Public Comments Regarding the
EPA Region 8 Proposed Dewey-
Burdock In-Situ Uranium Recovery
Project Permitting Actions
Comments from Private Individuals
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Zi-Jwn-Zii? 05:12
From
Phone
FaxZero,com
P-2
Dear Ms Valois,
I am writing you to oppose the in-situ recovery (ISR) of uranium using deep
injection wells within the Inyan Kara group of aquifers (souther Black Hills region
of Custer and Fall River counties).
First and foremost, the Black Hiils are sacred to the Indigineous peoples in the
area. It would be morally repugnant to desecrate sacred land in such a way.
There is also a great concern for the safety of the water supply if this project
were to take place. A contamination by uranium would be permanent, rendering
the local aquifer useless. The social and environmental impact of contamination
would be profound.
The people, animals, and environment of the Black Hills deserve better. Please
deny the permit for ISR activities-ir, th = -ar*a.
Thank you.
Best,
concerned citizen
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PETITION
In Support of In-Situ Recovery (ISR) Extraction of Uranium
By Powertech (L'SA) Inc. in Southwest South Dakota
WE, THE UNDERSIGNED RANCHERS & OWNERS OF PROPERTY
IN THE VICINITY OF THE PROPOSED DEWEY-BURDOCK PROJECT
IN SOUTHWEST SOUTH DAKOTA ACKNOWLEDGE:
• Certain areas of Fall River and Custer Counties in Southwest South Dakota have been, endowed with
the natural resource uranium which is an alternative source of energy which can help the United Stales
and meet an increasing demand for electricity without emitting greenhouses gasses into the
atmosphere; and
• ISR is the most modem and environmentally friendly method of extracting uranium; and
• ISR extraction of uranium is highly regulated by the State of South Dakota, the U.S. Nuclear
Regulatory Commission and the U.S. Environmental Protection Agency; and
• ISR can be conducted in our area without harming our had, air, water or quality of life.
THEREFORE, we support and encourage the granting of the permits and licenses required by the State of South
Dakota, the U.S. Nuclear Regulatory Commission and the II.S. Environmental Protection Ageacy that allow ISR
extraction of uranium by Powertech (L'SA) Inc. at Its Dewey-Burdock site io Fall River and Custer Counties in
southwest South Dakota.
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PETITION
In Support of In-Situ Recover)' (ISR) Kitmction of Uranium
By Powertech (USA) Inc. in Southwest South Dakota
WE, THE UNDERSIGNED RANCHERS & OWNERS OF PROPERTY
IN THE VICINITY OF THE PROPOSED DEWEY-BIRDOCK PROJECT
m SOUTHWEST SOUTH DAKOTA ACKNOWLEDGE:
• Certain areas of Fall River and Custer Counties in Southwest South Dakota have been endowed with
the natural resource uranium which is an alternative source of energy which can help the United States
and meet an increasing demand for electricity without emitting greenhouses gasses into the
atmosphere; and
• ISR is the most modern and environmentally friendly method of extracting uranium; and
• ISR extraction of uranium is highly regulated by the Slate of South Dakota, the U.S. Nuclear
Regulatory Commission and the U.S. Environmental Protection Agency; and
• ISR can be conducted in our area without harming our land, air, water or quality of life.
THEREFORE, we support and encourage the granting of the permit* and I kernes required by the State of South
Dakota, the LIS, Nuclear Regulatory Conmiuioa and the I'.S. Knvirunmentat Protect ion Agent) that allow ISR
ettraetinn of uranium by Powertech (I'SA) Inc. at Its Dewcy-Burdock site in Fall River and C"u*ter Counties In
southwest South Dakota.
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PETITION
In Support of ii-SItu Recovery (ISR) Extraction of Uranium
By Powcrtech (USA) lie. in Southwest South Dakota
WE, THE UNDERSIGNED RANCHERS & OWNERS OF PROPERTY
IN THE VICINITY OF THE PROPOSED DEWEY-BIJRIKK.'K PROJEC T
IN SOUTHWEST SOUTH DAKOTA ACKNOW LEDGE:
• Certain areas of Fall River and Custer Counties in Southwest South Dakota have been endowed with
the natural resource uranium which is an alternative source of energy which can help the United States
ami meet an increasing demand for electricity without emitting greenhouses gasses into (he
atmosphere: and
» ISR is the most modern and environmentally friendly method of extracting uranium; and
• ISR extraction of uranium is highly regulated by the Stale of South Dakota the U.S. Nuclear
Regulatory Commission and the U.S. Ian ironmental Protection Agency; and
• ISR can be conducted in our area without harming our kind, air, water or quality of life,
THEREFORE, we support and encourage tbc granting of the permits and licenses required by the State of South
Dakota, tie U.S. Nuclear Rrgalatorv Commi^ion and the I'.S. Environmental Profeetfoa Agency that alow ISi
extraction of uranium by Powerteeh (ISA) Inc. at its Dfwn •Burdock site in Fall River and Custer Counties in
southwest South Dakota.
Willi
Print jNamc
Signature
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BIOGRAPHY
had parallel professional careers In the Department of Veterans'
Affairs and Naval intelligence, m enlisted In the United States Marine Corps at
age 17 and completed his eight-year obligation to the United States Marine Corps
through an active Marine Reserve program. This United States Marine Corps
program allowed him to complete both undergraduate and graduate school at the
University of Houston, while also fulfilling his eight-year military obligation.
During the Vietnam War, flHHHH was recruited for a direct commission In a
United States Naval Intelligence Program. The Navy was seeking Individuals with
skills in basic science, computer science, and "exotic" linguists. ¦¦ education
and civilian specialties were chemistry, biochemistry, and psychology. ¦ also
earned a second graduate degree from the Army-Baylor Program at Fort Sam
Houston, San Antonio, TX, 1971-1973. Following intensive POW Debriefing
training by the Navy, he volunteered for active duty to debrief returning
Navy/Marine Corp POWs from Vietnam In 1973.
Concurrent with his Veterans' Administration 34-year careers in medical research
and executive health care positions, ¦¦¦¦¦¦¦¦ 28 years as a Naval
Intelligence Officer in twelve Navai Intelligence active reserve units. HHHHI
served three tours of active-duty.
HHHHi earned 11 Naval Intelligence Certifications. These certificates are
known as Navy Officer Billet Codes (NOBC). Examples of these certifications are:
Air Intelligence Officer, Naval Attach^, Photo Interpreter, Anti-submarine Warfare
Officer, and Navai Investigative Service Officer. ¦ volunteered for active duty
during the first Gulf War (1990-1991) and commanded a US Naval Intelligence
team during Desert Shield and Desert Storm. The team's mission was to identify
weapons, technology, arms, and chemical substraits that had been acquired by
Iraq. Also, the Team was to interdict those items still in transit to Iraq before
hostilities began. The Navy team was swarded the Defense Meritorious Service
medal and a Joint Meritorious Unit Award for their distinctive accomplishments
before and during was also awarded the Defense
Superior Service Medal. was injured while on active duty and
formally retired from Naval Intelligence In November 1996.
Oat* of tntormatkwi:
ill, MET
I'S NAVY IRF.Tj
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Position
Statement
SOUTH DAKOTA
ISL Dewey-Burdock EPA Class 3
and Class 5 UIC injection wels
for mining and other hazardous
waste deposition - March 2017
f \
t Help Us Stop This! J
Summary: v y
(https://knowmining.org/iportfolio)
The Hong Kong/China based uranium mining
company, Powertech/Azarga that has been pursuing ISt (in situ leach recovery}
mining permits in the Dewey-Burdock, Edgemont area of the Black Hifls, is
currently requesting permits from the EPA for waivers from the Clean Water Act
for the Inyan Kara aquifer in order to implement UIC injection wells for mining, and for
hazardous waste permanent deposition from mining activity in the Minnelusa aquifer.
We are opposed to both the mining activity, which would contaminate the Inyan Kara aquifer
permanently for agricultural use, for which it is currently being used, and also contaminate
other aquifers in the area as well, because of the many fissures, fractures, breccia pipes and
sinkholes that are naturally occurring, and the 7,650 unclosed old exploratory boreholes that
allow the mixing of aquifers at the site.
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We are opposed to the permanent deposition of any mining wastes, including hazardous and
radioactive metals and/or metal salts thereof into any aquifers in the Black Hills which would
effectively render the Black Hills a permanent hazardous waste dump-site - and with the
ability of the permit holder to take in mining waste from other regional sites, and also sell that
permit to other polluters.
We are opposed to injection of chemical lixivients that would dissolve rock and free up toxic
metals to pollute the groundwater aquifers in the mining process, that cannot be effectively
cleaned up.
Background of Powertech/Azarga:
The Issue of the 12 Requested Hazardous Deep Injection Wells by Powertech/Azarga at
Edgemont, vs the 4 That Would be Permitted
COMPANY HISTORY
1») Powertech/Azarga is a Chinese based - foreign owned company that is essentially
bankrupt. The partners took over a bankrupt refrigerator manufacturing company shell and
then declared themselves a uranium mining company, though to date, this company has never
mined anything anywhere. As a foreign owned company, they are free to mine and then
bankrupt the company when mining reserves are gone, leaving the hazardous and radioactive
mess for the taxpayers to clean up. This is the most common scenario with foreign owned
mining companies in the U.S. Further, no aquifer has ever been restored anywhere in the
world after ISL uranium mining. For this reason, I8L mining is banned in Europe, where
numerous mines have completely ruined many aquifers.
2») Evidence was presented to the NRC and ASLB in hearings appealing the mining permit
issued by the NRC. It was disclosed in these hearings that the Tennessee Valley Assoc.
thoroughly explored the area in question for more mine-able uranium deposits after the roll
front of uranium was mined out in the 1950's by surface mining. TVA came to the area several
times, years apart, and drilled a total of 7650 boreholes looking for more mine-
able/extractable uranium, but failed to find any. TVA subsequently abandoned the site,
leaving those boreholes not properly closed for the most part, that then allowed further
mixing of the aquifers even more than the already naturally existing numerous fractures,
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fissures, breccia pipes and sinkholes that are common in this continuing uplift region. This was
when uranium yellow-cake was in high demand during the Cold War and the spot price was
$100.00 per lb. Today, the spot price for yellow-cake is currently $18,00 per lb, with the
production break even cost of $63.00 per lb. Powertech/Azarga was ordered by NRC/ASLB
to find and properly close all of those boreholes before they would be able to actively mine, as
ISL mining requires aquifers to be contained properly for extraction efficiency. This is a
hugely expensive process and to date, no work has been done on this, Powertech/Azarga does
not have the finances to do this, and ISL uranium mining is not profitable today, and not
projected to be in the future.
3*Jln addition, ISL technology was available back in the 19S0's and 60's when the
exploration was done, but the amount of "recoverable" uranium at Dewey Burdock was not
deemed sufficient by TVA for mining in any form, as they said that the roll front was gone. So
by these former experts, upon extensive exploration, there is no recoverable uranium at
that site left, Powertech/Azarga's own testing showed that the highest levels of uranium
found were in the alluvial wells that are surface, and not mine-able, as they cannot be
contained. With the extensive mixing of aquifers and the 7650 open boreholes that
contaminate the aquifers, there is likely organised uranium and other toxic metals by bacteria
that create a form of organic uranium that is not recoverable by ISL anyway. Organic uranium
does not bind to the resin beads in the "glorified water softeners" of ISL recovery. So the only
money to be made at this site is from taking in hazardous toxic mining wastes from other
mines to dump into our aquifers and make the Black Hills a toxic waste dump.
4*) Powertech/Azarga is asking for 4 Class 5 UIC deep injection wells for hazardous waste
deposition, into the Minnelusa aquifer, with a reserve request for 4 more of the same "in case
they find the they need them". They say they need 2 of these" right away". Powertech/Azarga
will operate 14 well fields total. The Minnelusa aquifer is a major drinking water aquifer in
the Black Hills. To say that it Is not, is not correct.
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A. For comparison. Crow Butte ISL uranium mine in Crawford, Nebraska, operated 11
well fields for 20 yrs using a single UIC hazardous waste deep injection well for
deposition of their toxic wastes, Dewey Burdock originally requested a total of 8 UIC
hazardous waste deep injection wells, but EPA is only permitting 4, still too many for a
non functional, no profit mine, two of which are requested to be drilled right away.
(Really? What do they need them all for? No work has been done to find and properly
close any of the old borehole sites that is required by NRC, followed by adequate pump
testing to make sure that the aquifer is contained prior to actively mining. EPA is not
requiring borehole closure for the injection wells. This spells certain "disaster" even
more.)
• By the numbers: Smith Ranch in /
\ OUR Backuard is Your Backyard!
WY :10 well fields, one deep injection
well Crow Butte, Ne; 11 well fields,
one deep injection well for 20 yrs.
Willow Creek, composed of two sites
Christensen Ranch and Irigary- 2
injection wells.
5-) Powertech/Azarga has also applied for Class 3 injection wells for 14 well fields. This will
be an additional 84 injection wells that will be receiving rock dissolving chemicals/1 ixivients
for production. Normally a well field contains one production well for extraction surrounded
by 6 injection wells. Further, the 14 production well fields are not on a uranium rich roll front,
as per TVA documents, (uranium ISL mines are typically situated on a uranium rich roll front
so that extraction is efficient and the mine is profitable. Remember, the roll front was found
by TVA to be mined out prior by surface mining)
6*y The 4 hazardous waste deep injection wells in the area are destined for the Minnelusa
aquifer, a drinking water aquifer in the Black Hills. Normally, UIC hazardous waste deep
injection wells are drilled "below" aquifers, not "in" them. The hazardous waste injected
into the aquifer will travel hundreds and even thousands of miles and contaminate other
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aquifers that are connected, and ultimately the huge Ogallala Aquifer that services the
entire central US. In addition,, these hazardous waste wells will legally be able to take in
the water of the hazardous wastes, containing radioactives, with toxic and heavy metals
from other mining sites, to make our aquifers a toxic waste dump, and ruin the water we
have there. These permits are also able to be sold to another company once issued, if the
original company Azarga/Powertech files bankruptcy or sells the permits. These permits,
once issued, can be renewed indefinitely. Since the wastewater will contain radioactives
and toxic heavy metals, the ultimate destination as to which class of deposition well is
required, is determined by the proximity of the drinking water aquifer near it, above or
below. Powertech /Azarga has played a semantics game with the determination of the
class of disposal well required, however the toxicity of the ultimate wastewater is still the
same. See "From the Permit" below.
