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HomeMy WebLinkAboutDRC-2023-004268 - 0901a068811f607ef A~ ---~'T;NERGYFUELS May 9, 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, LJS, 80228 303 974 2140 \\'\\ w.ener!!.\ fu I .com Div of Wa.,te Management and Radiation Control MAY 12 2023 Re: Transmittal of Ql-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 first 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 Weinel Director, Regulatory Compliance CC: David Frydenlund Garrin Palmer Logan Shumway Scott Bakken DRC-2023-004268 (7S:-'1 £1 /·-~~ ~ ~ r- ~ ~ V ENERGYFUELS May 9, 2023 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 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 Ql-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 first 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 Weinel Director, Regulatory Compliance CC: David Frydenlund Garrin Palmer Logan Shumway Scott Balcken Q1-23 DATA QUALITY REPORT FOR THE PRIMARY TEST SECTION WHITE MESA MILL – TAILINGS MANAGEMENT CELL 2 ENERGY FUELS RESOURCES (USA) INC. SAN JUAN COUNTY, UTAH 28 April 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 first quarter 2023 (Q1-23). 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 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 Q1-23 from 25 December 2022 to 23 March 2023. These dates align with automated data downloads and do not correspond precisely to the conventional start and end of Q1-23. Data for 24 March 2023 and onward will be included in the Q2-23 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 Q1-23. The quality assurance summary is on pp. 7-8. Nearly 146 mm of precipitation was recorded in Q1-23 from a series of storms that occurred throughout the quarter (Fig. 8). The precipitation received in Q1-23 equals 81% of the total precipitation received in 2022, indicating that 2023 is beginning as a wet year. Infiltration from rainfall and snowmelt has penetrated to a depth of 914 mm (Fig. 16), and will likely penetrate further in Q2-23. Water contents at shallower depths are elevated relative to past levels. A small amount of runoff ( 0.08 mm) was transmitted in a series of events throughout Q1-23 corresponding to rainfall and snowmelt (Fig. 24). No lateral flow or percolation was transmitted (Figs. 27, 30). 2 3.0 CONCERNS • One of the reed switches on the 70-mL tipping bucket in the percolation basin malfunctioned in Q4-22 and remains non-functional. 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. • Power loss to the vault occurred very briefly in mid-January, with the power restored promptly without intervention. This likely was a power outage in the areas behind the mill rather than an issue with the ground fault circuit interrupter (GFCI) in the vault. Nevertheless, power to the vault will remain on watch, and the 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 • The significant differences in water content between Probes 1 and 2 and between Probes 3 and 4 that initiated in 2017 in response to heavy infiltration due to snow melt are diminishing. These differences are no longer a concern and have been removed from Section 3.0 – Concerns. 5.0 ACTION ITEMS • Replace the nonfunctional reed switch during the 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 = 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 03/23/23. Calendar Year Water Balance Quantities (mm) Precipitation Runoff Lateral Flow ET  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 145.7 0.08 0.00 51.3 128.0 0.00 Notes: aPartial year. bDamage 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 10/22/17 11/23/18 12/25/19 1/25/21 2/26/22 3/31/23 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 Fig. 3. Water balance quantities for the final cover test section at White Mesa from 09/29/16 to 03/23/23. 