HomeMy WebLinkAboutDRC-2022-023134 - 0901a06881126bc2November 22, 2022
Div of Waste Management and Radiation Control
NOV 2 3 2022
Sent VIA E-MAIL 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
Energy Fuels Resources (USA) Inc. 225 Union Blvd. Suite 600 Lakewood, CO, US, 80228
303 974 2140 www.energyfuels.com
Re: Transmittal of Q3-22 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 third quarter of 2022. 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,
ENERGY FUELS RESOURCES (USA) INC.
Kathy Weinel Director, Regulatory Compliance
CC: David Frydenlund Garrin Palmer Logan Shumway
Scott Bakken
DRC-2022-023134
Energy Fuels Resources (USA) Inc. 225 Union Blvd. Suite 600 Lakewood, CO, US, 80228 303 974 2140 www.energyfuels.com
November 22, 2022
Sent VIA E-MAIL 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 Q3-22 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 third quarter of 2022. 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,
ENERGY FUELS RESOURCES (USA) INC. Kathy Weinel Director, Regulatory Compliance
CC: David Frydenlund Garrin Palmer Logan Shumway Scott Bakken
~£RGYFUEL5
Q3-22 DATA QUALITY REPORT FOR THE
PRIMARY TEST SECTION
WHITE MESA MILL – TAILINGS MANAGEMENT
CELL 2
ENERGY FUELS RESOURCES (USA) INC.
SAN JUAN COUNTY, UTAH
6 November 2022
1
1.0 INTRODUCTION
This data quality report (DQR) was prepared to document data quality assurance for the
White Mesa Mill cover performance monitoring test section (Primary Test Section) for third
quarter 2022 (Q3-22). 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 initially
calibrated in September 2016 and have been re-calibrated annually. The most recent
calibration was on 12 July 2022.
2.0 WATER BALANCE DATA
Data in this DQR were collected during Q3-22 from 25 June 2022 to 24 September 2022.
These dates align with automated data downloads and do not correspond precisely to the
conventional start and end of Q3-22. Data for 25 September 2022 and onward will be
included in the Q4-22 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. 5-32 show data from each sensor collected during Q3-22. The
quality assurance summary is on pg. 7.
Approximately 70 mm of precipitation was recorded in Q3-22 from a series of storms
throughout the quarter (Fig. 8), which is more than double the total precipitation received
in 2022 through Q2-22. Total precipitation for 2022 is 103 mm (Table 1). Infiltration from
these storms was managed at the near surface, with only a minor influence on water
content at the shallowest sensors (457 mm bgs, Fig. 14) and no noticeable effect on water
content at greater depths (Fig. 15-20). Small amounts of runoff were transmitted
episodically during Q3-22 in response to storms (Fig. 24). Percolation began in late June,
as occurs each year at the site, and continued at a steady rate throughout Q3-22 (Fig. 30).
2
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.
• There were two periods of extended power loss in July 2022. These appear to have
been caused by a ground fault tripping the ground fault circuit interrupter (GFCI). The
precise cause of this fault is unknown, but is believed to be due to a ground fault in the
sump pump in the vault. The sump pump is a backup device used to remove water
from the vault should the internal drain in the vault clog or be overwhelmed. The pump
will be inspected, and replaced if necessary, during the next maintenance and
calibration event. A visual indicator is posted on the ground surface adjacent to the
vault that indicates whether the vault power is on or off. Site personnel have been
checking the indicator regularly to confirm that the power is on. Importantly, the
datalogger is powered by a solar panel; vault power is only used for the sump pump
in the vault. Therefore, power outages to the vault do not result in any data loss.
4.0 RESOLVED ISSUES
• No issues in need of resolution were reported in the previous DQR (Q2-22).
5.0 ACTION ITEMS
• Continue comparing water content Probes 1 and 2 and Probes 3 and 4.
• Continue to monitor the power in the vault after the two periods of extended power
loss in July 2022.
3
Fig. 1. Schematic of cover profile evaluated at White Mesa.
