HomeMy WebLinkAboutDRC-2023-001493 - 0901a06881189ec4?;i.t;,,,
��NERGYFUELS February 13, 202 3 Sent VIA E-MAIL AND EXPRESS DELIVERY Mr. Doug Hansen Director Division of Waste Management and Radiation Control Utah Department of Environmental Quality 195North 1950West Salt Lake City, UT 84 114-4880 " Energy Fuels Resources (USA) Inc. 225 Union Blvu. Suite 600 Lal.ewood, CO, U , 80228 303 97-t 21-t0 \\ \\'\\ .l:111!1'•1 \ ruels.C_..!.)}
Re: Transmittal of Q4-22 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 fourth quarter of 202 2. 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 303-38 9-4 I 34. Yours very truly, ENERGY FUELS RESOURCES (USA) INC.Kathy Weinel Director, Regulatory Compliance CC: David Frydenlund Garrin Palmer Logan Shumway Scott Bakken
'1t
DRC-2023-001493
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~~ERGYFUELS
February 13, 2023
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
\ W\ .cnerg\ fuels.com
Re: Transmittal of Q4-22 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"), EFRl 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
fourth 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
Q4-22 DATA QUALITY REPORT FOR THE
PRIMARY TEST SECTION
WHITE MESA MILL – TAILINGS MANAGEMENT
CELL 2
ENERGY FUELS RESOURCES (USA) INC.
SAN JUAN COUNTY, UTAH
24 January 2023
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
fourth quarter 2022 (Q4-22). 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 Q4-22 from 25 September 2022 to 24 December
2022. These dates align with automated data downloads and do not correspond precisely
to the conventional start and end of Q4-22. Data for 25 December 2022 and onward will
be included in the Q1-23 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 Q4-22. The
quality assurance summary is on pp. 7-8.
Approximately 60 mm of precipitation was recorded in Q4-22 from a series of storms
throughout the quarter (Fig. 8). Total precipitation for 2022 through the end of this reporting
period is 160 mm (Table 1), which is the second driest year since monitoring began.
Infiltration from the 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). A small amount of runoff (<0.1 mm) was
transmitted during Q4-22, with most in response to storms at the end of September and
2
the beginning of November (Fig. 24). No lateral flow was transmitted. Percolation began
tailing in October and ceased in late November (Fig. 30).
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.
• One of the reed switches on the 70-mL tipping bucket in the percolation basin is no
longer functioning. This switch is used to record tip counts from the 70-mL tipping
bucket, which are converted to percolation rates. This reed switch will be replaced
during the 2023 annual calibration and maintenance activity. The percolation basin is
equipped with redundant reed switches on each tipping bucket, and four different
redundant measures of percolation. Thus, no data loss is incurred by malfunctioning
of this reed switch.
• No power loss to the vault occurred in Q4-22, and none has occurred since the power
loss that occurred in July 2022. Nevertheless, power to the vault remains on watch,
and the ground fault circuit interrupter (GFCI) and the sump pump in the vault will be
inspected and replaced, if necessary, during the 2023 annual calibration and
maintenance activity. Vault power is only used for the sump pump in the vault.
Therefore, power loss to the vault does not result in data loss.
4.0 RESOLVED ISSUES
• None for Q4-22.
5.0 ACTION ITEMS
• Continue comparing water content Probes 1 and 2 and Probes 3 and 4.
• Replace reed switch on 70-mL tipping bucket in percolation basin during 2023 annual
calibration and maintenance visit.
• Continue to monitor power in the vault.
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
0 = WCR or thermocouple
4
Fig. 2. Schematic of lysimeter used for the White Mesa Primary Test Section.
rosion layer (0.5 ft)
____________________________ Growth Medium (3.5 ft) ____________________ _
Root Barrier
Sump
Percolation Pipe
Compacted
Subgrade
Compacted Cover (3.0 ft)
.................................. 1nterim .cover (2.S_ftJ.
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
12/24/22.
Calendar
Year
Water Balance Quantities (mm)
Precipitation Runoff Lateral
Flow ET D 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 160.0 0.10 0.01 168.9 -5.8 0.28
*damage from vault flooding precluded measuring flows from 7 February 2017 – 25 March
2017.
