal expansion of the basin
in summer combined with evaporation. This drop is accounted for in the water balance
analysis.
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• The vault stage has been negative, indicating no accumulating water (Fig. 30).
• The voltage sensor that monitors the power supply in the vault is functioning properly
(Fig. 31). No loss of power to the vault was recorded in Q2-21.
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5.0
Percolation
\
40-
10-
9/20/16 7/7/17
6/13/21 6/30/21 3/20/21 4/6/21 4/23/21 5/10/21 5/27/21
14
13
11
10
50
White Mesa, UT
Precipitation
4/24/18
CD
11111111I11L .I.11 0.0
-1.0 --
2/9/19 11/26/19 9/12/20 6/30/21
Fig. 4. Daily precipitation (blue) and cumulative percolation (red) for the final cover test
section at White Mesa from 09/29/16 to 06/24/21.
Fig. 5. Battery voltage for the datalogger at the final cover test section at White Mesa
from 03/24/21 to 06/24/21.
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1
Da
il
y

Pr
e
c
ip
it
a
tio
n (
m
m
)

10
4
2
6
8
I 1 i I I I I I 1 I I I I
White Mesa
NWS Blanding
I I , I I I I I I I I I I i I I I I I I
3/20/21 4/6/21 4/23/21 5/10/21 5/27/21 6/13/21 6/30/21
Fig. 6. Daily precipitation at the final cover test section at White Mesa from 03/24/21 to
06/24/21
20
3/20/21 4/6/21 4/23/21 5/10/21 5/27/21 6/13/21 6/30/21
Fig. 7. Cumulative precipitation at the final cover test section at White Mesa (blue) and
NWS Blanding station (red) from 03/24/21 to 06/24/21.
10
-1 0 3/20/21 4/6/21 4/23/21 5/10/21 5/27/21 6/13/21 6/30/21
40
30
6 o
cD
cD
20
10
>, 7o -
Air -
Avg. Air Temp
Max Air Temp
0 10 20 30 40
Geonor Precipitation (mm)
Fig. 8. Precipitation from tipper and Geonor precipitation gauge at the final cover test
section at White Mesa from 12/29/19 to 06/24/21.
Fig. 9. Daily air temperature at the final cover test section at White Mesa from 03/24/21
to 06/24/21.
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Da
il
y

Re
la
tiv
e

H
u
m
id
i
t
y

(
%)

120
100
80
60
40
20
Da
il
y

M
e
a
n W
i
n
d Sp
ee
d
(
m
/s
)

Fig. 10. Daily relative humidity at the final cover test section at White Mesa from 03/24/21
to 06/24/21.
Fig. 11. Daily mean wind speed at the final cover test section at White Mesa from
03/24/21 to 06/24/21.
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1
1
0.5
_ White Mesa, UT
- (457-mm Depth Topsoil Layer)
0.1
0.0
3/20/21 4/9/21 4/29/21 5/20/21 6/9/21 6/30/21
10000
8000
6000
0
d
354000
2000
0
3/20/21 4/6/21 4/23/21 5/10/21 5/27/21 6/13/21 6/30/21
Fig. 12 Total daily solar radiation at the final cover test section at White Mesa (blue) and
NWS Blanding station (red) from 03/24/21 to 06/24/21.
Fig. 13. Volumetric water content in the growth medium layer (457 mm bgs) of the final
cover test section at White Mesa from 03/24/21 to 06/24/21. Odd numbered
probe is downslope and even is upslope.
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1 l 1 1 1 1
o 0
450.3
0.0
3/20/21 4/6/21 4/23/21 5/10/21 5/27/21 6/13/21 6/30/21
0.1
0.5
0.4
- White Mesa, UT
- (685-mm Depth Growth Medium Layer)
Probe 11
Probe 12
1 1 1 1
o
0.0
3/20/21 4/6/21 4/23/21 5/10/21 5/27/21 6/13/21 6/30/21
0.5
0.4
0.1
1 1 1 l
_ White Mesa, UT
_ (914-mm Depth Growth Medium Layer)
Probe 10
Probe 9
1 1 1 1 1
Fig. 14. Volumetric water content in the growth medium layer (685 mm bgs) of the final
cover test section at White Mesa from 03/24/21 to 06/24/21. Odd numbered
probe is downslope and even is upslope.
Fig.15. Volumetric water content in the growth medium layer (914 mm bgs) of the final
cover test section at White Mesa from 03/24/21 to 06/24/21. Odd numbered
probe is downslope and even is upslope.
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0.5

