DRC-2023-070062 - 0901a068812587d2

Yi,;~
'Cf'#;NERGYFUELS
August 14, 2023
Div of w8~te Management
and Rad. t 011 Cort·ol
AU 15 2 23
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, VS, 80228
303 974 2140
\l'Ww.eni;;r!l\ fuel .com
Re: Transmittal of Q2-23 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 20 I 6 and initiated
performance monitoring. This letter transmits the data quality report for monitoring data collected during the
second quarter of 2023. 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 W einel
Director, Regulatory Compliance
CC: David Frydenlund
Garrin Palmer
Logan Shumway
Scott Bakken
Jordan App
DRC-2023-070062
August 14, 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
3039742140
www .enersz:vfuels.com
Re: Transmittal of Q2-23 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 2023. 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 W einel
Director, Regulatory Compliance
CC: David Frydenlund
Garrin Palmer
Logan Shumway
Scott Bakken
Jordan App

Q2-23 DATA QUALITY REPORT FOR THE
PRIMARY TEST SECTION

WHITE MESA MILL – TAILINGS MANAGEMENT
CELL 2

ENERGY FUELS RESOURCES (USA) INC.

SAN JUAN COUNTY, UTAH

4 August 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
second quarter 2023 (Q2-23). 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 adjacent to
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 2 August 2023.

2.0 WATER BALANCE DATA

Data in this DQR were collected during Q2-23 from 24 March 2023 to 24 June 2023. These
dates align with automated data downloads and do not correspond precisely to the
conventional start and end of Q2-23. Data for 25 June 2023 and onward will be included
in the Q3-23 report.

Table 1 summarizes the water balance quantities and Fig. 3 shows the water balance
graph for the test section. Fig. 4 shows cumulative percolation along with daily
precipitation measured at the test section. Figs. 5-32 show data from each sensor
collected during Q2-23. The quality assurance summary is on pp. 7-8.

Approximately 20 mm of precipitation was recorded in Q2-23 from a series of smaller
storms and two larger storms that occurred in mid-May and early June (Fig. 8). None of
the water content sensors responded to the precipitation events in Q2-23 (Figs. 14-20),
suggesting that infiltration from the larger storms penetrated to shallow depths, and then
rapidly transpired. No runoff or lateral flow was transmitted in Q2-23 (Figs. 22-27) and only
a minute amount (70 mL) of percolation was recorded (Fig. 28).

2
3.0 CONCERNS

• None at this time

4.0 RESOLVED ISSUES

• One of the reed switches on the 70-mL tipping bucket in the percolation basin
malfunctioned in Q4-22, and was repaired during the 2023 annual calibration and
maintenance event on 2 August 2023. There are two redundant reed switches on the
70-mL tipping bucket; thus, no data loss was incurred when the reed switch
malfunctioned.

• One of reed switches on the 1-L tipping bucket in the lateral flow basin was found to
be non-functional during the 2023 annual calibration and maintenance event. This
reed switch was replaced. There are two redundant reed switches on the 1-L tipping
bucket; thus, no data loss was incurred when the reed switch malfunctioned.

• The apparent periodic loss of power to the vault that was reported over the past year
has been resolved. The sensing device used to monitor power in the vault was
determined to be defective, and was replaced during the 2023 annual calibration and
maintenance event on 2 August 2023. No actual power loss occurred.

5.0 ACTION ITEMS

• None at this time.

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
06/24/23.
Calendar
Year
Water Balance Quantities (mm)
Precipitation Runoff Lateral
Flow ET D Storage Percolation
2016a 59.9 0.03 0.00 34.6 16.9 0.00
2017b 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 179.8 0.11 0.01 168.9 25.0 0.28
2023 164.1 0.08 0.00 172.4 -22.6 0.00
Notes: aPartial year. bDamage 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 06/24/23.
0
500
1000
1500
2000
0
1
2
3
4
5
9/20/16 11/6/17 12/23/18 2/9/20 3/27/21 5/13/22 6/30/23
Soil Water
Storage
ET
Surface
Runoff
Percolation
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: Q2-23
White Mesa Primary Test Section
03/24/23 through 06/24/23

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 agreement (Fig. 9).
• Solar radiation data are consistent with data recorded at the NWS Blanding station
(Fig. 13).