7-) The claim that Powertech/Azarga is going to treat the wastewater first to "purify" it to
classify for the Class 5 deep injection regulations, does not include the inability to extract
radioactive organified metals that are now found in wastewater by ISL in several studies,
notably uranium. By regulation, Class 5 wastewaters can only be as toxic as storm sewer
waters. This wastewater is hardly that Radioactive organified metals and metallic salts in this
wastewater make this waste water unusable for even agricultural purposes, as it would be in
this dry uplift area where water is "blue gold", if it were as "pure" as the company says it is.
Better technology today shows us the flaws of obsolete testing and regulations today, and
why we see such horrid toxicities in Nature at mining sites. The company has not shown any
technology that could be effective in processing this wastewater to be safe for a Class 5 well.
And the extra great expense of this processing will cost the profitability of the project dearly.
They already cannot pay their mining land teases and are essentially bankrupt going in to this
project See the toxicology testimony by Linsey McLean, expert witness for Consolidated
Interveners, to the Nuclear Regulatory Commission and Atomic Safety and Licensing Board
on the birth deformities found in wildlife and domestic farm animals studied in ISL mining
sites contaminated by toxic waste water and radioactive metals.
https://www.nrc.gov/docs/ML1513/ML15132AS07.pdf
(https://www.nrc.gov/docs/ML1513/ML15132AS07.pdf)
https://www.nrc.gov/docs/ML1513/ML15132A5Q6.pdf
(https://www.nrc.gov/docs/ML1513/ML15132A506.pdfi
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C —— — — — — — —N
The business model for this Chinese based company in Dewey-Burdock is
very likely to never start uranium mining to begin with, as by their own
admission, the price of uranium is far too low for profitability. They
intend to use these injection wells for importing hazardous toxic mining
wastes from other sites for profit, making the Black Mils an. everlasting
toxic waste dump, They state that they need two deep injection wells for
hazardous wastes right away.
V , J
What is an Injection well/UIC?
An injection well is a device that places fluid deep underground into porous rock formations,
such as sandstone or limestone, or into or below the shallow soil layer. The fluid may be water,
wastewater, brine (salt water), or water mixed with chemicals.
In waste water disposal, treated waste water is injected into the ground between
impermeable layers of rocks to avoid polluting fresh water supplies or adversely affecting
quality of receiving waters.
**ln the case of this EPA permit, the injection will go directly into the Minnelusa aquifer and
not in rock formations where injections typically are directed.
Injection wells are usually constructed of solid walled pipe to a deep elevation in order to
prevent toxic injections from mixing with the surrounding environment.
http://en.wikipedia.org/wiki/lniection well (http://en.wikiDedia.ore/wiki/lniection well)
Until the 1960s, drillers could just dump this stuff wherever they wanted. Being extremely
salty and full of chemicals, this is obviously a bad idea. The 1960s saw the introduction of
deep injection wells. The idea was that if you could inject fluids into rocks thousands of feet
underground, the toxic waste would stay there forever. In order for this to work, the rock
layers have to be porous, like a sponge, and the waste has to be injected under pressure to
force its way into the rocks.
Regulatory Requirements of Deep Injection
Wells
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In the United States, injection well activity Is regulated by the United States Environmental
Protection Agency (EPA) and state governments under the Safe Drinking Water Act
(http://en.wikipedia.org/wiki/Safe Drinking Water Actl fSDWAl EPA has issued Underground
Injection Control (UIC) regulations in order to protect drinking water sources. The EPA has
defined six classes of injection wells.
Class I wells are used for the injection of municipal and industrial wastes beneath
underground sources of drinking water.
Class II weils are used for the injection of fluids associated with oil and gas production,
including waste from hydraulic fracturing.
Class III wells are used for the injection of fluids used in mineral solution mining
(en.wikipedia.org/wiki/Solution mining) beneath underground sources of drinking water.
(ISL Uranium mining falls in here)
Class IV wells, like Class I wells, are used for the injection of hazardous wastes but
inject waste into or above underground sources of drinking water instead of below.
Class V wells are those used for all non-hazardous injections that are not covered by
Classes I through IV, Examples include storm-water drainage wells and seotic system
leachfieldsten.wikipedia.org/wiki/Septic drain field!.
Class VI wells are used for the injection of carbon dioxide for sequestration, or long
term storage. Currently, there are no Class VI wells in operation, but 6 to 10 wells are
expected to be in use by 2016.
lhttp:.//BeoDle.uwec,edu/piercetfa/HazwasteWebsSp04/DeepWelllmectton/DeeoWelHniectiori.htm)
Injection Wells Don't Just Pollute
lj They are well known to cause earthquakes, as hazardous wastes are continuously
being pumped into the aquifers at high pressure, and the wastes are meant to stay in the
ground forever. The pressure that the wastes exert in the aquifer forces the wastes to move
vertically and horizontally in all directions, mixing with the local waters there and traveling
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with the flow underground. The pressure also causes more fractures and fissures in the rock
layers, causing earthquakes, and further mixing of the wastes into the aquifers. Fracking is a
similar principle. Oklahoma has been the site of numerous fracking areas and have increased
a record number of earthquakes and contaminated drinking water wells, and the earthquakes
continue even after two years of a fracking ban.
INJECTION-INDUCED EARTHQUAKES
A July 2013 study by US Geological Survey /"""
( OUR Backuard is Your Backyard! )
scientist William Ellsworth links earthquakes to V,
wastewater injection sites. In the four years from (https://knowmir1ir1g.0rg/#DortfoliQ)
2010-2013 the number of earthquakes of
magnitude 3.0 or greater in the central and
eastern United States increased dramatically.
After decades of a steady earthquake rate
(average of 21 events/year), activity increased starting in 2001 and peaked at 188
earthquakes in 2011. USGS scientists have found that at some locations the increase in
seismicity coincides with the injection of wastewater in deep disposal wells. Injection-induced
earthquakes are thought to be caused by pressure changes due to excess fluid injected deep
below the surface and are being dubbed "man-made" earthquakes.
http://peoole.uwtc.edu/Diercech/H3ZwasteWebsSD04/
DeeDWelllniectlon/DeepWelHriieetion.htm
(http://Deoole.uwec.edu/Dlercech/HazwasteWebsSp04/DeeDWelllniection/DeepWelllniection.htm)
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References;
Hieh-rate injection is associated with the increase In U.S. mid-continent seismicitv
(https://pubs.er.uses.eov/publication/70161978)
Barbara A. Bekins, arid Justin L Rubinstein Abstract An unprecedented increase in
earthquakes in the U.S. mid-continent beganin 2009. Many of these earthquakes
have been documented as induced by wastewater injection. We examine the
relationship between wastewater injection... and U.S. mid-continent seismicity using a
newly assembled injection well database for the central and eastern United States. We
find that the entire... increase in earthquake rate is associated with fluid injection wells.
High-rate Injection wells {>300,000 barrels per month) are much more likely to be...
Induced Earthquakes (https://earthauake.usgs.gov/research/induced/mvths.php)
The primary cause of the recent increase in earthquakes in the central United States.
Wastewater disposal wells typically operate for longer durations and... injection wells
Induce earthquakes. Most injection wells are not associated with felt earthquakes, A
combination of many factors is necessary for injection to... induce felt earthquakes.
These include: the injection rate and total volume injected; the presence of faults that
are large enough to produce felt... earthquakes; stresses that are large enough to
produce earthquakes; and the presence of pathways for the fluid pressure to travel
from the injection...
Iniection-induced earthquakes (https://pubs.er.usgs.gov/publication/70048668)
Abstract Earthquakes in unusual locations have become an important topic of
discussion in both North America and Europe, owing to the concern that... and
underground mining, withdrawal of fluids and gas from the subsurface, and injection of
fluids into underground formations. Injection-induced... production of oil and gas from
previously unproductive formations. Earthquakes can be induced as part of the process
to stimulate the production from tight... associated with industrial activity, with a focus
on the disposal of wastewater by injection in deep wells; assess the scientific
understanding of induced...
A Century of Induced Earthquakes in Oklahoma? (https://www.usgs.eov/news/centurv-induced-
earthauakes-oklahoma)
related to oil production, particularly disposal of wastewater in deep injection wells, are
known to potentially cause earthquakes. Prior to the... Release Date: October 26,
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2015The rate of earthquakes has increased sharply since 2009 in the central and
eastern United States, with growing... evidence confirming that these earthquakes are
primarily caused by human activity, namely the injection of wastewater in deep disposal
wells. The rate of... earthquakes has Increased sharply since 2009 in the central and
eastern United States, with growing evidence confirming that these earthquakes are...
Sharp increase in centra! Oklahoma seismicitv 2009-2014 induced bv massive wastewater Infection
(https://Dubs.er.usgs.gov/publication/70137863)
data required to unequivocally link earthquakes to injection are rarely accessible. Here
we use seismicity and hydro-geological models to show that... earthquakes to distances
of 35 km, with a triggering threshold of -0.07 MPa. Although thousands of disposal
wells may operate aseismically, four of... Sharp increase in central Oklahoma seismicity
2009-2014 induced by massive wastewater injection Science By: Kathleen, M. Keranen,
Geoffrey A. Abers...»Matthew Weingarten, Barbara A. Bekins, and Shemin Ge
2m) Other common problems with deep injection wells are non approved hazardous
wastes being dumped in there, as there is essentially no daily oversight. Wells are not
maintained well and over pressure causes pipes to crack, dispersing the toxins in higher levels
than they are supposed to be. Spills are common on the surface and accidents when truck
hauling the toxins slip off road in icy roads, hit deer etc. and cause an instant dirty bomb at the
site, that is not able to be cleaned up as it soaks into the ground. In this case, toxic and heavy
metals and radiation.
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2008-2010
Cases of Water Contamination Violations
CLASS-2 WELLS: 22
OTHER WELLS: 77
Cases of Unauthorized Injection = 859
Cases of Pressurized Injection = 1,199
Test Failures for Significant Leaks = 6,723
Total Wells with Violations » 60,467
htto://arQiects.propyblica,org/eraDhics/ynderg.round-iniection-wells (http://proiects.proaybHca.org/graphics/ynderground-iniectioiT
wells!
STRUCTURAL FAILURES
A ProPublica review of well records, case histories, and government summaries of more
than 220,000 well inspections from October 2007 to October 2010 found that
structural failures inside injection wells are routine. From late 2007 to late 2010, one
well integrity violation was issued for every six deep injection wells examined - more
than 17,000 violations nationally. More than 7,000 wells showed signs that their walls
were leaking. Records also showed wells are frequently operated in violation of safety
regulations and under conditions that greatly increase the risk of fluid leakage and the
threat of water contamination, ProPublica's analysis showed that, when an injection
well fails, it is most often because of holes or cracks in the well structure itself.
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UNAUTHORIZED INJECTION
Basically illegal clumping, EPA officials describe this as the most serious of all violations.
It means waste was dumped into a well without a permit or without being legally
approved for a certain location. State regulators say most violations are for bad
paperwork, but in some cases, oil and gas companies have dumped dangerous waste
meant for Class 1 wells into Class 2 wells to avoid fees and tighter regulations.
MECHANICAL INTEGRITY VIOLATION
Mechanical Integrity testing, or MIT, is the primary way of checking the condition of
injection wells. All Class 1 and Class 2 deep injection wells are required to be tested
regularly, often by pressurizing the well and waiting to see if any of the pressure
escapes, indicating a crack in one of the well's layers. Regulators say most violations
indicate a small problem that, caught early, prevents a larger failure in the future. But
some failures noted in federal records do describe "significant"leaks and migration of
waste.
OVER PRESSURIZED INJECTION
When waste is injected at higher pressure than is allowed on an injection well permit, it
can either break out of the well or fracture the rock underground, creating new
pathways for that waste to migrate into, and pollute, water supplies. A violation means
that the pressure caused waste to move outside of its intended zone and endanger
drinking water.
TEST FAILURES FOR SIGNIFICANT LEAKS
This means that a well failed a mechanical integrity test and "caused the movement of
fluids outside of the authorized zone," because either its cement or steel structure, or
the tubing that lines the inside of the well, had a crack.
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WATER CONTAMINATION
In the reports each state submits to the EPA annually, they list the number of cases
where an underground source of drinking water was believed to have been polluted as a
result of leaking injection wells.
http://www.sourcewatch.org/index.Dhp/lniection well
(http://www.sourcewatch.ore/index.php/l niection we 11)
Here are some of the multiple regulations for the construction and maintenance of
monitoring and testing wells:
• follow waste analysis plan
• perform Mils at required intervals
• reporting and record Keeping
• record injection fluids and all monitoring results
• report on any changes at facility and noncompliances
Closing
• flush well with non-reactive fluid
• submit plugging and abandonment report
• monitor ground water until injection zone pressure can no longer influence any USDW
• inform authorities of well location and zone of influence
Siting
• AoR testing
• no-migration petition demonstration
• geological studies
Construction
• well is cased and cemented
• proper tubing and packer
• UIC program director must approve plan
Operation
• monitor injection pressure, flow rate, and volume
» alarms and devices to shut down flow if necessary
• maintain pressures that will not initiate cracking
http://www.eoa.Kov/safewater/uic/classonestudv.Ddf (http://www.epa.gov/safewater/uic/elatsonestudv.pdfl
htip;//»MW.mindful[v.ore/Water/2P03/PeeD-lniection-Welts-GAOI3iyl03.htm(httD://www.mir>dfullv.org/Wat8r/2C»3/Deep-lnleetiQn-WeHs-
GAQ13SulQ3.html
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Problems with Recovery of Mined Minerals
When Organic Compounds Contaminate an
Aquifer
Summary: You cannot recover all of the uranium from the mining water, Organified
uranium compound levels will build up In the wastewater.