0
0
0
0
0.5 ft Erosion Layer
3.5 ft Growth Medium
3.0 ft Compacted Cover
2.5 ft Interim Layer
= WCR or thermocouple
4
Fig. 2. Schematic of lysimeter used for the White Mesa Primary Test Section.
64ft
rosion Laver (0.5 ft)
--► I
Runoff
Berm
____________________________ Growth Medium(3.5ft) ____________________ _
Root Barrier
Sump
Percolation Pipe
Compacted
Subgrade
Compacted Cover (3.0 ft)
.. Interim Cover. (2.5. ft) ....... .
60 mil LLDPE GM Geocomposite Drain Compacted
Subgrade
60mil
LLDPE
GM
5
Table 1. Water balance quantities for the final cover test section at White Mesa from 09/29/16 to
09/24/22.
Calendar
Year
Water Balance Quantities (mm)
Precipitation Runoff Lateral
Flow ET 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 223.4 0.19 0.00 242.4 -19.5 0.60
2022 103.1 0.05 0.01 108.6 -6.0 0.22
*Damage from vault flooding precluded measuring flows from 7 February 2017 – 25 March 2017.
6
0
500
1000
1500
0
1
2
3
4
5
9/20/16 9/21/17 9/23/18 9/25/19 9/26/20 9/28/21 9/30/22
Soil Water
Storage
ET
Surface
RunoffPercolation
Lateral FlowSoil Water Storage, Cumulative Precipitation,
and Cumulative Evapotranspiration (mm)
Cumulative Runoff, Lateral Flow, and Percolation (mm)
Precipitation
White Mesa, UT
Fig. 3. Water balance quantities for the final cover test section at White Mesa from
09/29/16 to 09/24/22.
7
DATA QUALITY REPORT SUMMARY: Q3-22
White Mesa Primary Test Section
06/25/22 through 09/24/22
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. 6-13).
• The on-site precipitation data are generally consistent with the NWS data recorded
at the Blanding station (KBDG, 37.62° N, 109.47° W, Elev.: 6001 ft) (Fig. 8).
Independent precipitation measurements recorded by the Geonor gage, and the
tipping bucket are in good agreement (Fig. 9).
• Solar radiation data are consistent with data recorded at the NWS Blanding station
(Fig. 13).
Test Section
• The WCR probes used to measure water content are functioning properly (Figs. 14-
20). Differences in water content of approximately 0.12 are reported by Probes 3 and
4 in the compacted layer at 2134 mm bgs (Fig. 19). Differences in water content of
approximately 0.10 are reported by Probes 1 and 2 in the interim layer at 2743 mm
bgs (Fig. 20). 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.
• The thermocouples used to measure soil temperature are functioning properly (Fig. 21).
• Flows reported by the transducer and tippers for runoff are reasonably consistent
(Figs. 22-24).
• Flows reported by the transducer and tippers for lateral flow are reasonably consistent
(Figs. 25-27).
• Flows reported by the transducer and tippers for percolation are reasonably
consistent (Figs. 28-30).
8
• The vault stage has been negative, indicating no accumulating water (Fig. 31). The
vault pump was checked during the annual maintenance and calibration event on 12
July 2022.
• The voltage sensor that monitors the power supply in the vault is functioning properly
(Fig. 32). Power loss occurred between 07/02/22 and 07/12/22 and 07/14/22 and
07/31/22. No power loss has been recorded since 07/31/22.
9
-
0
10
20
30
40
50
0.0
1.0
2.0
3.0
4.0
5.0
9/20/16 9/21/17 9/23/18 9/25/19 9/26/20 9/28/21 9/30/22
Daily Precipitation (mm)
Cumulative Percolation (m
m)
White Mesa, UT
Percolation
Precipitation
Fig. 4. Daily precipitation (blue) and cumulative percolation (red) for the final cover test
section at White Mesa from 09/29/16 to 09/24/22.
10
11
12
13
14
6/20/22 7/7/22 7/24/22 8/10/22 8/27/22 9/13/22 9/30/22
Battery (Volts)
Fig. 5. Battery voltage for the datalogger at the final cover test section at White Mesa
from 06/25/22 to 09/24/22.