Test Section
• The WCR probes for measuring water content are functioning properly (Figs. 14-20).
Differences in water content of approximately 0.08 are reported by Probes 3 and 4 in
the compacted layer at 2134 mm bgs (Fig. 19). Differences in water content of
approximately 0.06 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 decreasing and negative, indicating no accumulating water
(Fig. 31).
• The voltage sensor that monitors the power supply in the vault is functioning properly
(Fig. 32). Not-a-number (NAN) readings were recorded intermittently between
3/31/23 and 4/12/23. These NAN readings are due to a defect in the sensor, which
was replaced on 8/2/23. NAN readings are not anticipated in the future.

9

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0
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Battery (Volts)
t

10

Fig. 6. Daily precipitation at the final cover test section at White Mesa from 03/24/23
to 06/24/23.

Fig. 7. Frequency of Geonor precipitation gauge at White Mesa from 03/24/23 to
06/24/23. Frequency recorded by load cell is proportional to weight of liquid in
gauge and precipitation.
3/20/23 4/6/23 4/23/23 5/10/23 5/27/23 6/13/23 6/30/23
0
2
4
6
8
10
Daily Precipitation (mm)
3/20/23 4/6/23 4/23/23 5/10/23 5/27/23 6/13/23 6/30/230
1000
2000
3000
Frequency of Geonor Precipitation Gauge (Hz)

11

Fig. 8. Cumulative precipitation at the final cover test section at White Mesa (blue) and
NWS Blanding station (red) from 03/24/23 to 06/24/23.

Fig. 9. Precipitation from tipper and Geonor precipitation gauge at the final cover test
section at White Mesa from 03/24/23 to 06/24/23.
3/20/23 4/6/23 4/23/23 5/10/23 5/27/23 6/13/23 6/30/23
0
10
20
30
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. Daily air temperature at the final cover test section at White Mesa from 03/24/23
to 06/24/23.

Fig. 11. Daily relative humidity at the final cover test section at White Mesa from
03/24/23 to 06/24/23.
3/20/23 4/6/23 4/23/23 5/10/23 5/27/23 6/13/23 6/30/23
Min Air Temp
Avg. Air Temp
Max Air Temp
-10
0
10
20
30
40
Daily Air Temperature (oC)
3/20/23 4/6/23 4/23/23 5/10/23 5/27/23 6/13/23 6/30/23
Min RH
Avg. RH
Max RH
0
20
40
60
80
100
120
D
aily Relative Humidity (%)

13

Fig. 12. Daily mean wind speed at the final cover test section at White Mesa from
03/24/23 to 06/24/23.

Fig. 13 Total daily solar radiation at the final cover test section at White Mesa (blue)
and NWS Blanding station (red) from 03/24/23 to 06/24/23.
0
2
4
6
8
10
3/20/23 4/6/23 4/23/23 5/10/23 5/27/23 6/13/23 6/30/23
Daily Mean Wind Speed (m/s)
0
2000
4000
6000
8000
10000
3/20/23 4/6/23 4/23/23 5/10/23 5/27/23 6/13/23 6/30/23
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 03/24/23 to 06/24/23. 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 03/24/23 to 06/24/23. Odd numbered
probe is downslope and even is upslope.
0.0
0.1
0.2
0.3
0.4
0.5
3/20/23 4/9/23 4/29/23 5/20/23 6/9/23 6/30/23
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
3/20/23 4/6/23 4/23/23 5/10/23 5/27/23 6/13/23 6/30/23
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 03/24/23 to 06/24/23. 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 03/24/23 to 06/24/23. Odd numbered
probe is downslope and even is upslope.
0.0
0.1
0.2
0.3
0.4
0.5
3/20/23 4/6/23 4/23/23 5/10/23 5/27/23 6/13/23 6/30/23
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
3/20/23 4/6/23 4/23/23 5/10/23 5/27/23 6/13/23 6/30/23
White Mesa, UT
(1524-mm Depth Compacted Layer)
Volumetric Water Content
Probe 8
Probe 7
7

16

Fig. 18. Volumetric water content in the compacted layer (1829 mm bgs) of the final
cover test section at White Mesa from 03/24/23 to 06/24/23. 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 03/24/23 to 06/24/23. Odd numbered
probe is downslope and even is upslope.
0.0
0.1
0.2
0.3
0.4
0.5
3/20/23 4/6/23 4/23/23 5/10/23 5/27/23 6/13/23 6/30/23
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
3/20/23 4/6/23 4/23/23 5/10/23 5/27/23 6/13/23 6/30/23
White Mesa, UT
(2134-mm Depth Compacted Layer)
Volumetric Water Content
Probe 4
Probe 3
\
____ , ------------

17

Fig. 20. Volumetric water content in the interim layer (2743 mm bgs) of the final cover
test section at White Mesa from 03/24/23 to 06/24/23. Odd numbered probe is
downslope and even is upslope.