Arabian journal of Chemistry
Volume 4, Issue 4, October 2011 (www.sciencedirect.com/science/ioymal/18785352/4/41 Pages 361
-377
PROBLEMS WITH ION EXCHANGE IN WATER PURIFICATION
Ion exchange is another method used successfully in the industry for the removal of heavy
metals from effluent An ion exchanger is a solid capable of exchanging either cations or
anions from the surrounding materials. Commonly used matrices for ion exchange are
synthetic organic ion exchange resins. The disadvantage of this method is that it cannot
handle concentrated metal solution as the matrix gets easily fouled by organics and other
solids in the wastewater. Moreover ion exchange is non-selective and is highly sensitive to
the pH of the solution. (Kurniawan et at., 2006).
ORGANIFIED URANIUM IS A REAL THING IN ISL MINES
httDi//www.newswi'se.com/articles/s.lac-study-helps-exDlain-
wtw-uranium-oerslsts-ia-CTQundwatef-at-forroer-mining-sites (http://wwwjiewswlse.com/articles/slat-studv-helps-explam~whv-
urawum-Dersists-ln-eroyfid.water-at-former-mfnlng-sitesi
• SLAC Study Helps Explain Why Uranium Persists in Groundwater at Former Mining
Sites
• New Details About Uranium Chemistry Show How It Binds to Organic Matter
Article ID: 668799
Released; 2-Feb-2017 2:05 PM EST
Source Newsroom: SLAC National Accelerator laboratory
Newswise - Decades after a uranium mine is shuttered, the radioactive element can still
persist in groundwater at the site, despite cleanup efforts.
-------
A recent study led by scientists at the Department of Energy's SLAC National Accelerator
Laboratory helps describe how the contaminant cycles through the environment at former
uranium mining sites and why it can be difficult to remove. Contrary to assumptions that have
been used for modeling uranium behavior, researchers found the contaminant binds to
organic matter in sediments. The findings provide more accurate information for monitoring
and remediation at the sites.
The results were published in the Proceedings of the National Academy of Sciences,
In 2014, researchers at SLAC's Stanford Synchrotron Radiation Lightsource (SSRL) began
collaborating with the DOE Office of Legacy Management, which handles contaminated sites
associated with the legacy of DOE's nuclear energy and weapons production activities.
Through projects associated with the Uranium Mill Tailings Radiation Control Act, the DOE
remediated 22 sites in Colorado, Wyoming and New Mexico where uranium had been
extracted and processed during the 1940s to 1970s,
Uranium was removed from the sites as part of the cleanup process, and the former mines and
waste piles were capped more than two decades ago. Remaining uranium deep in the
subsurface under the capped waste piles was expected to leave these sites due to natural
groundwater flow. However, uranium has persisted at elevated levels in nearby groundwater
much longer than predicted by scientific modeling.
In an earlier study, the SLAC team discovered that uranium accumulates in the low-oxygen
sediments near one of the waste sites in the upper Colorado River basin. These deposits
contain high levels of organic matter—such as plant debris and bacterial communities.
During this latest study, the researchers found the dominant form of uranium in the
sediments, known as tetravalent uranium, binds to organic matter and clays in the sediments.
This makes it more likely to persist at the sites. The result conflicted with current models used
to predict movement and longevity of uranium in sediments, which assumed that it formed an
insoluble mineral called uraninite.
Different chemical forms of the element vary widely in how mobile they are—how readily
they move around-in water, says Sharon Bone, lead author on the paper and a postdoctoral
researcher at SSRL, a DOE Office of Science User Facility.
-------
Since the uranium is bound to organic matter in sediments, it is immobile under certain
conditions, Tetravalent uranium may become mobile when the water table drops and oxygen
from the air enters spaces in the sediment that were formerly filled with water, particularly if
the uranium is bound to organic matter in sediments rather than being stored in insoluble
minerals.
"Either you want the uranium to be soluble and completely flushed out by the groundwater,
or you just want the uranium to remain in the sediments and stay out of the groundwater,"
Bone says, "But under fluctuating seasonal conditions, neither happens completely."
This cycling in the aquifer may result in the persistent plumes of uranium contamination
found in groundwater, something that wasn't captured by earlier modeling efforts.
"For the most part, uranium contamination has only been looked at in very simple model
systems in laboratories," Bone says, "One big advancement is that we are now looking at
uranium in its native environmental form in sediments. These dynamics are complicated, and
this research will allow us to make field-relevant modeling predictions,"
The study combined the expertise of researchers at SLAC, Pacific Northwest National
Laboratory and the Canadian Light Source, The research team used a blend of techniques to
analyze samples of sediments in the experiment They performed X-ray spectroscopy at SSRL
to identify the chemical form of uranium. Capabilities at the Canadian Light Source and at the
Environmental Molecular Science Laboratory (EMSL) at Pacific Northwest National
Laboratory were used to map the locations of the elements in the samples at the nanometer
scale. This additional information allowed the researchers to determine whether or not the
uranium was bound to carbon-containing, or organic, materials. SSRL and EMSL are DOE
Office of Science User Facilities.
The DOE Office of Science funded the project.
SLAC is a multi-program laboratory exploring frontier questions in photon science,
astrophysics, particle physics and accelerator research. Located in Menlo Park, Calif., SLAC is
operated by Stanford University for the U.S. Department of Energy's Office of Science. For
more information, please visit slac.stanford.edu (slac.stanford.edu).
-------
SLAC National Accelerator Laboratory is supported by the Office of Science of the U.S.
Department of Energy, The Office of Science is the single largest supporter of basic research
in the physical sciences in the United States, and is working to address some of the most
pressing challenges of our time. For more information, please visit science.energv.gov
(science.energv.gov).
The Bottom Line on Leaky Injection Wells,
ISR/L Recovery and the Stabilization of
Plumes:
If an ISR/L recovery well is contaminated with organic carbon compounds, whether
naturally occurring or from leaky underground waste disposals, then the efficiency of
recovery of uranium or any other metal by the common ion exchange method will be
compromised, and will be rendered unrecoverable.
Moreover, if the organic carbon compounds are stereoisomers, whether naturally
occurring or synthetic Industry wastes, they will only react with other stereoisomers, so
no inorganic method of stabilizing a plume will be effective, as demonstrated at Smith-
Highland Ranch in WY,
Contaminated old ISR/L field waters may still test high for the elemental presence of
uranium, and be marketed and sold (stocks and investments) as having a high
propensity for extraction, but that would not be the case. It would not be recoverable.
There is no technology known today that will clean up an aquifer like that.
restoration of state oversight, repeal of SB 158, and new
laws in place to prevent heavy hazardous waste tankers from destroying our roads and
jeopardizing our clean Black Hills environment with accidents and spills on icy roads,
hitting deer etc., and causing a permanent dirty bomb forever at these sites. We need
laws now that will prohibit the transportation of these radioactive toxic wastes on our
roads, through our state, and bringing in other mines' toxic wastes from other states.
With the impending demise of the EPA, we need
(https://knowmining.Org/#Dortfolio!
-------
Respectfully submitted to the EPA by |
MESSAGE TO THE PUBLIC;
PREPARE FOR THE EPA HEARINGS
1.) Get there early to sign in for your time to present your concerns,
2.) You are most effective if you take the time to write out your understanding of the permit
and your objections to it and handing it to the judges. You can save time by reading it aloud to
the judges and then submitting the written paper to them for their records. You will have only
a short time to speak, so make you comments relevant and pointed. Be sure to sign your
name. If you print your comments out on your computer,, be sure to sign your name and
address at the bottom to make it legal.
3.) Use the science to make your point Show that you understand the science by
explaining why you are against any hazardous waste in our aquifers, whether the Inyan
Kara or the Minnelusa, and also why you are against making the Inyan Kara any more
compromised than It already is. Both of these aquifers are being used, if not for personal
use, then for ag use. Many people with wells in the area, do not even know what aquifer
they are in. If you know your well aquifer and it is the Inyan Kara or Minnelusa, you need
to make that point. These judges are scientists and need to hear that you understand and are
opposed to this permit. Do Not just get up there and whine about how this doesn't feel good
to you. That just gets blown off. Use the studies and scientific points outlined in this document
to help you. More if you know more. You only need a couple points to hammer down on.
4.) Encourage your friends and neighbors to get involved and come with you to protect our
water.
The Permit in Question:
EPA seeks public comment on draft permits and aquifer exemption for uranium mining
project in southwestern South Dakota.
Public hearings will be held in Valentine, NE and in Rapid City, Hot Springs and
Edgemont, SD.
-------
CONTACT:
Lisa McClain-Vanderpool
(303} 312-6077
mcclain-vanderpool.lisa@epa.gov
{Denver, Colo, - March 6,2017} EPA has issued two draft Underground Injection Control
(UIC) Area Permits to Powertech (USA) Inc., for injection activities related to a proposed
uranium recovery project in the southern Black Hills region in Custer and Fall River Counties
of South Dakota. EPA will conduct information sessions combined with public hearings on
April 27th and on May 8 through May 11 at the times and locations detailed below, EPA will
accept public comments on the draft permits and a proposed aquifer exemption associated
with the project through May 19,2017,
The draft permits issued today include a UIC 'Class III' Area Permit for injection wells for the
in-situ recovery (ISR) of uranium in the Inyan Kara Group aquifers and a UIC 'Class V' Area
Permit for deep injection wells that would be used to dispose of ISR process waste fluids into
the Minnelusa Formation below the Inyan Kara after treatment. Under the terms of the draft
permits, waste injected under the Class V permit must be treated prior to being injected and
must meet all radioactive waste and hazardous waste standards. Monitoring of the
underground sources of drinking water surrounding the Class III injection well-fields will take
place before, during and after ISR operations to ensure the underground sources of drinking
water are protected.
EPA is also proposing an aquifer exemption approval in connection with the draft UIC Class III
Area Permit. Specifically, this approval would exempt the uranium-bearing portions of the
Inyan Kara Group aquifers from protection under the Safe Drinking Water Act. Such an
exemption must be in place before ISR activities within these aquifers can occur.
Under its obligation to comply with the National Historic Preservation Act and under EPA's
Tribal Policy on Consultation and Coordination with Indian Tribes, EPA has been consulting
and coordinating with several interested Tribes to identify the potential effects of the
proposed project on traditional cultural places, historic and sacred sites. EPA will continue to
consult and coordinate with Tribes as necessary throughout the public comment period
concerning these proposed permitting actions.
-------
The public is encouraged to provide comment on these draft permits and the aquifer
exemption by midnight mountain time, May 19,2017, EPA's final permit decision will be
based on an evaluation of comments received and a determination of whether underground
sources of drinking water are protected. The draft permits can be found at the EPA Region 8
UIC Program website:
https://www.epa.gov/uic/uic-epa-region-8 (https://www.epa.gov/uic/uic-eoa-region-8)
https://www.eoa.gov/uic/administrattve-record-
dewev-burdock-class-iii-and-class-v-iniection-
well-draft-area-permits fhttps://www.epa.gov/sites/production/files/2017-
03/documents/class v draft area permit fact sheet.pdf)
How to Comment:
Written comments must be received by email, fax or mailed to:
Valois Shea
shea.valois@epa.gov fshea.valois@epa.gov)
fax: 303-312-6741
U.S. EPA Region 8 Mail Code: 8WP-SUI
1595 Wynkoop Street
Denver, CO 80202-1129
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Public Information Sessions and Hearing
Information (The public may also provide
written and/or verbal comments during the
following EPA public hearings):
Thursday, April 27,2017 from 4:00 to 8:30 p.m. {with a break from 5:00 to 6:00 p.m.)
Niobrara Lodge, 803 US Highway 20, Valentine, Nebraska 69201
Monday-Tuesday, May 8-9,2017,1:00 to 8:00 p.m. (with a break from 5:00 to 6:00
p.m.)
The Best Western Ramkota Hotel, 2111N. taCrosse Street, Rapid City, South Dakota
57701
Wednesday, May 10,2017, from 1:00 to 8:00 pm (with a break from 5:00 to 6:00 p.m.)
The Mueller Center, 801S 6th Street, Hot Springs, South Dakota 57747
Thursday, May 11,2017, from 1:00 to 8:00 pm (with a break from 5:00 to 6:00 pm)
St James Catholic Church, 310 3rd Avenue, Edgemont, South Dakota 57735from
From the Permit:
Powertech USA submitted an application for aUIC Program Class V Area Permit proposing to
construct and operate up to eight (8) deep injection wells within the Dewey-Burdock Project
Boundary to be used for the disposal of treated uranium ISR process wastewater into the
Minnelusa and Deadwood Formations. At the time the Class V Area Permit Application was
submitted, Powertech anticipated that the two (2) Minnelusa and the two (2) Deadwood
injection wells proposed in the Class V Permit Application would provide adequate disposal
capacity for the Permit SD52173-00000 6 Dewey-Burdock Class V Draft Area Permit Fact
Sheet volume of uranium ISR process wastewater that is expected to be generated at the site.
As further explained below in Section 2.3, Powertech did not intend to request additional
injection wells to be added under the Class V Area Permit unless the first four (4) wells did not
provide adequate disposal capacity. However, Powertech withdrew the permitting request
for the two Deadwood injections wells in a letter dated December 9,2016.
-------
This Class V Area Permit authorizes up to four (4) wells for injection into the Minnelusa
Formation only. Powertech originally proposed the construction of the two (2) Minnelusa
Formation injection wells listed in Table 1, but may elect to construct up to two (2) additional
injection wells allowed under this Class V Area Permit If Powertech decides that more than
four (4) injection wells are needed to provide enough capacity to disposed of the treated ISR
waste fluids, a modification under this permit will be required per 40 CFR § 144,39 and 40
CFR § 124.5, This process will involve issuing a draft permit modification subject to public
comment on the modifications only.