7 DATA QUALITY REPORT SUMMARY: Q1-23 White Mesa Primary Test Section 12/25/22 through 03/23/23 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 not in agreement (Fig. 9), most likely due to snow accumulation (the tipping bucket does not register snowfall). Agreement between the Geonor gage and the tipping bucket will be reviewed again in Q2-23, when snowfall is unlikely. • 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 0.07 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). • 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). There was one brief interruption in vault power in Q1-23. 9 0 10 20 30 40 50 0.0 1.0 2.0 3.0 4.0 5.0 9/20/16 10/22/17 11/23/18 12/25/19 1/25/21 2/26/22 3/31/23 Daily Precipitation (mm) C um ul ative 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 03/23/23. 10 11 12 13 14 12/20/22 1/5/23 1/22/23 2/8/23 2/25/23 3/14/23 3/31/23 Battery (Volts) Fig. 5. Battery voltage for the datalogger at the final cover test section at White Mesa from 12/25/22 to 03/23/23. 10 12/20/22 1/5/23 1/22/23 2/8/23 2/25/23 3/14/23 3/31/23 0 5 10 15 20 Da i l y P r e c i p i t a t i o n ( m m ) Fig. 6. Daily precipitation at the final cover test section at White Mesa from 12/25/22 to 03/23/23. 12/20/22 1/5/23 1/22/23 2/8/23 2/25/23 3/14/23 3/31/23 0 1000 2000 3000 Fr e q u e n c y o f G e o n o r P r e c i p i t a t i o n G a u g e ( H z ) Fig. 7. Frequency of Geonor precipitation gauge at White Mesa from 12/25/22 to 03/23/23. Frequency recorded by load cell is proportional to weight of liquid in gauge and precipitation. I I I I I -- n -- -- ---------,-~' U'y-k__J I .,._ - 11 12/20/22 1/6/23 1/23/23 2/9/23 2/25/23 3/14/23 3/31/23 0 50 100 150 200 Cu m u 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 12/25/22 to 03/23/23. 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 12/25/22 to 03/23/23. \ • • l • • • 12 12/20/22 1/5/23 1/22/23 2/8/23 2/25/23 3/14/23 3/31/23 Min Air Temp Avg. Air Temp Max Air Temp -20 -10 0 10 20 30 Daily Air Temperature (oC) Fig. 10. Daily air temperature at the final cover test section at White Mesa from 12/25/22 to 03/23/23. 12/20/22 1/5/23 1/22/23 2/8/23 2/25/23 3/14/23 3/31/23 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 12/25/22 to 03/23/23. 13 0 2 4 6 8 10 12/20/22 1/5/23 1/22/23 2/8/23 2/25/23 3/14/23 3/31/23 Daily Mean Wind Speed (m/s) Fig. 12. Daily mean wind speed at the final cover test section at White Mesa from 12/25/22 to 03/23/23. 0 2000 4000 6000 8000 10000 12/20/22 1/5/23 1/22/23 2/8/23 2/25/23 3/14/23 3/31/23 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 12/25/22 to 03/23/23. 14 0.0 0.1 0.2 0.3 0.4 0.5 12/20/22 1/9/23 1/29/23 2/18/23 3/10/23 3/31/23 White Mesa, UT (457-mm Depth Topsoil Layer) Volumetric Water Content 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 12/25/22 to 03/23/23. Odd numbered probe is downslope and even is upslope. 0.0 0.1 0.2 0.3 0.4 0.5 12/20/22 1/5/23 1/22/23 2/8/23 2/25/23 3/14/23 3/31/23 White Mesa, UT (685-mm Growth Medium Layer) Volumetric Water Content 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 12/25/22 to 03/23/23. Odd numbered probe is downslope and even is upslope. 15 0.0 0.1 0.2 0.3 0.4 0.5 12/20/22 1/5/23 1/22/23 2/8/23 2/25/23 3/14/23 3/31/23 White Mesa, UT (914-mm Depth Growth Medium Layer) Vol u m e t r i c W a t e r C o n t e n t 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 12/25/22 to 03/23/23. Odd numbered probe is downslope and even is upslope. 0.0 0.1 0.2 0.3 0.4 0.5 12/31/22 1/17/23 2/3/23 2/20/23 3/8/23 3/25/23 White Mesa, UT (1524-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 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 12/25/22 to 03/23/23. Odd numbered probe is downslope and even is upslope. 