Fig. 21. Soil temperature in the final cover test section at White Mesa from 03/24/23 to
06/24/23 (sensor depths in mm bgs in legend, D = downslope; U = upslope).

0.0
0.1
0.2
0.3
0.4
0.5
3/20/23 4/6/23 4/23/23 5/10/23 5/27/23 6/13/23 6/30/23
White Mesa, UT
(2743-mm Depth Interim Layer)
Volumetric Water Content
Probe 2
Probe 1
-10
0
10
20
30
40
3/20/23 4/6/23 4/23/23 5/10/23 5/27/23 6/13/23 6/30/23
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 03/24/23 to 06/24/23.

Fig. 23. Pressure transducer stage in the runoff basin for the final cover test section at
White Mesa from 03/24/23 to 06/24/23.

0
1
2
3
4
5
3/20/23 4/6/23 4/23/23 5/10/23 5/27/23 6/13/23 6/30/23
White Mesa, UT
Cumulative Tips for Runoff
Tipper (1 L)
0
100
200
300
400
500
3/20/23 4/6/23 4/23/23 5/10/23 5/27/23 6/13/23 6/30/23
White Mesa, UT
Runoff Basin Stage for Runoff (mm)
I I I I I
-
-
-
... -
I -

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 04/24/23 to 06/24/23.

Fig. 25. Cumulative tips from tipper in the lateral flow basin for the final cover test section
at White Mesa from 03/24/23 to 06/24/23.

0.0
0.1
0.2
0.3
0.4
0.5
3/20/23 4/6/23 4/23/23 5/10/23 5/27/23 6/13/23 6/30/23
White Mesa, UT
Cumulative Flow in Runoff Basin (mm)
Tipper (1 L)Pressure Transducer
0
1
2
3
4
5
3/20/23 4/6/23 4/23/23 5/10/23 5/27/23 6/13/23 6/30/23
White Mesa, UT
Cumulative Tips for Lateral Flow
Tipper (1 L)

20

Fig. 26. Pressure transducer stage in lateral flow basin for the final cover test section at
White Mesa from 03/24/23 to 06/24/23.

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 03/24/23 to 06/24/23.
0
100
200
300
400
500
3/20/23 4/6/23 4/23/23 5/10/23 5/27/23 6/13/23 6/30/23
White Mesa, UT
Pressure Transducer Stage for Lateral Flow (mm)
0.0
0.1
0.2
0.3
0.4
0.5
3/20/23 4/6/23 4/23/23 5/10/23 5/27/23 6/13/23 6/30/23
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 03/24/23 to 06/2324/23.
3

Fig. 29. Pressure transducer stage in drainage basin for the final cover test section at
White Mesa from 03/24/23 to 06/24/23.

0
1
2
3
4
5
3/20/23 4/6/23 4/23/23 5/10/23 5/27/23 6/13/23 6/30/23
White Mesa, UT
Cumulative Tips for Drainage
Tipper (1 L)
Tipper (70 mL)
0
100
200
300
400
500
3/20/23 4/6/23 4/23/23 5/10/23 5/27/23 6/13/23 6/30/23
White Mesa, UT
Pressure Transducer Stage for Drainage (mm)
I -

22

Fig. 30. Cumulative flow from pressure transducer stage and from tippers in drainage
basin for the final cover test section at White Mesa from 03/24/23 to 06/24/23.

Fig. 31. Vault stage for the final cover test section at White Mesa from 03/24/23 to
06/24/23.

0.0
0.1
0.2
0.3
0.4
0.5
3/20/23 4/6/23 4/23/23 5/10/23 5/27/23 6/13/23 6/30/23
White Mesa, UT
Cumulative Flow in Drainage Basin (mm)
Tipper (70 mL)Pressure TransducerTipper (1 L)
-15.0
-10.0
-5.0
0.0
3/20/23 4/6/23 4/23/23 5/10/23 5/27/23 6/13/23 6/30/23
White Mesa,UT
Vault Stage (mm)

23

Fig. 32. Vault voltage in the basin for the final cover test section at White Mesa from
03/24/23 to 06/24/23.
0
50
100
150
200
3/20/23 4/6/23 4/23/23 5/10/23 5/27/23 6/13/23 6/30/23
White Mesa, UT
Vault Voltage (volt)