Table 1. Injection Wells Proposed under the Class V Area Permit
- = approximately
-------
1, The approximate depths shown in this table are extrapolated from the type logs
described in the Class V Permit Application. Actual injection zone depths will be
determined from drill hole logs during well construction.
The Class V Permit Application, Including the required information and data necessary
to issue a UIC permit in accordance with 40 CFR parts 124,144,146 and 147, was
reviewed by the EPA and determined to be complete.
This Class V Area Permit is issued for a time period of ten (10) years after the Permit
Effective Date and will expire after that time. The Class V Area Permit also may be
terminated upon delegation of primary enforcement responsibility for the Class V UIC
Program to the State of South Dakota unless the State agency chooses to adopt and
enforce this Permit, If Powertech wishes to continue any activity regulated by this
Permit after the expiration date of this Class V Area Permit, Powertech must submit a
complete application for a new Permit at least 180 days before the Class V Area Permit
expires.
2.1 Injection Well Classification
The injection wells authorized under this permit are classified as Class V industrial
wastewater injection wells. The proposed injection zone for injection wells DW No. 1
and DW No. 3 is the Minnelusa Formation, which overlies the Madison Formation, a
USDW. Typically, Class I radioactive waste injection wells are used for process
wastewater disposal at uranium ISR sites because process wastewater at these types of
facilities usually meets the definition of "radioactive waste" under 40 CFR § 144.3. Class
I radioactive waste disposal wells are required to inject fluids below the lowermost
formation containing an underground source of drinking water within one quarter mile
of the well bore per 40 CFR § 144.6(a)(3). Radioactive waste disposal above USDWs are
classified as Class IV wells and are banned per 40 CFR § 144.13. Because the proposed
Minnelusa injection zone for DW No. 1 and DW No. 3 is located above a USDW, these
wells do not fit the regulatory definition of a Class I injection well. Therefore, in order to
be able to inject in the Minnelusa, above USDWs, the permit requires Powertech to
treat the injectate so that it does not fall under the definition of "radioactive waste."
According to 40 CFR § 144.5(e)
-------
Permit SD52173-
Fact Sheet:
7 Dewey-Burdock Class ¥ Draft Area Permit
Well Permit Number: SD52173-08764
Well Name: DW No. 1
Proposed Injection Zone: Minnelusa Formation
Anticipated Injection Zone Depth: -1,615' - -2,205'
Location within Project Area: Burdock
Well Permit Number: SD52173-08765
Well Name: DW No, 3
Proposed Injection Zone: Minnelusa Formation
Anticipated Injection Zone Depth: -1,950* - -2,540'
Location within Project Area; Dewey
Class V injection wells are those riot included in Class I, II, III, IV or VI, Therefore, DW No. 1
and DW No. 3 must be classified as Class V injection wells.
Because these two wells will be used as deep disposal wells, the Class V Area Permit contains
the protective construction and monitoring requirements designed for Class I injection wells.
However, because these wells are Class V wells, the Class V Area Permit contains permit
limits requiring injectate constituent concentrations to be at or below radioactive waste
standards set in 10 CFR Part 20, Appendix B, Table 11, Column 2 and hazardous waste
standards set in 40 CFR § 261,24 Table 1,
The proposed injection zone for injection wells DW No, 2 f ~*\
{ Contribute J
and DW No. 4 is the Deadwood Formation, which is J
expected to lie beneath all USDWs in the area. These two (httDs://knowmining.org/#Dortfoiiol
wells fit the regulatory definition of Class I wells found at 40
CFR § 144.6(a). Even if Powertech treats the injectate for these two wells so that injectate
constituent concentrations would be at or below radioactive waste standards set in 10 CFR
Part 20, Appendix B, Table II, Column 2 and hazardous waste standards set in 40 CFR §
261,24 Table 1, these wells would still meet the definition of Class I other industrial well
found at 40 CFR § 144.6(a)(2). South Dakota regulation 74:55:02:02 prohibits Class I
injection wells in the State. When the EPA informed Powertech that the DW No, 2 and DW
-------
No. 4 wells proposed for injection into Deadwood Formation are classified as Class I wells
under U1C regulation 40 CFR § 144.6(a)(2), Powertech submitted a letter to the EPA
withdrawing the request for authorization for construction and operation of wells injecting
into the Deadwood Formation. Because there is no longer an active application for injection
into the Deadwood Formation, there is no agency action related to injection into this
formation.
https://www.epa.gov/sites/production/files/2017-03/
documents/class v draft area permit fact sheet.pdf (https://www.epa.gov/sites/production/files/2017-
03/documents/ctass v draft area permit fact sheet.odf)
CONTACT US
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jk^rruJdfcaS
mcuj H
Good day to each of you,
4,fV
My name is and I a former Mayor of Edgemont, South Dakota, the host community for the
Dewey-Burdock Project,
With few exceptions, this community is strongly in support of Powertech's proposed in-situ uranium
project.
The Dewey-Burdock site is about 23 miles northwest of our community and we expect that our schools,
our infrastructure and our businesses will see the benefits of this project,
Powertech has been a good corporate citizen of Edgemont since they opened their office here 10 years
ago.
They have been very open with us and explained the project in detail. We look forward to the economic
activity this will bring to our small community.
Over the years, we've had an awful lot of kids from our area earn engineering and science degrees and
then have to go elsewhere to find meaningful work. Others have gone to Wyoming or North Dakota to
work in technical and service oriented jobs.
Personally, I look forward to having good jobs nearby so that uur young people can stay here or return
here to work and raise a family.
As an elected official, I took my office and responsibilities very seriously. And I think our City Council
did that when thev passed a Resolution of Support for the Dewey-Burdock Project. I have a copy of it
right here.
Jim Turner was our mayor when this was signed, but Jim has since passed away. So, I will do the honors
of presenting you with this copy of the Resolution of Support for the Dewey-Burdock Project, and ask
that it be included in the record of this hearing.
In conclusion, I want to emphasize my personal, strong support for the Dewey-Burdock project and I
hope you will finalize the subject permits quickly and without unduly burdening the company.
More than 10 years is more than enough time to get a project like this started.
Thank you.
-------
Submittal b*,
m^ii
RESOLUTION 2013-03-05
Supporting Responsible Uranium Recovery in Fall River and Custer Counties, South Dakota
WHEREAS Powertech (USA) Inc. desires to extract uranium on the Dewey-Burdock Project site in Fall
River and Custer Counties utilizing the in situ recovery method; and
WHEREAS the Dewey-Burdock Project has been analyzed by knowledgeable independent parties and
demonstrates excellent economic characteristics as well as safe and environmentally sound capacity to be
mined such that it meets the requirements of South Dakota and Federal oversight agencies; and
WHERERAS the economic base of the State of South Dakota and Fall River and Custer Counties will be
significantly enhanced as Powertech (USA) Inc. directly or indirectly employs over 80 workers, provides
an influx of more than $50 million in non-payroll capital expenditures, and pays mineral severance taxes
estimated to be more than $10 million to the State of South Dakota and more than $5 million each to Fall
River County and Custer County; and
WHEREAS uranium mining in Fall River and Custer Counties will be strictly regulated and overseen by
the State of South Dakota, the U.S. Nuclear Regulatory Commission and the U.S. Environmental Protection
Agency so as to protect the public health, worker health and the surrounding environment; and
WHEREAS it is the belief of this entity that energy production and economic development will be
balanced with environmental stewardship in Fall River and Custer Counties.
NOW THEREFORE BE IT RESOLVED that upon demonstrating to state and federal regulators
that operations at the Dewey-Burdock Project can be done in a manner that is protective of the
public health and the environment, the City of Edgemont Common Council supports and encourages
the granting of state and federal licenses and permits to Powertech (USA) Inc. to commence in situ
uranium recovery activities at the Dewey-Burdock Project site in Fall River and Custer Counties,
South Dakota.
Dated this 5* Day of March 2013.
Edgemont Common Council
Edgemont, South Dakota
-------
Mrftan stemmed «?|8111
1
A BONFIRE OF LIES
Thank you. I am
and I live near Nemo, SD. My theme today
will be lies, cowardice, laziness, hypocrisy, cynicism, Native rights, and
Azarga's and the EPA's role in environmental destruction or protection,
First let us say that there are good people in the EPA who want to do
good things, and have done a few good things. Perhaps some are in this
room. BUT my message to you, the EPA, today is—don't be lazy. Don't
be a coward, Stand up against Trump's war on the environment Be like
the employees of the Badlands Park Service who posted the TRUTH
about climate change on the website. When you rule on this draft
permit, speak truth to power.
Today those of you from the EPA will be hearing or reading some good
science, and some bad science. The good science will be from
community members opposed to pollution of our precious Black Hills
aquifers. The bad pseudo-science—let's call it alternative science-- will
be from Azarga. EPA, believe the community members. Follow up on
the sources we provide to you and decide to stand for the truth, that the
in situ leaching will allow poisons into Black Hills aquifers. Learn these
truths—that Black Hills aquifers are permeable—they leak into each
other, so there is no way to sequester the toxic byproducts of in situ
leaching, And second, learn that ISL may use horrific chemicals like
sulfuric acid to do its gruesome dirty work.
Let's talk about hypocrisy and cynicism. It is breathtakingly cynical for
Azarga and other mining forces to stand before us today and say that
they will clean up after their mining activities. They cannot restore
leached water to its prior condition, and they know it. Consider this
quote from the US Geological Survey: "To date, no remediation of an ISL
operation in the US has successfully returned the aquifer to baseline
conditions."
And Azarga are crooks to boot! Their stock is worth pennies, and
Platinum Partners, which owns 30 % of Azarga stock, is under an
1
-------
A BONFIRE OF LIES
2
indictment that basically describes Platinum Partners as a Ponzi
scheme, according to the Rapid City Journal and other sources. So even
IF Azarga intended to use the most advanced monitoring and cleanup
methods on the Dewey-Burdock site, they wouldn't be able to afford it.
The people of Custer and Fall liver counties will be left with toxic water
and the bill to pay for it! Pay for it with the health of their children, their
stock, and their livelihoods.
How about let's talk about the opposite of cowardice—courage. Let's
look at what REAL environmental protection looks like. I think it looks
like the Native American folks who stood tall at Standing Rock,
defending the earth and the water against scum like the Dakota Access
Pipeline, and those who stood against the KXL pipeline. We here in this
room need to follow the leadership of those proud Native folks and their
allies to defeat Dewey Burdock.
We community members here in this room are all allies against
environmental destruction. We invite you, the employees of the EPA, to
stand for Mother Earth, to stand for clean water, to stand for the
principles that probably caused you to seek employment there in the
first place. Stand against these mining permits.
—30—
2
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U S EPA Region 8 Mai Code: 8WP-SUI
1595 Wynkoop Street
Denver CO 80202-1129
Attention: Yaiois Shea
May 10,201?
Dear EPA Region 8 representative,
I am writing to strongly urge you to deny the UIC Program Class V Area permits to construct and operate
up to eight (8) deep Injection wells within the Dewey-Burdock Project Boundary to be used for the
disposal of treated uranium ISR process wastewater into the iHinneiysa and Deadwood Formations.
My husband and I recently purchased property in Hot Springs & relocated here for the natural beauty,
peace, clean air & water afforded to a less populated part o! the country. This is intended to be our place
of retirement, I am deeply concerned about the prospect of our final residence being degraded and
devalued by the potential contamination of our water supply.
Our property, located at , has a well m the Minneiusa Aquifer The water is great
and we currently use it extensively to grow organic vegetables, feed our animals as well as many other
uses as needed outdoors. Since our property is 2 acres, it is large enough to tuMivide in the future if we
so choose. Any additional structure we may build on our property could be tap into our well for potential
household use Thai is of course unless you approve this permit.
These proposed permits for deep injection wells that would be used to dispose of ISR process waste
fluids into the Minneiusa Formation is a real threat to our family, home & community. For numerous
reasons including; 1) The mining industries recurrent inability to properly manage these materials safely,
?) The Black Hills geology is not static and the sheer movement of earth allows for the materials to flow
into our aquifers, 3) Uranium ts known to cause harm to human health & 4) The potential of increased
seismic activity could result in our town losing it's greatest resource, our water.
Following are some specific scientific articles restating the evidence to these reasons 1 have just pointed
out
1 )The 1 Iranian mining industry does not have a very good history of being responsible for ctean up nor
preventing accidents. According to lindsey Mclean, Biochemist & expert withness for NRCIASli in her
Position statement sH.e states, * Tennessee Valley Assoc drilled a total of 7850 torehoies looking for more
mine -3bie.'extractable uranium, but failed to find any, Pcwertech/Azarga was ordered by NRC/ASLB to
find and property close all of those boreholes before they would be able to actively mine, as ISL mining
requires aquifers to be contained properly for extraction efficiency. This is a hugely expensive process
and to date, no work has teen done on this ' information obtained by, UNITED STATES OF AMERICA
NUCU AR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before
Administrative Judges: Wiltiam J. froehfch, Chairman Dr. Mark O Barnett Docket No. 40-i0?5-MLA
ASLBP No 10-898-02-MLA-BDQt Source Ink; htps:/teww.nrc.iCivldo««l1512IML15l20A299 pdf
According to a Sep 23, 2013 Rapid City Journal Articled Tilled 'Leaks, spills, and other problems af in situ
uranium mines across the country* Journalist Daniel Simmons-Ritchie sites eight examples of violations
for other similar mining operations, hi
More recently, on April 3rd, 2017 the U S Nuclear Regulatory Commission cited Cameco Resources d»
Power Resources, Inc. with nine apparent violations were identified and are being considered for
escalated enforcement action in accordance with the NRC Enforcement Policy. Source: NRC
INSPECTION REPORT ©4®-08SS4l20t«»3,
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2) In addition, I have recently learned that The hydrology of the Black Hills area is very complex.