6
Fig. 3. Water balance quantities for the final cover test section at White Mesa from
09/29/16 to 12/24/22.
0
500
1000
1500
0
1
2
3
4
5
9/20/16 10/7/17 10/24/18 11/10/19 11/26/20 12/13/21 12/31/22
Soil Water
Storage
ET
Surface
RunoffPercolation
Lateral Flow
Soil Water Storage, Cumulative Precipitation,
and Cumulative Evapotranspiration (mm)
Cumulative Runoff, Lateral Flow, and Percolation (mm)
Precipitation
White Mesa, UT
7
DATA QUALITY REPORT SUMMARY: Q4-22
White Mesa Primary Test Section
09/25/22 through 12/24/22
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 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).
8
• Flows reported by the transducer and tippers for percolation are reasonably
consistent (Figs. 28-30). However, reed switch 1A is no longer reporting tips (Fig. 28).
Reed switch 1A should be replaced.
• The vault stage has been negative, indicating no accumulating water (Fig. 31).
• The voltage sensor that monitors the power supply in the vault is functioning properly
(Fig. 32). Power to the vault for the sump pump has been continuous throughout Q4-
22.
9
-
Fig. 4. Daily precipitation (blue) and cumulative percolation (red) for the final cover test
section at White Mesa from 09/29/16 to 12/24/22.
Fig. 5. Battery voltage for the datalogger at the final cover test section at White Mesa
from 09/25/22 to 12/24/22.
0
10
20
30
40
50
0.0
1.0
2.0
3.0
4.0
5.0
9/20/16 10/7/17 10/24/18 11/10/19 11/26/20 12/13/21 12/31/22
Daily Precipitation (mm
)
C
um
ulative Percolation (mm)
White Mesa, UT
Percolation
Precipitation
10
11
12
13
14
9/20/22 10/7/22 10/24/22 11/10/22 11/27/22 12/14/22 12/31/22
Battery (Volts)
10
Fig. 6. Daily precipitation at the final cover test section at White Mesa from 09/25/22
to 12/24/22
Fig. 7. Frequency of Geonor precipitation gauge at White Mesa from 09/25/22 to
12/24/22. Frequency recorded by load cell is proportional to weight of liquid in
gauge and precipitation.
9/20/22 10/7/22 10/24/22 11/10/22 11/27/22 12/14/22 12/31/22
0
5
10
15
20
Daily Precipitation (mm)
9/20/22 10/7/22 10/24/22 11/10/22 11/27/22 12/14/22 12/31/220
1000
2000
3000
Frequency of Geonor Precipitation gauge (Hz).
--
--
I I I I I
11
Fig. 8. Cumulative precipitation at the final cover test section at White Mesa (blue) and
NWS Blanding station (red) from 09/25/22 to 12/24/22.
Fig. 9. Precipitation from tipper and Geonor precipitation gauge at the final cover test
section at White Mesa from 09/25/22 to 12/24/22.
9/20/22 10/7/22 10/24/22 11/10/22 11/27/22 12/14/22 12/31/22
0
20
40
60
80
100
Cumulative Precipitation (mm)
White Mesa
NWS Blanding
0
5
10
15
20
25
0 5 10 15 20 25
White Mesa, UT
Tipper Precipitation (mm)
Geonor Precipitation (mm)
• •
•
12
Fig. 10. Dily air temperature at the final cover test section at White Mesa from 09/25/22
to 12/24/22.
Fig. 11. Daily relative humidity at the final cover test section at White Mesa from
09/25/22 to 12/24/22.
9/20/22 10/7/22 10/24/22 11/10/22 11/27/22 12/14/22 12/31/22
Min Air Temp
Avg. Air Temp
Max Air Temp
-20
-10
0
10
20
30
Daily Air Temperature (oC)
9/20/22 10/7/22 10/24/22 11/10/22 11/27/22 12/14/22 12/31/22
Min RH
Avg. RH
Max RH
0
20
40
60
80
100
120
Daily Relative Humidity (%)
13
Fig. 12. Daily mean wind speed at the final cover test section at White Mesa from
09/25/22 to 12/24/22.
Fig. 13 Total daily solar radiation at the final cover test section at White Mesa (blue)
and NWS Blanding station (red) from 09/25/22 to 12/24/22.