10
6/20/22 7/7/22 7/24/22 8/10/22 8/27/22 9/13/22 9/30/22
0
5
10
15
20
Daily Precipitation (mm)
Fig. 6. Daily precipitation at the final cover test section at White Mesa from 06/25/22
to 09/24/22
6/20/22 7/7/22 7/24/22 8/10/22 8/27/22 9/13/22 9/30/220
1000
2000
3000
Frequency of Geonor Precipitation gauge (Hz)
Calibration
Fig. 7. Frequency of Geonor precipitation gauge at White Mesa from 06/25/22 to
09/24/22. Frequency recorded by load cell is proportional to weight of liquid in
gauge and precipitation.
11
6/20/22 7/7/22 7/24/22 8/10/22 8/27/22 9/13/22 9/30/22
0
20
40
60
80
100
Cu
m
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l
a
t
i
v
e
P
r
e
c
i
p
i
t
a
t
i
o
n
(
m
m
)
White Mesa
NWS Blanding
Fig. 8. Cumulative precipitation at the final cover test section at White Mesa (blue) and
NWS Blanding station (red) from 06/25/22 to 09/24/22.
0
5
10
15
20
25
0 5 10 15 20 25
White Mesa, UT
Ti
p
p
e
r
P
r
e
c
i
p
i
t
a
t
i
o
n
(
m
m
)
Geonor Precipitation (mm)
Fig. 9. Precipitation from tipper and Geonor precipitation gauge at the final cover test
section at White Mesa from 06/25/22 to 09/24/22.
• •
12
6/20/22 7/7/22 7/24/22 8/10/22 8/27/22 9/13/22 9/30/22
Min Air Temp
Avg. Air Temp
Max Air Temp
-10
0
10
20
30
40
Daily Air Temperature (oC)
Fig. 10. Daily air temperature at the final cover test section at White Mesa from 06/25/22
to 09/24/22.
6/20/22 7/7/22 7/24/22 8/10/22 8/27/22 9/13/22 9/30/22
Min RH
Avg. RH
Max RH
0
20
40
60
80
100
120
Daily Relative Humidity (%)
Fig. 11. Daily relative humidity at the final cover test section at White Mesa from
06/25/22 to 09/24/22.
13
0
2
4
6
8
10
6/20/22 7/7/22 7/24/22 8/10/22 8/27/22 9/13/22 9/30/22
Daily Mean Wind Speed (m/s)
Fig. 12. Daily mean wind speed at the final cover test section at White Mesa from
06/25/22 to 09/24/22.
0
2000
4000
6000
8000
10000
6/20/22 7/7/22 7/24/22 8/10/22 8/27/22 9/13/22 9/30/22
Solar Radiation (W-hr/m2)
White Mesa
Blanding
Fig. 13 Total daily solar radiation at the final cover test section at White Mesa (blue)
and NWS Blanding station (red) from 06/25/22 to 09/24/22.
14
0.0
0.1
0.2
0.3
0.4
0.5
6/20/22 7/10/22 7/30/22 8/20/22 9/9/22 9/30/22
White Messa, UT
(457-mm Depth Topsoil Layer)
Vol
u
m
e
t
r
i
c
W
a
t
e
r
C
o
n
t
e
n
t
Probe 13
Probe 14
Fig. 14. Volumetric water content in the growth medium layer (457 mm bgs) of the final
cover test section at White Mesa from 06/25/22 to 09/24/22. Odd numbered
probe is downslope and even is upslope.
0.0
0.1
0.2
0.3
0.4
0.5
6/20/22 7/7/22 7/24/22 8/10/22 8/27/22 9/13/22 9/30/22
White Mesa, UT
(685-mm Depth Growth Medium Layer)
Vo
l
u
m
e
t
r
i
c
W
a
t
e
r
C
o
n
t
e
n
t
Probe 11
Probe 12
Fig. 15. Volumetric water content in the growth medium layer (685 mm bgs) of the final
cover test section at White Mesa from 06/25/22 to 09/24/22. Odd numbered
probe is downslope and even is upslope.