According to the USGSs website 'Numerous fractures, faults, and solution cavities alow flow of water in
rocks that otherwise are relatively impermeable" fink source; hipsi#sd,water.ysts,§ov/pfO|ectslbtiiis/introAtnil
In addition to the very common occurrences of spills, leakage and lack of proper containment as sited
previously & the geological data that shows that rock is not impermeable and water can flow into our
aquifers. Scientist from Arabian Journal of Chemistry state "Problems with Recovery of Mined Minerals
When Organic Compounds Contaminate an Aquifer. Summary: You cannot recover all of the uranium
from the mintng water Organised uranium compound levels will build up in the wastewater." Volume 4
« C». t.'Dt?; ,V> >1, Priges 381 377
3) With this inability to guarantee adequate protection comes real concerns to Human health. Science
clearly shows the dangers of Uranium to the human body Toxicology testimony by Unsay McLean, expert
withness for NRC/ASU3 on the birth deformities found in wildlife and domestic farm animals studied in
1SL mining sites contaminated by toxic waste water and radioactive metals. Can be reviewed here;
and mmiimmm.
A study by the Departments Biological Sciences, Northern Arizona University, Flagstaff Arizona USA
Department of Physiology, College of Medicine, University of Arizona, Tucson Arizona USA Titled
'Drinking Water with Uranium below the U.S. EPA Water Standard Causes Estrogen Receptor-
Dependent Responses in Female Mice*. Also provides evidence that uranium is an endocrine-disrupting
chemical and populations exposed to environmental uranium should be followed for increased risk of
fertility problems and reproductive cancers Source: JOURNAL ARTICLE Emmnmmiaf Health
Vol 115, No 1?(Dec 200 a pp 1711 1716 Published byllw Notwuil InsMufc. ol
ftttp://www.jstor. org/stab!el4S40m/Radium_Argonne
%20Nat»nal%20Lab.pdf
As a Yoga Instructor, I spend a considerable amount of my time and money to stay healthy. Pumping our
aquifer with the fluids coniaininf yraniym puts me, my family and our community at substantia! health
risks. Is the EPA going to pay for our long-term health care bills due to uranium exposure? Are you going
to provide me, my family & community with clean drinking water the rest of my life?
4) Furthermore, our city was founded and continues to be dependent on our water supply for our
economic well-being. So much so that our City Council recently approved' a Resolution 2017-10: A
Resolution to Reaffirm a Clywide Commitment for Clean Water and Water Resource Protection.
From May 1st 2017 minutes:
One of the reasons for this is that our small City's invested approximately $19 million to purchase Evans
Plunge Mineral Springs, one of the Black Hiis* oldest & popular tourist attractions. This resource
generates an income of approximately $800,000 per year according to our finance office at City Hall We
can sfirtpif not afford to risk one of our major resources.
According to studies published on the USGS website, "An unprecedented increase in earthquakes in the
U S mid-continent began in 2009. Many of these earthquakes have been documented as induced by
wastewater injection," from Journal article 'High-rate injection is associated with the increase in U.S. roicf-
continent seismicity' Science By: Matthew Vfemgarten, Shemin Ge. Jonathan W. Godt, Barbara A.
Bekins. and Justin L. Rubinstein. Source link: litp:l/pubs.er.usfs.80¥lpybiicatlon/701iii?8
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Earthquakes have been know to cause springs to dry up. According to U.S. Geological Survey Fact Sheet
096-03 By Michelle Sneed, Devin L. Galloway and William L. Cunningham, "Hydrogeologic responses to
earthquakes can create a variety of hazards. Water supply may be disrupted if welts 90 dry or become
too turbid to pump, and infrastructure damage may result from ground motion " Source link:
hips;fpybs,usis.govlfslfs-0ii-03l
Let's face it, the applicant is in it to make money and does not care about the consequences to the public.
It is your Job to protect the public's access to clean water per the Safe Drinking Water Act. No exemptions
should be made nor any permit be issued to mine Uranium nor dump toxic chemicals into our critical
acpafirs that are necessary to sustain life. Please use your conscious and legal obligations to the
American public and deny these permits.
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*
May 12,2017 RE: EPA permitting of proposed new mines
and mills in the Black Hills
U.S. EPA Region 8
Mail Code 8WP-SUI
1595 Wynkoop St. RECEIVED MAY 1 7 2017
Denver, CO 80202-1129
TO WHOM IT MAY CONCERN:
This is in regard to information I have just received today regarding the effort to prevent EPA permitting
of proposed new mines and mills in the Black Hills. This is to go on record as a "FRIEND" of the Black
Hills Clean Water Alliance.
The news from Rapid City, SO states "The Nuclear Regulatory Commission's release of a shortlist April 4
containing Homestake Mining Co.'s "apparent violations" of surface and groundwater requirements in
uranium mill cleanup underscored the latest efforts to prevent EPA permitting of proposed new mines
and mills in the Black Hills."
This is to comment on the EPA draft permits that would allow uranium mining and waste disposal to
take place in the underground water tables at the Dewey Burdock site in the southern Black Hills. The
Azarga Uranium Corp., formerly Powertech Uranium Corp., headquartered in China, wants an
underground injection permit for 4,000 wells in the inyan Kara Group of aquifers, so it can conduct in
situ leach mining and milling of yellow cake on the 10,000-acre site it is leasing at the Cheyenne River
headwaters 50 miles west of the Pine Ridge Indian Reservation near Edgemont. Further, the company
also wants EPA to grant it a deep underground disposal well permit, allowing the mine and mill to pump
its wastewater through four wells into the Minnelusa Aquifer for final disposition at a depth of 2,800
feet.
If Azarga Uranium Corp, doesn't obtain the deep disposal permit, it is set to seek a permit to apply the
wastewater to the (and surface, according to the environmental impact statement prepared for a
Nuclear Regulatory Commission license that is being contested by the Oglala Sioux Tribe, headquartered
at Pine Ridge Indian Reservation.
Reading all the above makes one wonder if the EPA Federal Agency is really and truly effective, and
considers the effects on ail of mankind and humanity. I am one of millions of the average citizenry of
our great country, and do not have a whole lot of initials after my name, but am of the opinion I don't
need those to make an intelligent response to the article "regarding the fight uranium mining in Black
Hills." Common sense is all that is needed to know how dangerous and hazardous such projects in the
Black Hills pose to humanity.
I am of the opinion mankind and humanity no longer matter to the EPA, NRC, or any other federal
agency of the government. I am of the opinion the "almighty dollar of profits", no matter if the
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RE,* EPA permitting of proposed new mines and mills in the Black Hills page 2
beneficiary is of our country or from a foreign country, is all that matters. The federal government
making reference to regulating anything, no matter what the subject may be, is one big false effort.
Companies no matter who they are or where they are from are granted permits, licenses, and
everything they need to do their projects, but none are ever made to clean and restore the land once
they have taken all that they can from the land and water.
Our land, both surface and subsurface have been exploited for so long and for so much, that it is
amazing the whole earth does not cave in to become one big sinkhole, to say the least regarding climate
change,
I am sure there are some workers in all the bureaucracy that really care about mankind, but the profits
to be made and the end $ figures to be made under the guise of progress and energy independence
ensure that mankind and all of humanity should appreciate each and every day that they wake up and
have air to breathe and water to drink (even if it is a little polluted), just be grateful for being able to rise
another day.
The air quality, the water quality, climate change, the whole environment quality is of no concern to
those few with the wealth to continue to expand their personal empires where only those few will
benefit, and humanity is on its own (every man for himself). One day this whole country is going to be
one big sinkhole thanks to all the underground pipes, fracking and drilling for "supposed energy/fuel
resources, and defense purposes", all the violations of surface and groundwater requirements, there will
be no future for our grandchildren who will be forced to survive with the barest minimum which may
come down to "only the strong survive". Of course there are some people that say "climate change is a
hoax", but that is their opinion and won't be worth much when the country and the world have to pay
the price for all the exploitation that has already been done to contaminate the quality of air, water,
surface and subsurface areas of our country and the world.
The sound of these comments may sound like doom and gloom but that is exactly what the end result of
development, progress and energy independence is causing to happen to our country and this world.
Forget the open spaces, the greenery, foliage, forests, wetlands, habitat, animal species, because some
wealthy mogul has a need to increase his personal profits, and these topics and certainly the effects on
mankind are the last things to be considered at all. The effects on the environment or on mankind
never enter the equation at all. ONLY PROFITS are to be considered!! How much wealth does a person
need to be satisfied with themselves and be happy each and every day? At the rate of exploiting our
country and the world at such a fast pace, one day there won't be a need for any of the federal agencies
to even exist, or if they do, for them to pretend there are regulations that prohibit or govern procedures
how something should be done.
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Re: EPA permitting of proposed new mines and mills In the Black Hills
page 3
Every elected official in this country, no matter what level of government, be it federal, state,
city/county or tribal should consider it a privilege to represent the people, and serve to the best of their
ability for what is best for the people. Yet, any person with common sense knows the elected officials,
no matter the level of government, cannot accomplish what is needed, unless they have a majority of
votes to accomplish what is best for the people. Partisan and bi-partisan become so tangled and
enmeshed to "win a battle and forget about winning the war", whatever the topic is, that in the end
nothing is accomplished, and the common citizenry can do nothing about our own personal situations,
except continue to strive to meet each new day with hope and be thankful for each new day,
I hope this letter expressing my concerns receives fair, uniform, and equal treatment and consideration
that I richly deserve. Thank you for this opportunity to submit my response to oppose the projects being
proposed to occur in the Black Hills,
Sincere!
FRIEND
To the Black Hills Clean Water Alliance
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^ kubjrrufts^ 5J9I(J
Helio, my name is that's ancl 1
believe I speak for many that cannot be here today, they just simply could
not take off work or have family obligations.
Having hearings during the week when people have to work, makes it
very difficult,
I wonder if most of the frustration we hear is because people are
frustrated that they have to fight for what is righfully theirs?
Water is the most important ingredient to life.
We cannot survive without good water.
Everyone in this room knows the pitfalls and danger to our water this
project possesses. The amount of water asked by this foreign company,
for FREE, is ridiculous. City residents pay for thier water use, why should
we give it away to a foreign company?
To give away so much water in a semi-arid region that suffers from
drought more often than not, is a disaster in the making. We rely heavily
on our aquifers. The Ogallala Aquifer is important to the plain states. It is
a vital resource we cannot sqander. Human demands on this water that
sprawls underneath parts of eight states from South Dakota to Texas.
Landowners strive to conserve what's left, they face a tug-of-war between
economic growth and declining natural resources. We should not give
away so much to a foreign company.
They claim there is no connectivity between the aquifers, and their
project is completely contained. Spelunkers thought they reached the end
of the third largest cave in the world, Jewel Cave, which is north of the
project. The spelunkers were thrilled when they squeezed through that
tight space and found yet more huge caverns. We are not confident with
Powertech Azarga's claims of knowing what lies beneath.
The transportation and disposal of all related waste is an issue with far-
reaching compromises to the environment, and contains its own very long
list of concerns. They have found radioactive tracking socks discarded in
North Dakota illegally. Is there any wonder we are skeptical of another
extractive business?
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You have heard already, from other testimony that we can not trust this
company. Powertech Azarga's lobbyist wrote legislation and got it
passed, whether by ignorance or corruption, that has made this project
a self-monitored operation. This was intentionally introduced to make it
easier for them to Self-Monitor. This was an underhanded and arrogant
thing to do to South Dakotans. How can we ever trust Powertech Azarga
when they have this kind of dishonest intentions? Why, if the process is,
to quote Mr Hollenbeck, "safe and benign", would we need to change the
rules to make it easier for a company to destroy an area and then walk
away without paying the consequences. Asking for an aquifer exemption
should certainly make clear their intentions.
Many people use the very same Inyan Kara aquifer that the mining will
be done in, and are at lower elevations. The deep disposal of waste into
lower aquifers, is just an easy means for disposal of this toxic waste. Out
of sight, out of mind, and too deep to be monitored.
Will it flow into other aquifers?
What happens after they are finished and long gone?
Who monitors it then?
Who cleans up any leaks or excursions from waste disposal ponds?
Who pays for it?
Once stirred up, the process continues, leaching forever into the gound
water around the project area. Into Beaver Creek, into the Cheyenne
River, into Angostara Reservoir, where people swim, fish and enjoy the
outdoors.
Since the recovery of the uranium is not 100% and they are not pulling
the other harmful elements out for production, arsenic, which is a known
cancer-causing metal and contaminates wells. Molybdenum and
Vanadium, etc. are another elements that could be extracted. But I see
no intention within permits to recover anything other than uranium. AH
that will be waste. We recycle plastics, glass and cardboard. Why
wouldn't it be fiesable to insist on the recovery of ail heavy metals and
elements that are extractable from the process?
The market for uranium is at an all-time low. Thanks to the ongoing fiasco
of Fukushima and the shift to new renewable technology on the rise.
Why would we risk contamination of a more precious resource, for
uranium, that may not be used for energy in the future? Again is this worth
the risk? Here I would like to remind you that the half life of uranium is
4.5 BILLION years.
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« - •" • •
At this time it is not economical to extract. At $22,50 a pound, perhaps Mr
Hollenbeck with his organic farming background should look for a more economic
and ecologically sound idea for creating jobs in Edgemont by growning hemp.
It's worth far more than uranium.
Once extracted and shipped to Canada for placement on the International
market, where would this uranium end up? Perhaps China, North Korea, or Iran?
There are concerns for the safety of our tourists, our second largest economic
sector.
We have so many scenarios of accidents going through our minds. What would
happen if one of our vacationers had an accident with a truck filled with uranium
heading to Canada?
What if there was a fire at the accident? Who would respond?
What if there was a fire at the operation?
Who would respond? Are the first responders equipped and trained to deal with
such accidents? The trucks would have to be marked as radioactive. How does
that look to people vacationing here? What would be their Perception of the Black
Hills then? Would that deter them from a return visit? The company, when asked
at the hearing prior to this, they were unclear on many safety issues.