I I i I I I

White Mesa, UT
_ (1524-mm Depth Compacted Layer)

Probe 8

0.1

Probe 7

0.0

I

3/20/21 4/6/21 4/23/21 5/10/21 5/27/21 6/13/21 6/30/21
Fig. 16. Volumetric water content in the compacted layer (1524 mm bgs) of the final cover
test section at White Mesa from 03/24/21 to 06/24/21. Odd numbered probe is
downslope and even is upslope.
0.5

I I I
0.4 •E' a)
o
0.3
o
- White Mesa, UT
- (1829-mm Depth Compacted Layer)
Probe 6
0.1
0.0
Probe 5
1111 I I I Ii I I l l 1 I 1 -L-
3/20/21 4/6/21 4/23/21 5/10/21 5/27/21 6/13/21 6/30/21
Fig. 17. Volumetric water content in the compacted layer (1829 mm bgs) of the final cover
test section at White Mesa from 03/24/21 to 06/24/21. Odd numbered probe is
downslope and even is upslope.
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0.5

I I I iI I I I I I

_ White Mesa, UT
_ (2134-mm Depth Compacted Layer)

Prc-:

Probe 4

0.1
0.0

I I I
3/20/21 4/6/21 4/23/21 5/10/21 5/27/21 6/13/21 6/30/21
Fig. 18. Volumetric water content in the compacted layer (2134 mm bgs) of the final cover
test section at White Mesa from 03/24/21 to 06/24/21. Odd numbered probe is
downslope and even is upslope.
0.5

I I I I

0.4
_ White Mesa, UT
_ (2743-mm Depth Interim Layer)

Probe 1

Probe 2

0.1

0.0

I I I I I I I I I

3/20/21 4/6/21 4/23/21 5/10/21 5/27/21 6/13/21 6/30/21
Fig. 19. Volumetric water content in the interim layer (2743 mm bgs) of the final cover
test section at White Mesa from 03/24/21 to 06/24/21. Odd numbered probe is
downslope and even is upslope.
16
30
,
r2.
0-20
a)
0
3/20/21 4/6/21 4/23/21 5/10/21 5/27/21 6/13/21 6/30/21
40
10
- 2743 mm D
2743 mm U
2134 mm D
2134 mm U
1829 mm D
1829 mm U
1524 mm D
1524 mm U
914 mm Li
914 mm U
685 mm D
685 mm U
457 mr,
Fig. 20. Soil temperature in the final cover test section at White Mesa from 03/24/21 to
06/24/21 (sensor depths in mm bgs in legend, D = downslope; U = upslope).
10
White Mesa, UT
Cu
mu
la
tiv
e T
i
p
s f
o
r Ru
no
ff

4
2
Tipper (1 L)
0 - r- T-
3/20/21 4/6/21 4/23/21 5/10/21 5/27/21 6/13/21 6/30/21
Fig. 21. Cumulative tips from tipper in the runoff basin for the final cover test section at
White Mesa from 03/24/21 to 06/24/21.
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1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
White Mesa, UT
500
400
o
cr 300
cu
co cn c 200 •(7)
ca
o
100
0
3/20/21 4/6/21 4/23/21 5/10/21 5/27/21 6/13/21 6/30/21
Fig. 22. Pressure transducer stage in the runoff basin for the final cover test section at
White Mesa from 03/24/21 to 06/24/21.
0.5
0.4
0.3
0.2
0.1
Tipper (1 L)
0.0 - I I ----1-4 I 1 I I I -Il l l / I I I I I 1 I 1 -
3/20/21 4/6/21 4/23/21 5/10/21 5/27/21 6/13/21 6/30/21
Fig. 23. Cumulative flow from pressure transducer stage and from the tipper in the runoff
basin for the final cover test section at White Mesa from 03/24/21 to 06/24/21.
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Cu
mu
la
tiv
e