7
15
0.0
0.1
0.2
0.3
0.4
0.5
6/20/22 7/7/22 7/24/22 8/10/22 8/27/22 9/13/22 9/30/22
White Mesa, UT
(914-mm Depth Growth Medium Layer)
Volumetric Water Content
Probe 9
Probe 10
Fig.16. Volumetric water content in the growth medium layer (914 mm bgs) of the final
cover test section at White Mesa from 06/25/22 to 09/24/22. Odd numbered
probe is downslope and even is upslope.
0.0
0.1
0.2
0.3
0.4
0.5
6/20/22 7/7/22 7/24/22 8/10/22 8/27/22 9/13/22 9/30/22
White Mesa, UT
(1524-mm Depth Compacted Layer)
Volumetric Water Content
Probe 8
Probe 7
Fig. 17. Volumetric water content in the compacted layer (1524 mm bgs) of the final
cover test section at White Mesa from 06/25/22 to 09/24/22. Odd numbered
probe is downslope and even is upslope.
16
0.0
0.1
0.2
0.3
0.4
0.5
6/20/22 7/7/22 7/24/22 8/10/22 8/27/22 9/13/22 9/30/22
White Mesa, UT
(1829-mm Depth Compacted Layer)
Vol
u
m
e
t
r
i
c
W
a
t
e
r
C
o
n
t
e
n
t
Probe 6
Probe 5
Fig. 18. Volumetric water content in the compacted layer (1829 mm bgs) of the final
cover test section at White Mesa from 06/25/22 to 09/24/22. Odd numbered
probe is downslope and even is upslope.
0.0
0.1
0.2
0.3
0.4
0.5
6/20/22 7/7/22 7/24/22 8/10/22 8/27/22 9/13/22 9/30/22
White Mesa, UT
(2134-mm Depth Compacted Layer)
Vo
l
u
m
e
t
r
i
c
W
a
t
e
r
C
o
n
t
e
n
t
Probe 4
Probe 3
Fig. 19. Volumetric water content in the compacted layer (2134 mm bgs) of the final
cover test section at White Mesa from 06/25/22 to 09/24/22. Odd numbered
probe is downslope and even is upslope.
\
___________,__ __ ------..L--I ____
17
0.0
0.1
0.2
0.3
0.4
0.5
6/20/22 7/7/22 7/24/22 8/10/22 8/27/22 9/13/22 9/30/22
White Mesa, UT
(2743-mm Depth Interim Layer)
Vol
u
m
e
t
r
i
c
W
a
t
e
r
C
o
n
t
e
n
t
Probe 2
Probe 1
Fig. 20. Volumetric water content in the interim layer (2743 mm bgs) of the final cover
test section at White Mesa from 06/25/22 to 09/24/22. Odd numbered probe is
downslope and even is upslope.
0
10
20
30
40
6/20/22 7/7/22 7/24/22 8/10/22 8/27/22 9/13/22 9/30/22
White Mesa, UT
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 D
914 mm U
685 mm D
685 mm U
457 mm D
457 mm U
So
i
l
T
e
m
p
e
r
a
t
u
e
(
o
C)
2743 mm (D)
457 mm (U)
Fig. 21. Soil temperature in the final cover test section at White Mesa from 06/25/22 to
09/24/22 (sensor depths in mm bgs in legend, D = downslope; U = upslope).
~
18
0
10
20
30
40
50
6/20/22 7/7/22 7/24/22 8/10/22 8/27/22 9/13/22 9/30/22
White Mesa, UT
Cumulative Tips for Runoff
Tipper (1 L)
Calibration
Fig. 22. Cumulative tips from tipper in the runoff basin for the final cover test section at
White Mesa from 06/25/22 to 09/24/22.
0
100
200
300
400
500
6/20/22 7/7/22 7/24/22 8/10/22 8/27/22 9/13/22 9/30/22
White Mesa, UT
Runoff Basin Stage for Runoff (mm)
Calibration
Fig. 23. Pressure transducer stage in the runoff basin for the final cover test section at
White Mesa from 06/25/22 to 09/24/22.