The Black Hills enjoys a relatively sound economy. Agriculture and tourism
supports the majority of businesses. We who live here have an opportunity to
enjoy the attractions and the beauty as well, it's just a nice place to live, 1 hope
you have a chance to enjoy some of the beauty here in the Black Hills while
you're here. If you should visit the shrine of democracy, Mount Rushmore, think
about the people, the water people drink from the fountains there. This is water
from one of our aquifers. What statement does it make if we allow Powertech
Azarga to use and contaminate that same water?
Thank you, and 1 hope you reach the conclusion that you must not further this
permit. Thank you.
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Written Testimony May 10, 2017 Hot Springs Public Hearing
EPA Hearing
We drink water. If these water aquifers will be contaminated, then we will have no clean water to drink.
As a licensed EMT, we will see more hospital visits. We will have more ambulance rides here to Rapid
City. This means severe dehydration cases. We must prevent these cases, so the ambulance and
personnel can be used for heart attacks. I will be quoting Emergency Care 12th Edition on how water is a
part of the human body.
"About 60 percent of the body is made up of water and without this fluid the functions of the cells
would cease. Water is distributed throughout the body both inside and outside the cells and balancing
this distribution is an important part of maintaining normal cellular function. Normally water is divided
among three spaces in the body, with the following percentages representing averages.
• Intracellular (70 percent) - this is water that is inside the cells
• Intravascular (5 percent) - this is water that is in the bloodstream
• Interstitial (25 percent) - this water can be found between cells and blood vessels.
We regulate the levels of water in our body by drinking fluids and making excretions, urine. This allows
us to constantly adjust our hydration based on our levels of activity. Inside our bodies, fluid is
distributed appropriately through a number of factors:
• The brains and kidneys regulate thirst and elimination of excess fluid
• The large proteins in our blood plasma pull fluids into the bloodstream
• The permeability of both cell membranes and the walls of capillaries help determine how much
water can be held in and pushed out of cells and blood vessels.
Each of these factors helps us regulate the amount and distribution of fluid. If these factors were to be
interfered with, fluid levels and distribution can become problematic.
Dehydration is an abnormal decrease in the total amount of water in the body. This may be caused by
decreased fluid intake or a significant loss of fluid from the body by one or more of a variety of means.
Remember, however, that maintaining a balance of water relies on a healthy gastrointestinal system.
Fever, vomiting or diarrhea can also significantly alter the amount of water in the body. Fluid can be lost,
as well, through rapid breathing (as in a respiratory distress patient) and profuse sweating. The plasma
protein of blood can be lost with injuries such as burns." "Dehydration results from losing more fluid
than the patient takes in. This is very common in hot weather, when the patient sweats a great dela but
done not drink enough liquid to keep up with the fluid (heat exhaustion)."
Quote from Brady, Emergency Care, 12th Edition, Daniel Limmer and Michael F. O'Keefe.
If our waters are contaminated, then our youth will not be protected. Our citizens will not be protected.
Our future is at stake. We protect our youth and help our EMTs and first responders by leaving the
uranium in the ground. As a candidate for City Council, and if I get elected, I will fight to protect our
youth and citizens of Hot Springs. So I am asking you to stop the mining and the wells, to protect
American citizens. I don't want to see the Black Hills become a third world country. I just helped with a
6K for water from World Vision to bring clean water to 22 kids and families overseas. So
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let's not turn the Black Hills into a third-world country. As candidate for City Council, if I am elected, I
will fight to protect the City of Hot Springs, Black Hills and Reservations.
Note: the EPA needs to visit the Evans Plunge, water from the Madison aquifer.
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Resolution 2017-10
A Resolution to Reaffirm a Citywide Commitment for
Clean Water and Water Resource Protection
BE IT RESOLVED by the Common Council of the City of Hot Springs, South Dakota, that we are
committed to preserving and maintaining the amount and quality of water for the citizens of
Hot Springs and its surrounding environs, and
Whereas: The City of Hot Springs was first developed as a town in the late 1800's due to its
proximity to the Fall River and the abundant natural warm mineral springs within the valley, and
Whereas: The City of Hot Springs has made long-term investments in stormwater management,
potable water systems and wastewater management programs and infrastructure to reduce
nutrients and pollution in our waters and to protect our vital water resources, and
Whereas: The Common Council is obligated to preserve and protect the public health, safety
and welfare by preventing the pollution of, and maintaining the quality of the water entering in,
held within and removed from aquifers serving as the City's water source, and
Whereas: The City of Hot Springs has stated in its water ordinance that our mission is to provide
the City's water customers with a safe drinking water supply, water for fire protection and an
adequate supply of water for our essential daily needs, and
Whereas: The City of Hot Springs Common Council finds that any pollution or contamination,
willful or not, of our water supply to be a direct threat to our community and its health, safety
and welfare, and
Therefore: Be it resolved that the City of Hot Springs will take necessary action to ensure the
perpetual purity and quality of the waters available for use by the citizens of Hot Springs and
those the City distributes water to, and
Therefore: Commit to support any action from the County, State or Federal Governments aimed
at protecting the waters of South Dakota, both surface water and underground aquifers, as a
critical natural resource necessary for life.
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RECEIVED JUN 1 9 2017
Valois Shea
U.S. EPA Region 8
Mail Code; 8WP-SUI
1595 Wynkoop Street
Denver, CO 80202-1129
Dear EPA, Region 8:
My name Thank you for the opportunity to comment regarding the Underground
Injection Control Program's Draft Permits for the Proposed Dewey-Burdock Uranium Mine and Deep
Disposal Wells in South Dakota. 1 am grateful to have been able to attend some of the public hearings
held at the Ramkota in Rapid City in May; grateful that some avenue is open to the people to have a
voice in this important decision that will affect everyone. At the hearing, I was nonetheless surprised
and encouraged to find that citizens from every walk of life, political stripe, age, race, and religion
stood together in opposition to the threat that the proposed permits would bring to our land.
Not knowing what to expect at the public hearings, I went to show my opposition just by being there.
Never did I anticipate rising to the podium to speak. Since time allowed and no other speakers had
submitted their names, I too, stood before you to beg you to please deny these permits. Here I have
taken some more time to formalize my thoughts.
As a concerned citizen and life-long resident of Rapid City and the Black Hills, I am opposed to any
further uranium mining in this area and to the use of in-situ recovery of the uranium. The risk of
irremediable harm to the water supply, the environment, and ultimately human life should any
contamination by radioactive agents occur, far outweighs any economic gain or consideration.
My Bachelor's Degree is in Chemistry from the South Dakota School of Mines and through my studies I
understand that radioactive waste must be thought of as forever, since the half-life of some of the
materials might be hundreds, thousands, even millions of years. To disrupt the mineral deposits by in-
situ recovery and then return the spent water into the underground aquifers is simply too great a risk.
It is not possible to remediate nuclear waste, only contain it. A deep disposal well in an aquifer, no
matter how deep, is connected to other water sources and should not be considered a place of
containment. Water is not stationary; surface water and ground water are interconnected. The
proposed wells are in an area known to have geological faults and fractures, and thousands of old
boreholes. If during the in-situ recovery and disposal the massive volumes of water are pumped in and
around these potential escape routes, the poisoned water might easily find its way into other aquifers
or water sources. Adequate oversight of the quality of liquid wastes pumped into the Minnelusa
Formation through the proposed deep disposal wells will be impossible, and our groundwater is likely
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to be contaminated. Furthermore, the use of such large volumes of water would alone create great
hardship for our ranching families and their livestock. Most of my life we have experienced year after
year of drought in western South Dakota,
What science experiment ever has one-hundred percent efficiency? Since the history of uranium
mining indicates that uranium mining cannot be done without creating and leaving contamination by
radioactive and heavy metal pollutants, the text of the permits already includes exemptions to the
uranium-bearing portions of the lnyan Kara Group aquifers. In my reading 1 have learned that if no
exceptions or exemptions to existing environmental laws were granted, no part of this operation
would be allowed.
Simply because we can obtain uranium through in-situ recovery does not mean we ought. As I listened
to each speaker, my horror of allowing the permits only intensified. I heard a South Dakota Legislator
tell of the hasty way some state laws were crafted to allow for the work on the Dewey-Burdock project
to proceed, a young Native American mother promise to pray for those making this decision and
remind us all that monetary riches are fleeting, a woman rancher from the area describing how quickly
in Just a normal summer the wells might dry out enough to run toxic for the cattle, how the company in
charge of this mine has already left a Colorado mine without cleaning it up, and a U.S. Veteran describe
the chemical munitions stored at the Army Depot near the mining site, yet another threat to our water
supply and life. Earlier in the day, my own father wondered just who would end up with the uranium
should it be mined.
Thus for reasons of national security, the protection of the water supply for all the Black Hills and
western South Dakota, the livelihood of area ranchers, and the health of the water we leave for our
children and theirs, I once again beg you to please deny these permits.
Should the water permits be allowed and the Proposed Dewey-Burdock Uranium Mine and Deep
Disposal Wells project move forward, I fear for the life of the Hills, the land and its people.
Thank you for your kind consideration.
Sincerely,
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&wferruiisiJ fe«j
W&y 10
To Whom it may concern,
In response to the two draft permits and future proposed Dewey-Burdock uranium mining plan, I would
like to respond as follows:
First, as a Critical Care Registered Nurse, I have practiced nursing for 40 years. With all the most
advanced technology available, in all practice, it is the basics of life that precedes all else -
Airway, Breathing, Circulation - "ABC's of Life". So it is with this proposal, there is NO LIFE without
WATER! Absolutely no water source should be purposefully contaminated. Attached is a copy of the
Well .Drilling Report for my well. It shows 'that it was drilled through the Minnelusa aquifer, down to the
Madison aquifer. This hole will be a source of contamination from the Minnelusa to the Madison. There
are MANY such wells throughout the area that will allow this cross-contamination to occur. Natural
fracturing of the geological layers will also serve as contamination points between aquifers. I also have
several neighbors who have wells drilled into the Minnelusa and utilize this water for their every day 'use.
Water is VERY precious in this area as many people haul their water or have it delivered to cisterns.
Contamination is NOT AN OPTION!! It is a scientific fact that the Minnelusa flows from west to east It
would flow directly to my area, and ultimately contaminate the entire regions' water sources.
I also am against this proposal for the following reasons:
* Hie previous mines in the Dewey-Burdock area have not been fully reclaimed.
* Adequate oversight of the quality of liquid wastes pumped into the Minnelusa Formation
through the proposed deep disposal wells will be impossible and NOT a SINGLE
accident can be allowed.
* There are over 7000 old boreholes that have not been properly plugged, making it
impossible to contain mining fluids or waste liquids. Contamination of our groundwater
would be almost guaranteed.
* There is no need for uranium for use in the United States. All of it would be shipped out
of country - contaminating our lives, for foreign countries, i.e. potential enemy use.
AMERICA FIRST!
* The Black Hills region is dependent on Tourism as one of our prime sources of income.
Contamination of our water sources would render this a "Dead Zone" to tourism, not to
mention total evacuation of the local population would follow.
This is not another "Not in my back yard" argument. This has the potential for severe disastrous
consequences. I IMPLORE YOU to deny these permits.
-------
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5/17 EPA HEARING TESTIMONY
My name is l'm a retired pathologist living in
the Black Hills.
I'd simply like to report to you that in 2014, after a
discussion of the ISL uranium mining technique and the
potential risks to SD aquifers, the SD Medical Association
adopted a resolution opposing uranium mining in the state.
It was felt that the risks outweighed any potential benefits
to residents of the state.
In this action, SD followed the example of the CO medical
association, which also went on record to oppose uranium
mining.
I think physicians in the region are concerned about the
public health consequences of any prolonged increase
over background radiation exposure (even if small)
experienced by humans or food animals, and are
concerned as well about the chemical toxicity of uranium
and other heavy metals freed during the ISL procedure.
Proven and potential cross-communication and cross-
contamination among aquifers pose a significant risk to
health which the proponents of ISL uranium mining have
no way of providing absolute protection against.
Thank you.
-------
rmxj n
My name is IBIB- I8111 eunently living In Bdgeniaiit, South Dakota. I have
a relative whose fiist wife grew inhere. She died of cancer at 37. Ik only tiling he
will say Is, "Don't drink the water.**
As a young man, I lived a few jobs in Utah, whore I tad to comfort a KMMnmaie
Horn St Geoij^Utahwholosta If-year-oMtaoiierto l^3ttlD0EL Children there wed to
write their names in. die nuclear fiUout dost covering automobiles.
A July 2017 eleven-page Special Report to the Oregouiai reported there were an
estimated 400,000 Atomic Veterans ordered to be nuclear guinea pigs under or near
atomic test Masts, and the reluctance of government experts to acknowledge ongoing
health damages.
Salt Lake's DeseietNews spent ye« documenting the aitace ofinaensitivity and
denial of fist the Atomic Ena^ Commission aid then the Nuclear KfiguJatmy
Commission, a cosmetic change tint rode Utile actual difference. More recently, I
knew a Rapid City South Dakota photopapher who .loved vacationing in the beautiful
Utah areas wiAtteajfereflectsofhundfedsofuianium mines and nuclear tests. lie
died of cancer. leouMnotwsistiiM;Mngiipa^pvoftl>ebodk:tMed»lheIMvThev
1 tombed Utah by John Fuller.
The fiat of nuclear test problems ad tosses is mind-numbing. These countless
examples demonstrate an ongoing culture of denial and inseasitivity that carries forward
to this day. I can see why regulators would block out things which would eost them
their jobs and bring billions of dollars in lawsuits.
According to pad engineers working for the Chinese uranium mining company,
Azaiga, they and the Nuclear Rcguiataty Commission are best qualified to look after
our safety an! wel fare.
Not everyone always sees it that way. In 2007, then candidate Iiarack Obama
stated, "The NRC is a... moribund agency that needs to be revamped and has become
captive oftiie industries that it regulates,** accenting to a Reene (NIL) Sentinel
interview.