0
2
4
6
8
10
9/20/22 10/7/22 10/24/22 11/10/22 11/27/22 12/14/22 12/31/22
Daily Mean Wind Speed (m/s)
0
2000
4000
6000
8000
10000
9/20/22 10/7/22 10/24/22 11/10/22 11/27/22 12/14/22 12/31/22
Solar Radiation (W-hr/m2)
White Mesa
Blanding
14
Fig. 14. Volumetric water content in the growth medium layer (457 mm bgs) of the final
cover test section at White Mesa from 09/25/22 to 12/24/22. Odd numbered
probe is downslope and even is upslope.
Fig. 15. Volumetric water content in the growth medium layer (685 mm bgs) of the final
cover test section at White Mesa from 09/25/22 to 12/24/22. Odd numbered
probe is downslope and even is upslope.
0.0
0.1
0.2
0.3
0.4
0.5
9/20/22 10/10/22 10/30/22 11/20/22 12/10/22 12/31/22
White Mesa, UT
(457-mm Depth Topsoil Layer)
Volumetric Water Content
Probe 13
Probe 14
0.0
0.1
0.2
0.3
0.4
0.5
9/20/22 10/7/22 10/24/22 11/10/22 11/27/22 12/14/22 12/31/22
White Mesa, UT
(685-mm Growth Medium Layer)
Volumetric Water Content
Probe 11
Probe 12
15
Fig.16. Volumetric water content in the growth medium layer (914 mm bgs) of the final
cover test section at White Mesa from 09/25/22 to 12/24/22. Odd numbered
probe is downslope and even is upslope.
Fig. 17. Volumetric water content in the compacted layer (1524 mm bgs) of the final
cover test section at White Mesa from 09/25/22 to 12/24/22. Odd numbered
probe is downslope and even is upslope.
0.0
0.1
0.2
0.3
0.4
0.5
9/20/22 10/7/22 10/24/22 11/10/22 11/27/22 12/14/22 12/31/22
White Mesa, UT
(914-mm Depth Growth Medium Layer)
Volumetric Water Content
Probe 9
Probe 10
0.0
0.1
0.2
0.3
0.4
0.5
9/20/22 10/7/22 10/24/22 11/10/22 11/27/22 12/14/22 12/31/22
White Mesa, UT
(1524-mm Depth Compacted Layer)
Volumetric Water Content
Probe 8
Probe 7
~--_...z:....__I __
16
Fig. 18. Volumetric water content in the compacted layer (1829 mm bgs) of the final
cover test section at White Mesa from 09/25/22 to 12/24/22. Odd numbered
probe is downslope and even is upslope.
Fig. 19. Volumetric water content in the compacted layer (2134 mm bgs) of the final
cover test section at White Mesa from 09/25/22 to 12/24/22. Odd numbered
probe is downslope and even is upslope.
0.0
0.1
0.2
0.3
0.4
0.5
9/20/22 10/7/22 10/24/22 11/10/22 11/27/22 12/14/22 12/31/22
White Mesa, UT
(1829-mm Depth Compacted Layer)
Volumetric Water Content
Probe 6
Probe 5
0.0
0.1
0.2
0.3
0.4
0.5
9/20/22 10/7/22 10/24/22 11/10/22 11/27/22 12/14/22 12/31/22
White Mesa, UT
(2134-mm Depth Compacted Layer)
Volumetric Water Content
Probe 4
Probe 3
___ \
I _____ / __ _
17
Fig. 20. Volumetric water content in the interim layer (2743 mm bgs) of the final cover
test section at White Mesa from 09/25/22 to 12/24/22. Odd numbered probe is
downslope and even is upslope.
Fig. 21. Soil temperature in the final cover test section at White Mesa from 09/25/22 to
12/24/22 (sensor depths in mm bgs in legend, D = downslope; U = upslope).
0.0
0.1
0.2
0.3
0.4
0.5
9/20/22 10/7/22 10/24/22 11/10/22 11/27/22 12/14/22 12/31/22
White Mesa, UT
(2743-mm Depth Interim Layer)
Volumetric Water Content
Probe 2
Probe 1
-10
0
10
20
30
9/20/22 10/7/22 10/24/22 11/10/22 11/27/22 12/14/22 12/31/22
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
Soil Temperatue (oC)2743 mm (D)
457 mm (U)
I
18
Fig. 22. Cumulative tips from tipper in the runoff basin for the final cover test section at
White Mesa from 09/25/22 to 12/24/22.