19
0.0
0.1
0.2
0.3
0.4
0.5
6/20/22 7/7/22 7/24/22 8/10/22 8/27/22 9/13/22 9/30/22
White Mesa, UT
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R
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o
f
f
B
a
s
i
n
(
m
m
)
Tipper (1 L)Pressure Transducer
Fig. 24. Cumulative flow from pressure transducer stage and from the tipper in the runoff
basin for the final cover test section at White Mesa from 06/25/22 to 09/24/22.
0
5
10
15
20
6/20/22 7/7/22 7/24/22 8/10/22 8/27/22 9/13/22 9/30/22
White Mesa, UT
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Calibration
Fig. 25. Cumulative tips from tipper in the lateral flow basin for the final cover test section
at White Mesa from 06/25/22 to 09/24/22.
I I r::
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e
Me
s
a
f
r
o
m
0
6
/2
5/22
to
09
/24
/22
.
t -
-
-
21
0
20
0
40
0
60
0
80
0
10
0
0
6/
2
0
/
2
2
7
/
7
/
2
2
7
/
2
4
/
2
2
8
/
1
0
/
2
2
8
/
2
7
/
2
2
9
/
1
3
/
2
2
9
/
3
0
/
2
2
Wh
i
t
e
M
e
s
a
,
U
T
Cumulative Tips for Drainage
Ti
p
p
e
r
(
1
L
)
Ti
p
p
e
r
(
7
0
m
L
)
Fi
g
.
2
8.
Cu
m
u
l
a
t
i
v
e
t
i
p
s
f
r
o
m
t
h
e
t
i
p
p
e
r
i
n
t
h
e
d
r
a
i
n
a
g
e
b
a
s
i
n
f
o
r
t
h
e
f
i
n
a
l
c
o
v
e
r
t
e
st
se
c
t
i
o
n
a
t
W
h
it
e
M
e
s
a
fr
o
m
0
6
/2
5/2
2
to
09
/24
/22
.
0
10
0
20
0
30
0
40
0
50
0
6/
2
0
/
2
2
7
/
7
/
2
2
7
/
2
4
/
2
2
8
/
1
0
/
2
2
8
/
2
7
/
2
2
9
/
1
3
/
2
2
9
/
3
0
/
2
2
Wh
i
t
e
M
e
s
a
,
U
T
Pressure Transducer Stage for Drainage (mm)
Ca
l
i
b
r
a
t
i
o
n
Fi
g
.
29
.
Pr
e
s
s
u
r
e
t
r
a
n
s
d
u
c
e
r
st
a
g
e
in
d
r
a
i
n
a
g
e
b
a
s
i
n
f
o
r
t
h
e
f
i
n
a
l
c
o
v
e
r
t
e
st
s
e
c
t
i
o
n
a
t
Wh
i
te
Me
s
a
f
r
o
m
06
/2
5/2
2
to
09
/2
4
/
2
2
.
t
22
0.0
0.1
0.2
0.3
0.4
0.5
6/20/22 7/7/22 7/24/22 8/10/22 8/27/22 9/13/22 9/30/22
White Mesa, UT
Cumulative Flow in Drainage Basin (mm)
Tipper (70 mL)
Pressure Transducer
Tipper (1 L)
Fig. 30. Cumulative flow from pressure transducer stage and from tippers in drainage
basin for the final cover test section at White Mesa from 06/25/22 to 09/24/22.
-15.0
-10.0
-5.0
0.0
6/20/22 7/7/22 7/24/22 8/10/22 8/27/22 9/13/22 9/30/22
White Mesa, UT
Vault Stage (mm)
Fig. 31. Vault stage for the final cover test section at White Mesa from 06/25/22 to
09/24/22
23
0
50
100
150
200
6/20/22 7/7/22 7/24/22 8/10/22 8/27/22 9/13/22 9/30/22
White Mesa, UT
Va
u
l
t
V
o
l
t
a
g
e
(
v
o
l
t
)
Fig. 32. Vault voltage in the basin for the final cover test section at White Mesa from
06/25/22 to 09/24/22.
I I I I I
-..
I I I I I