A ProPubliea website article teed December 26,. 2012 on Wyoming in situ
mining notes "The Safe Drinking Water Act forbids injecting industrial waste into or
above drinking water aquifers, but the EPA issued what are called aquifer exemptions
that gave mine operators at the ranch permission to ignore the law. Over the last three
decades, the agencyhas issued more thim 1,5000 such exemptions iratknwidb,alk)wing
energy aiKl mining companies to pollute portions of at leastl 00 drinking aquifers"
A USGS stuffy published by Otton in 2009 found "to date, no remediation of a
ISR operation in the United SMes las successfully returned the aquifer to its baseline."
free rings throughout the West provide an historic record of draughts faatiqg as
long as 30 yejirs. This would drastically argue against proposed calculations of ground
water recha^^je.
Whoa tritium, from nuclear fallout moved through groundwater in the Inya Kara
Group at fifteen feet per day it indicated possible flaws in the rocks, or parous lenses.
This data was either ignored or explained away. A recent paper said the 1963 tritium
-------
data showing much faster velocity Is an unresolved issue. (South Dakota Academy of
Science, Vol. 93 (2014) p. 28.)
Research experiments by Duke University published on October 26,2010 showed
placing C02 underground for greater than 300 days, "could pose a risk to overlying
fresh groundwater." Ibey further said, "potentially dangerous uranium and barium
increased throughout the experiment in some samples." This showed underground
storage of CG2 create carbonic acid and is not harmless.
No exemption should allow placing nuclear waste in waters which could be used
by agricultural animals and thus indirectly by humans.
-------
Si 911J
M¥ NAME I LIVE IN RAPID CITY. MY PH.D. IS IN POLITICAL SCIENCE, WITH
AN EMPHASIS ON ENVIRONMENTAL POLICY. I STARTED STUDYING URANIUM MINING IN 1979, WHEN
ABOUT TWO DOZEN LARGE COMPANIES THAT WANTED TO MINE URANIUM HERE WERE CONVINCED TO
LEAVE EMPTY-HANDED. IN RECENT YEARS, 11 URANIUM COMPANIES HAVE EXPRESSED AN INTEREST IN
THE BLACK HILLS.
MY DISSERTATION CONSIDERED TRIBAL-FEDERAL-STATE GOVERNMENT RELATIONSHIPS
AROUND NATURAL RESOURCES. PART OF THAT RESEARCH WAS CONDUCTED UNDER AN EPA
FELLOWSHIP, i HAVE PUBLISHED ON THESE TOPICS IN PEER-REVIEWED JOURNALS AND PRESENTED THE
RESULTS OF MY RESEARCH AT A NUMBER OF PROFESSIONAL CONFERENCES.
I FOCUS ON POLICY AND THE ROLES OF GOVERNMENT AGENCIES ON THE URANIUM ISSUE. I
AM ON MY THIRD DAY OF OBSERVING YOUR HEARINGS ON THE DEWEY-BURDOCK PROPOSAL, AND I
HAVE READ LARGE CHUNKS OF THE RELATED DOCUMENTS. MY PRELIMINARY CONCLUSION IS THAT
SOME OF THE EPA HAS BEEN CAPTURED BY THE URANIUM INDUSTRY. FOR THOSE IN THE AUDIENCE
WHO DON'T KNOW THIS TERM, WHEN I SAY "CAPTURED," I MEAN THAT THE AGENCY HAS COME TO
RELATE TOO CLOSELY TO THE COMPANIES IT REGULATES, TO THE DETRIMENT OF THE GENERAL PUBLIC.
THIS IS A DIFFICULT THING TO SAY, AND YOU DESERVE TO HEAR MY REASONS FOR THIS
CONCLUSION.
THE FIRST REASON I SAY THIS IS THE USE OF LANGUAGE BY REPRESENTATIVES OF THE AGENCY
AT THESE HEARINGS. INSTEAD OF SAYING THAT PARTS OF THE INYAN KARA AQUIFERS ARE UNDER
CONSIDERATION FOR EXEMPTION, YOUR STAFF SAID, "THE AREAS THAT WE ARE EXEMPTING" - AS IF
THE EXEMPTION HAS ALREADY BEEN GRANTED-OR AT LEAST AS IF THE DECISION HAS ALREADY BEEN
MADE. IN THE POWER POINT THAT I HAVE NOW OBSERVED SEVERAL TIMES, THE SLIDE ON THE ROLES
OF THE VARIOUS AGENCIES MAKES IT SOUND AS IF THE PERMITTING PROCESS IS ALL BUT COMPLETE.
IN FACT, THE NRC LICENSE IS UNDER LITIGATION. THE STATE DENR HAS ONLY HELD ONE WEEK OF
-------
HEARINGS ON THE PROPOSED LARGE-SCALE MINE PERMIT, AND THAT HAPPENED 3 YEARS AGO. IN
FACT, THE PROCESS HAS BEEN ON HOLD SINCE THEN.
THE SECOND REASON ! SAY THAT SOME OF THE EPA HAS BEEN CAPTURED CAN BE FOUND ON
THE INFORMATION SHEETS THAT HAVE BEEN PASSED OUT TO THE PUBLIC ATTHESE HEARINGS. ONE OF
THEM IS TITLED "HOW MUCH GROUNDWATER WILL BE LOST FROM THE INYAN KARA AQUIFERS?" THIS
SHEET, AS WELL AS THE INFORMATION PRESENTED WITH THE POWER POINT, INDICATE THAT ONLY "A
SMALL PERCENTAGE" OF INYAN KARA WATER WILL BE CONSUMED, THIS FOLLOWS THE COMPANY'S
LINE, BUT IT DOES NOT FIT THE FACTS, THE INYAN KARA WATER THAT IS BEING USED FOR MINING WILL
BE RUN THROUGH THE REVERSE OSMOSIS PROCESS. IT IS COMMON KNOWLEDGE THAT REVERSE
OSMOSIS IS AN INEFFICIENT WAY TO PURIFY WATER, BECAUSE IT TURNS AT LEAST 30% OF THE WATER
IT HANDLES INTO WASTE WATER, THIS MEANS THAT AT LEAST 30% OF THE INYAN KARA WATER USED
BY THE PROPOSED MINE WOULD BECOME WASTE, NOT THE 1% OR THE 3% THAT THE COMPANY - AND
THE EPA-- CLAIM. THE EPA MAPS MAKE THE BARRIER LAYER BETWEEN THE MINNELUSA AND MADISON
AQUIFERS UNNATURALLY LARGE-AND CONSISTENT-AND MINIMIZE THE SIZE AND IMPORTANCE OF
THE MADISON AQUIFER,
THE EPA FAILS TO ACKNOWLEDGE THE DOZENS OF VIOLATIONS AND REPORTABLE INCIDENTS
AT JUST ONE IN SITU LEACH MINE - THE CROW BUTTE MINE - OR TO TALK REALISTICALLY ABOUT THE
FACT THAT EXCURSIONS AND LEAKS ARE "NORMAL" FOR IN SITU MINES, IN FACT, AT AT LEAST TWO ISL
MINES, EXCURSIONS HAVE REACHED OUTSIDE THE MINE BOUNDARY, INSTEAD, THE PUBIC IS
PRESENTED WITH A SANITIZED, READY FOR PRIME-TIME VERSION OF THE ISL PROCESS THAT CAN BE
DISPLAYED BY NEAT DRAWINGS.
THIS LACK OF REALISTIC CONSIDERATION OF THE IN SITU LEACH MINING PROCESS BODES
POORLY FOR THE PUBLIC, AS IT INCREASES THE PROBABILITY THATTHE AGENCY WILL ISSUE FINAL
PERMITS WITHOUT EVER HAVING GIVEN A "HARD LOOK" AT THE PROPOSAL, I KNOW THAT THE
-------
AGENCY IS LIKELY TO GET SUED, WHETHER IT ISSUES FINAL PERMITS OR NOT, BUT THIS ONE-SIDED
CONSIDERATION OF THE SITUATION SIMPLY INCREASES THE PROBABILITY OF EXTENDED LITIGATION -
AT TAXPAYERS' EXPENSE. SO DOES THE LACK OF PROPER TRIBAL CONSOLATION, WHICH HAS CAUSED
THE NRC ENDLESS HEADACHES, YOU CAN'T START TRIBAL CONSULTATION PART WAY THROUGH THE
PROCESS. IT NEEDED TO BE COMPLETED YEARS AGO.
I WOULD STRONGLY SUGGEST THAT THE EPA REFOCUS ITS EFFORTS WITH FULL CONSIDERATION
OF THE EASILY-AVAILABLE INFORMATION ON THE PROBLEMS ASSOCIATED WITH ISL URANIUM MINING
AND DEEP DISPOSAL WELLS. AS I THINK HAS BEEN ABUNDANTLY CLEAR DURING THESE HEARINGS,
ONLY THEN CAN THE AGENCY REALLY DO ITS JOB TO THE BENEFIT OF THE PUBLIC, RATHER THAN A
FOREIGN CORPORATION. YOU ARE SUPPOSED TO BE ACCOUNTABLE TO US.
THANK YOU FOR THIS OPPORTUNITY TO COMMENT. I PLAN TO SUBMIT FURTHER COMMENTS
BY MAY 19.
-------
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U.S. Environmental Protection Agency, Region 8 May 14,201?
Attention; Vatois Shea, mail code: 8WP-SUI
1595 Wynkoop St,
Denver CO 80202-1129
I am writing to express my concern for a proposed mining activity in the southwest comer of
Custer County, S.D. and northwest corner of Fall River County S.D., in and around the area of Dewey and
Burdock S.D.
The proposed in-situ mining of uranium, water extraction for that purpose, processing, and
disposal of waste, in my opinion, has not been adequately researched prior to consideration for
permitting this operation. The potential impact to life and environment possess a significant threat.
1 learned of this concern from public opinion, the Black Hills Clean Water Alliance (BHCWA), and
the population that would be impacted by this activity. Unable to attend any public hearings that
addressed all the concerns and their recording, I explored these issues by reading a formal research
report compiled by BHCWA. I believe there is, validity for opposition; particularly that detailed in the
report performed by Dr. Hannan laGarry and his assistants, which was recorded and submitted to the
NRC in November 2014, A copy of Dr. LaGarry's research is attached for your consideration.
This report captured my attention mainly because of my education; t am a geological engineer
with an emphasis in hydrogeology. 1 found this research/report to be quite appropriate and significantly
accurate enough to reconsider any permits that may have already been issued or are now being
considered to allow this proposed mining, water extraction, and waste disposal to take place.
It is my professional opinion that Powertech's proposed mining and activities surrounding such
will have a detrimental impact in the immediate area, as well as downstream of the Cheyenne River and
beyond. I am opposed to this activity the way it has been presented.
Geological Engineer (Colorado School of Mines)
RECEIVED MAY 1 3 2i?
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OST -029
UNITED STATES OF AMERICA
NUCLEAR REGULATORY COMMISSION
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
In the matter of
POWERTECH (USA) INC.
Docket No. 40-9075-MLA
ASLBP No. 10-898-02-MLA-BD01
(Dewey-Burdock In Situ Uranium
Recovery Facility)
November 21,2014
WRITTEN SUPPLEMENTAL TESTIMONY OF PR, HANNAN LAGARRY
1,
|, hereby declare as follows:
1. I am an expert in the above-captioned proceeding; my testimony, C Y, arid area of expertise
are already in the record. To summarize, I am a stratigraphic mapper and full-time professor
at Oglaia Lakota College in Kyle, South Dakota. In preparing this declaration, 1 relied on the
expertise gained through my training and experience in reviewing and interpreting borehole
logs and other geologic data to create and review narratives, representations, and maps of
subsurface geology and hydrogeology.
2. My testimony herein is based on my review of Powertech's recently disclosed borehole logs,
maps, and other data. My testimony is also based on my review of the testimony and exhibits
submitted by both NRC Staff and Powertech to the Nuclear Regulatory Commission Atomic
Safety and Licensing Board, and my expert opinions offered before and during the hearing in
Rapid City, South Dakota.
3. On November 12, 14, and J 5, 2014 myself and 3 student assistants continued to review
drillers' notes and borehole logs prepared by the Tennessee Valley Authority and recently
disclosed by Powertech. This review was conducted at the Powertech offices in Edgemont,
South Dakota.
The available data consists of paper flies contained in 28 bankers' boxes, 5 file cabinets, and
31 sets of mini logs (reduced to about 1/10th of the full-sized logs). Based on records I
reviewed during my initial visit to the Powertech offices on September 14-16, 2014 these
boxes, cabinets, and mini logs contain at feast:
7515 total borehole logs
7454 known borehole logs prior to acquisition of the recently described data
3920 borehole logs owned prior to acquisition of the recently disclosed data
3075 digitized data logs
1
1
-------
OST-029
These totals may underreport the number of logs made available, as I was not able to confirm
whether my count was inclusive of all logs made available. Our understanding was that the
newly disclosed borehole logs numbered over 4,000 data sets.
In total, my assistants and 1 were able to review drillers' notes from 4,177 boreholes (56% of
the 7515 listed above) in 2,5 bankers' boxes, with at least 2.5 bankers' boxes of similar
records remaining unexamined. We also examined 488 full-sized (in 3 boxes) and 1774
"mini" resistivity and gamma log pairs (30% of the 7515 listed above), with at least 6
bankers' boxes and 5 file cabinets of similar records remaining unexamined. The number of
notes and logs examined was likely 5% fewer than the total number of records reviewed
because some logs and notes were discovered to be moved or missing (see below). Also,
there is overlap between the drillers' notes and the "mini" borehole logs reviewed. The
"mini" logs, although briefly reviewed, did not contribute to the observations listed below.
My review confirmed my previous testimony that the raw data was not presented by modern
modeling 1 would expect to find in such data compilations. Because of the limited time
available and the lack of modelling, we did not attempt to reconstruct the geology of the
proposed license area. Rather, we focused on the first-hand accounts of the geology of the
site and the drilling conditions recorded by the geologists logging the wells. Based on our
review of the data, we documented the following unique instances:
140
open, uncased holes
16
previously cased, redrilled open holes
4
records of artesian water
13
records of holes plugged with wooden fenceposts
6
records of holes plugged with broken steel
12
records of faults within or beside drilled holes
1
drawing of 2 faults and a sink hole within a drilled transect
7
notations "do not record this value on drill hole maps"
2
notations "do not return this to landowner"
63
redacted borehole logs
Many notes contained references to water at various levels and poor, muddy, or destroyed
samples. We also found that, in the data sets we reviewed, blocks of records had been moved or
were missing.