F
l
o
w i
n

R
u
no
ff

Ba
sin

(
m
m)

Pressure Transducer
10
8
6
4
2 Cu
m
u
la
tiv
e

T
i
p
s fo
r

L
a
te
r
a
l
F
l
o
w
0
-
- White Mesa, UT
-
1-
, i , , i , , i ,
-
-
- -
-
- -
-
1
, i , i I ,
- Whie Mesa, UT
-
- -
-
- -
Tipper (1 L)
/
_
, I I I i I li 1 1 It t
3/20/21 4/6/21 4/23/21 5/10/21 5/27/21 6/13/21 6/30/21
Fig. 24. Cumulative tips from tipper in the lateral flow basin for the final cover test section
at White Mesa from 03/24/21 to 06/24/21.
500
400
300
200
100
o
3/20/21 4/6/21 4/23/21 5/10/21 5/27/21 6/13/21 6/30/21
Fig. 25. Pressure transducer stage in lateral flow basin for the final cover test section at
White Mesa from 03/24/21 to 06/24/21.
Pr
e
s
s
u
re

Tr
a
n
s
du
c
e
r

S
t
a
g
e fo
r La
te
r
a
l Fl
o
w

(
m
m
)

19
0.5
0.4
*7)
co
LT_ 0.3
• 0.2
a)
.1'73 0.1
o
0.0
I
- White Mesa, UT
Pressure Transducer Tipper (1 L)
1 I I
3/20/21 4/6/21 4/23/21 5/10/21 5/27/21 6/13/21 6/30/21
Fig. 26. Cumulative flow from pressure transducer stage and from tipper in lateral flow
basin for the final cover test section at White Mesa from 03/24/21 to 06/24/21.
10
8
Cu
mu
la
tiv
e

T
i
p
s fo
r

D
r
a
in
a
g
e
6
4
2
3/20/21 4/6/21 4/23/21 5/10/21 5/27/21 6/13/21 6/30/21
Fig. 27. Cumulative tips from the tipper in the drainage basin for the final cover test
section at White Mesa from 03/24/21 to 06/24/21.
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I Ir I II
_ White Mesa, UT
Tipper (1 L) Tipper (70 mL)
1
1
1
1
1
1
1
1
1
1
1
I
1
1
1
1
1
1
1
1.0
Cu
mu
la
tiv
e

F
lo
w

i
n

D
r
a
in
a
g
e B
a
s
in

(
mm
)

0.8
0.6
0.4
0.2
0.0
500
CD 400
'Ft
300
ca cn
o'ci3 200 z -0 ci)
,c12
92 100
(i)
Et.) a_

I I I
White Mesa, UT
It i I t t I t a
3/20/21 4/6/21 4/23/21 5/10/21 5/27/21 6/13/21 6/30/21
Fig. 28. Pressure transducer stage in drainage basin for the final cover test section at
White Mesa from 03/24/21 to 06/24/21.
_ White Mesa, UT
Pressure Transducer
Tipper (1 L)
Tipper (70 mL)
I I 1
3/20/21 4/6/21 4/23/21 5/10/21 5/27/21 6/13/21 6/30/21
Fig. 29. Cumulative flow from pressure transducer stage and from tippers in drainage
basin for the final cover test section at White Mesa from 03/24/21 to 06/24/21.
21
200
180
120
100
3/20/21 4/6/21 4/23/21 5/10/21 5/27/21 6/13/21 6/30/21
4/6/21 4/23/21 5/10/21 5/27/21 6/13/21 6/30/21
Fig. 30. Vault stage for the final cover test section at White Mesa from 03/24/21 to
06/24/21.
Fig. 31. Vault voltage in the basin for the final cover test section at White Mesa from
03/24/21 to 06/24/21.
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