Fig. 23. Pressure transducer stage in the runoff basin for the final cover test section at
White Mesa from 09/25/22 to 12/24/22.
0
5
10
15
20
9/20/22 10/7/22 10/24/22 11/10/22 11/27/22 12/14/22 12/31/22
White Mesa, UT
Cumulative Tips for Runoff
Tipper (1 L)
0
100
200
300
400
500
9/20/22 10/7/22 10/24/22 11/10/22 11/27/22 12/14/22 12/31/22
White Mesa, UT
Runoff Basin Stage for Runoff (mm)
19
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 09/25/22 to 12/24/22.
Fig. 25. Cumulative tips from tipper in the lateral flow basin for the final cover test section
at White Mesa from 09/25/22 to 12/24/22.
0.0
0.1
0.2
0.3
0.4
0.5
9/20/22 10/7/22 10/24/22 11/10/22 11/27/22 12/14/22 12/31/22
White Mesa, UT
Cumulative Flow in Runoff Basin (mm)
Tipper (1 L)
Pressure Transducer
0
1
2
3
4
5
9/20/22 10/7/22 10/24/22 11/10/22 11/27/22 12/14/22 12/31/22
White Mesa, UT
Cumulative Tips for Lateral Flow
Tipper (1 L)
-_J
I \ ~--------
20
Fig. 26. Pressure transducer stage in lateral flow basin for the final cover test section at
White Mesa from 09/25/22 to 12/24/22.
Fig. 27. Cumulative flow from pressure transducer stage and from tipper in lateral flow
basin for the final cover test section at White Mesa from 09/25/22 to 12/24/22.
0
100
200
300
400
500
9/20/22 10/7/22 10/24/22 11/10/22 11/27/22 12/14/22 12/31/22
White Mesa, UT
Pressure Transducer Stage for Lateral Flow (mm)
0.0
0.1
0.2
0.3
0.4
0.5
9/20/22 10/7/22 10/24/22 11/10/22 11/27/22 12/14/22 12/31/22
White Mesa, UT
Cumulative Flow in Lateral Flow Basin (mm)
Tipper (1 L)Pressure Transducer
21
Fig. 28. Cumulative tips from the tipper in the drainage basin for the final cover test
section at White Mesa from 09/25/22 to 12/24/22.
Fig. 29. Pressure transducer stage in drainage basin for the final cover test section at
White Mesa from 09/25/22 to 12/24/22.
0
50
100
150
200
250
9/20/22 10/7/22 10/24/22 11/10/22 11/27/22 12/14/22 12/31/22
White Mesa, UT
Cumulative Tips for Drainage
Tipper (1 L)
Tipper 1B (70 mL)
Tipper 1A (70 mL)
0
100
200
300
400
500
9/20/22 10/7/22 10/24/22 11/10/22 11/27/22 12/14/22 12/31/22
White Mesa, UT
Pressure Transducer Stage for Drainage (mm)
22
Fi
g
.
3
0
.
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4
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/27
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/2
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/2
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0.0
0.1
0.2
0.3
0.4
0.5
9/20/22
10/7/22
10/24/22
11/10/22
11/27/22
12/14/22
12/31/22
White Mesa, UT
Cumulative Flow in Drainage Basin (mm)
Tipper (70 mL)
Pressure Transducer
Tipper (1 L)
-1
5
.
0
-1
0
.
0
-5
.
0
0.
0
9/
2
0
/
2
2
10
/
7
/
2
2
10
/
2
4
/
2
2
11
/
1
0
/
2
2
11
/
2
7
/
2
2
12
/
1
4
/
2
2
12
/
3
1
/
2
2
Wh
i
t
e
M
e
s
a
,
U
T
Vault Stage (mm)
t
23
Fig. 32. Vault voltage in the basin for the final cover test section at White Mesa from
09/25/22 to 12/24/22.
0
50
100
150
200
9/20/22 10/7/22 10/24/22 11/10/22 11/27/22 12/14/22 12/31/22
White Mesa, UT
Vault Voltage (volt)