7' 16 0.0 0.1 0.2 0.3 0.4 0.5 12/20/22 1/5/23 1/22/23 2/8/23 2/25/23 3/14/23 3/31/23 White Mesa, UT (1829-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 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 12/25/22 to 03/23/23. Odd numbered probe is downslope and even is upslope. 0.0 0.1 0.2 0.3 0.4 0.5 12/20/22 1/5/23 1/22/23 2/8/23 2/25/23 3/14/23 3/31/23 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 12/25/22 to 03/23/23. Odd numbered probe is downslope and even is upslope. \ 17 0.0 0.1 0.2 0.3 0.4 0.5 12/20/22 1/5/23 1/22/23 2/8/23 2/25/23 3/14/23 3/31/23 White Mesa, UT (2743-mm Depth Interim Layer) Vo l 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 12/25/22 to 03/23/23. Odd numbered probe is downslope and even is upslope. -10 0 10 20 30 12/20/22 1/5/23 1/22/23 2/8/23 2/25/23 3/14/23 3/31/23 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 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 12/25/22 to 03/23/23 (sensor depths in mm bgs in legend, D = downslope; U = upslope). I_ - L ~~~ 18 0 5 10 15 20 12/20/22 1/5/23 1/22/23 2/8/23 2/25/23 3/14/23 3/31/23 White Mesa, UT Cumulative Tips for Runoff Tipper (1 L) Fig. 22. Cumulative tips from tipper in the runoff basin for the final cover test section at White Mesa from 12/25/22 to 03/23/23. 0 100 200 300 400 500 12/20/22 1/5/23 1/22/23 2/8/23 2/25/23 3/14/23 3/31/23 White Mesa, UT Runoff Basin Stage for Runoff (mm) Fig. 23. Pressure transducer stage in the runoff basin for the final cover test section at White Mesa from 12/25/22 to 03/23/23. 19 0.0 0.1 0.2 0.3 0.4 0.5 12/20/22 1/5/23 1/22/23 2/8/23 2/25/23 3/14/23 3/31/23 White Mesa, UT Cumulative Flow in Runoff Basin (mm) 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 12/25/22 to 03/23/23. 0 1 2 3 4 5 12/20/22 1/5/23 1/22/23 2/8/23 2/25/23 3/14/23 3/31/23 White Mesa, UT Cumulative Tips for Lateral Flow Tipper (1 L) Fig. 25. Cumulative tips from tipper in the lateral flow basin for the final cover test section at White Mesa from 12/25/22 to 03/23/23. 20 0 100 200 300 400 500 12/20/22 1/5/23 1/22/23 2/8/23 2/25/23 3/14/23 3/31/23 White Mesa, UT Pr e s s u r e T r a n s d u c e r S t a g e f o r L a t e r a l F l o w ( m m ) Fig. 26. Pressure transducer stage in lateral flow basin for the final cover test section at White Mesa from 12/25/22 to 03/23/23. 0.0 0.1 0.2 0.3 0.4 0.5 12/20/22 1/5/23 1/22/23 2/8/23 2/25/23 3/14/23 3/31/23 White Mesa, UT Cu m u l a t i v e F l o w i n L a t e r a l F l o w B a s i n ( m m ) Tipper (1 L)Pressure Transducer 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 12/25/22 to 03/23/23. I I I I I -- I I 21 0 1 2 3 4 5 12/20/22 1/5/23 1/22/23 2/8/23 2/25/23 3/14/23 3/31/23 White Mesa, UT Cu m u l a t i v e T i p s f o r D r a i n a g e Tipper (1 L)Tipper (70 mL) Fig. 28. Cumulative tips from the tipper in the drainage basin for the final cover test section at White Mesa from 12/25/22 to 03/23/23. 0 100 200 300 400 500 12/20/22 1/5/23 1/22/23 2/8/23 2/25/23 3/14/23 3/31/23 White Mesa, UT Pr e s s u r e T r a n s d u c e r S t a g e f o r D r a i n a g e ( m m ) Fig. 29. Pressure transducer stage in drainage basin for the final cover test section at White Mesa from 12/25/22 to 03/23/23. I I I I I ... - ... - - - ,I L -I I I I I 22 0.0 0.1 0.2 0.3 0.4 0.5 12/20/22 1/5/23 1/22/23 2/8/23 2/25/23 3/14/23 3/31/23 White Mesa, UT Cu m u l a t i v e F l o w i n D r a i n a g e B a s i n ( m m ) Tipper (70 mL)Pressure TransducerTipper (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 12/25/22 to 03/23/23. -15.0 -10.0 -5.0 0.0 12/20/22 1/5/23 1/22/23 2/8/23 2/25/23 3/14/23 3/31/23 White Mesa, UT Va u l t S t a g e ( m m ) Fig. 31. Vault stage for the final cover test section at White Mesa from 12/25/22 to 03/23/23. / ...., ___ .,,. ___ ,11 .. , ............ ,;t ..... _.,..,,,,, 1 ---...... 23 0 50 100 150 200 12/20/22 1/5/23 1/22/23 2/8/23 2/25/23 3/14/23 3/31/23 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 12/25/22 to 03/23/23. I• ''"' hi It 11