4. Based on the observations noted above, I offer the following expert opinions:
Sample size
We examined drillers' notes from 4,177 boreholes, which is at least 56% of the available
data. In my expert opinion, while this sample likely underrepresents the total number of
features listed above, it is sufficiently large to characterize the data and to reasonably reflect
the geological conditions in the licensed area. In contrast, the NRC review of 34 boreholes
2
2
-------
OST-029
constitutes less than 1% of the available data, grossly misrepresents the sample, and is not
scientifically valid or useful in arty meaningful way.
Open, uncased holes, including red rilled open holes
(Exhibit SNT25)
Casing of boreholes prevents the unwanted migration, transfer, and cross-contamination of
water within a borehole. Uncased holes allow unrestricted communication between water-
bearing strata at the site. Each uncased hole is a breach of the confining layers assumed to
restrict the movement of mining fluids and contaminants. Redrilling of previously cased
holes destroys the pre-existing casing and returns the borehole to the open, uncased
condition. In my expert opinion, while it is possible that confinement may yet exist in
undrilled areas, there is no reasonable expectation that confinement remains in drilled areas.
Artesian water
(Exhibits TRT44, ELT4)
Artesian water is water that flows under pressure exerted by connected waters at higher
elevations. The presence of artesian water in the licensed area clearly demonstrates such
connections, and that there is communication of water between the aquifers onsite and
offsite. Artesian flow allows the rapid transfer of water along the subsurface conduits
through which it flows, and greatlv increases the likelihood of large amounts of highly
contaminated subsurface water reaching the surface and contaminating it. In my expert
opinion, artesian flow demonstrates a lack of containment at the site and poses a significant
risk of unexpected, serious contamination of the Cheyenne River and its tributaries.
Plugged holes
Typically, boreholes are plugged with concrete. Plugs made of wood rot and disappear.
Plugs made of ferrous metals, including steel, rust and disappear. It is my expert opinion
that, for purposes of determining aquifer isolation, boreholes plugged in such a way should
be considered open, uncased boreholes.
Faults and sinkholes
(Exhibits DS178 backside, DS392, IHK2, IHM32, IHM62, TRR17, TRT16, FBM95)
During hearings before the AS LB in August of 2014, Powertech repeatedly asserted that
faults and sinkholes were not present in the license area, and that the license was somehow
unique in that regard. In my previous testimony, I offered the expert opinion that faults were
almost certainly present, and the license area was most likely crossed by numerous faults.
The observations I document herein demonstrate that my previous expert testimony was
correct, and there are numerous faults present in the licensed area. Likewise, the drillers'
notes document a sinkhole along a drilled transect associated with two closely spaced faults
also intersecting the drilled transect. Sinkholes typically form along faults, as the fault
allows the initial penetration of acidic surface waters, which then dissolve a conduit through
the rock which eventually forma a cave that subsequently collapses to for the sinkhole.
3
3
-------
OST-029
Suppression and redaction of data
(Exhibit TRJ111)
Notations in the drillers' notes to withhold data imply that there was an attempt to deceive
somebody about the character of particular boreholes. The possible motivation for
withholding the data was not clear from our limited review in these instances. More
troubling is the deliberate masking (redaction) of borehole log data, This information may
not be recoverable without additional drilling adjacent to the original borehole, and is clear
evidence that information was withheld for some reason. As in the previously mentioned
withholding of data, what this is and why it was withheld cannot be determined. A
competent and complete scientific review upon which a determination could be based that
containment of mining solution can be achieved at the Dewey-Burdock property would
account for this missing data.
Water in boreholes
The presence of water at various levels in the dri II holes suggests that there are multiple
aquifers present at the site, and in the case of uncased holes, open communication and
unrestricted flow between water-bearing strata at the site.
Poor, muddy, and destroyed samples
Problems with samples can bias rock descriptions and create circumstances in which the
confining units would be misidentitkd. leading to miscorrelations of strata and confining
layers considered present when in fact they are not. In order to determine if miscorrelation or
false identifications have occurred would require detailed redescription of the available data,
in my expert opinion, conclusions based on such samples, such as the presence or absence of
a confining layer, should remain tentative at best.
Moved or missing data
The amount of moved or missing data and its significance is difficult to ascertain from our
brief review. It may have been extracted from the set it is part of and relocated to another
box, withheld, or destroyed. Only a thorough review and inventory can determine the
disposition of the missing data. A review of this data is necessary to form concrete
conclusions as to the confining properties of the geological strata.
5. In conclusion, the numerous records of open holes, artesian water, faults, and sinkholes. My
prior testimony and opinions regarding Contentions 2 and 3 are supported by the
observations recounted here.
6. It is my further expert opinion that N RC-direeled ' spot check" of 34 borehole logs from
somewhere between 1750 and 6000 available borehole logs does not provide a scientifically
recognized analysts that can support any hydrogeological conclusion about the project area.
In my professional experience, there are numerous methodologies for analyzing the raw data
contained in borehole logs. There are also numerous methodologies for presenting the results
of the analysis of the raw data. Modern methods typically result in GIS/three-dimensional
visualization and modeling of systems or similar computer modelling based on the raw data
4
4
-------
O ST-029
in borehole logs. A copy of the website is attached to confirm the widespread and accepted
use of these methodologies within the profession,
7. A "spot check" of borehole logs is not proper where analysis has not been carried out and
recorded by GlS/three-dimensional visualization and modeling or similar technique. The
NRC Staff testimony indicates that Powertech has not conducted the necessary mapping of
available data. In such a circumstance, NRC Staff"s conclusions are not reliable where NRC
Staff accepts assertions of scientific fact made by Powertech that are not supported by
accepted methodologies used to review data in borehole logs.
8. The NRC Staff testimony makes no mention of the information contained in the drillers"
notes. Drillers' notes are an important source of interpretive information, often revealing
information not disclosed by sliding logs, for example, drillers' notes can reveal the location
of caves, artesian water, and the intermittent absence of confining layers. Although my
review is not complete, the drillers' notes I have reviewed do contain this type of
information.
9. The NRC "spot check" of 34 data points does not provide a statistically reliable testimony or
basis for any conclusions regarding confinement or hydrology, I teach various math and
statistics courses at Oglala l.akota College. Multivariate statistics is one of the formal
research tools required for my PhD in Geology from the University of Nebraska-Lincoln. I
am charged with review of research students at 01 C who frequently apply statistical
methods in their capstone research sequence required for their BS in Natural Science. NRC
Staff s "random" analysis lacks the basic safeguards applicable to those who would rely on
statistical methods.
10. The minimum number of data points for a statistically valid and meaningful sample is
generally 10%. In the Powertech instance the minimum acceptable sample size would be a
randomly selected sample of at least 175 borehole logs. Based on the recent disclosure of
over 4,000 previously withheld borehole logs, the appropriate sample would be 10% of the
entire set, or about 575+ borehole logs checked. NRC Staff presents no basis for its so-called
"random" selection. Without such information, professionals in my field cannot accept such
assertions where it is possible that the limited data set resulted in poor methodology thai is
the hallmark of modern junk science. Having examined only .37 data points out of thousands
available, NRC would have failed my Math 123 Introduction to Statistics class. None of my
student researchers would be allowed to publish or present their research findings had they
made such a fundamental error.
11. In m> experience and training, NRC Staffs methodology is fundamentally flawed and the
testimony based on the NRC Staffs review cannot be relied upon for any legitimate
scientific purpose.
5
5
-------
OST-029
12. Although I relied on student assistants as appropriate, the testimony and opinion provided
herein are based on my direct professional review and personal knowledge, Any errors or
misinterpretations of data herein are exclusively my own.
/ declare under penalty ofperjury that the foregoing is true and correct of my own knowledge.
Executed in accord with 10 CFR 2.304(d).
Executed in Chadron, Nebraska on November 21, 2014
8
e
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Dewey-Burdock Injection Well Permits
U.S. EPA Region 8
Dewey-Burdock-class-ll! and class-V injection-well-
draft-area-permits
All of the aquifers in this proposal are presently being used for potable water by local residents,
thus no exemption to the safe drinking water act of 1974 should be allowed. Both domestic and
agriculture wells are in use. The NRC has prohibited the in-situ mining operation in this area
until the 7600 plus abandoned bore holes are properly sealed. Geologically this is part of the
Black hills uplift area, which is still rising, causing the rock to be highly fractured and constantly
changing. Both of these conditions allow flow between all area Aquifers This will make
containment of mining and waste fluids impractical or improbable. Aquifer flow data as
presented is inconsistent. In the mining application a flow rate of feet per year is cited, yet in the
next paragraph a pump test showed a drop in a test well 1500 feet away in less than 5 minutes,
pressurized injection would certainly move faster than pump suction head values. USGS
Aquifer data shows tritium levels which would infer high flow rates from the known recharge
sources. This was assumed to be caused by an unknown recharge source. TVA driller notes
(Initially suppressed by Powertech) show that at least one bore hole went into an underground
cave. This could be due to the Jewel Cave and/or Wind Cave structures extending under this
area. USGS Aquifer data also concludes that flow rates through such structures is similar to
surface flows in the area. This could easily explain the deviation between well data and tritium
data without the need to identify an inferred new recharge source. I am concerned that this
project has a high probability for rendering my water unusable forever in the next few years. I do
not understand how radioactive waste is acceptable for injection into an actively used Aquifer
which sits above another Aquifer which is also actively used. Present Ion exchange technology
will not remove organified heavy metals, including uranium. Disposal of this waste fluid should
require permitting for a class 1 well and continuous independent monitoring of the waste. Since
no mining operations are occurring, no need is shown for disposal wells at this time. This area is
also seismically active, with known faults in close proximity. Given the known occurrences of
induced seismicity from injection well operations, containment of hazardous materials cannot be
guaranteed. Will the agency granting these exceptions be responsible for mitigating any
damages caused by this permit? Will a bond be required sufficient to provide water to all
affected residents and to cover any damages like those seen in Oklahoma. Who will be
responsible for the cost of testing present domestic wells, to obtain a true water quality
baseline? I understand the concept of putting a few rural residents at risk for the perceived
benefit of a larger population base. However you must accept that agricultural products grown
on soil you allowed to be contaminated, with water you allowed to be polluted will end up in your
grocery market shelves. It's called karma.
10 May 2017
-------
Hydrogeologic Framework for the
Madison and Minnelusa Aquifers
in the Black Hills Area
by
A thesis submitted to the Graduate Division
in partial fulfillment of the requirements for the degree of
MASTER OF SCIENCE IN GEOLOGICAL ENGINEERING
SOUTH DAKOTA SCHOOL OF MIN ES AND TECHNOLOGY
RAPID CITY, SOUTH DAKOTA
2013
Prepared by:
|, Degree Candidate
Approved by:
|, Major Professor
, Graduate Division Representative
Committee Member
i Committee Member
Head of Department of Geology and Geological Engineering
(» Dean of Graduate Education
-------
i
Abstract
More than 50 percent of the public drinking water systems and more than 90
percent of the population in Sooth Dakota rely solely on groundwater. This dependence
on groundwater raises important questions regarding the Madison and Minnelusa aquifers
in and near the Black Hills of South Dakota, including groundwater availability, the
effects of water use or drought, mixing of regional flow and local recharge, and the
effects of capture zones of springs and wells on the groundwater-flow system. These
questions are best addressed with a three-dimensional numerical groundwater-flow model
that includes the entire Black Hills area. In preparation for such a model, a three-
dimensional hydrogeologic framework was constructed for the Black Hills and
surrounding area. The study area includes approximately 60,000 square miles, extending
approximately 150 miles from the center of the Black Hills in all directions. Structural-
contour maps, potentiometric maps, and summaries of aquifer properties presented in this
report will enhance groundwater modeling of the Madison and Minnelusa aquifers on a
regional scale and allow for more realistic modeling of boundary conditions on a local,
site-specific scale.
Structural-contour maps and well logs quantifying the top and bottom altitudes of
the Madison and Minnelusa aquifers were aggregated from numerous previous
investigations to construct continuous surfaces defining the hydrogeologic framework.
The primary challenge in this aggregation was that structural-contour maps from different
sources frequently were inconsistent for overlapping areas, usually as a result of varying
resolution in spatial data. For these inconsistencies, a systematic workflow was
developed to determine which source was most accurate or reliable and would be used in
the final aggregation.
Potentiometric maps delineating the hydraulic head of the Madison and
Minnelusa aquifers are a result of aggregating numerous previous investigations using a
method similar to the construction of the structural-contour maps, with modifications
based on additional groundwater-level measurements. The data were combined to
construct continuous surfaces defining the regional potentiometric surface for the
Madison and Minnelusa aquifers. The Minnelusa aquifer potentiometric map is largely
similar to recent publications. The Madison aquifer potentiometric map enhances
understanding of a trough, or % alley-shaped feature, in the potentiometric surface
extending from Rapid City through Philip and eastward. This trough was previously
identified by Downey in U.S. Geological Survey Professional Paper 1402-E but not
shown in many other recent publications.
Aquifer properties, including hydraulic conductivity, transmissivity, and storage
coefficient, also were summarized from 40 wells for which estimates were available from
various types of aquifer tests. Hydraulic ranged from 2x 103 ft/day to 113.62 ft/day for
the Madison aquifer and from 0.36 tit/day to 24.43 ft/day for the Minnelusa aquifer.
Storage coefficient values derived from pumping tests ranged from 1x10 7 to 2x10 3 for
the Madison aquifer and from 7xl0"5 to 2xl()"J for the Minnelusa aquifer.
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«S» «dW Science Center: Missouri River bank erosfm
5/8/17, 0:51 AM
South Dakota Water Science Center
Alt! Wis site
only s„rt
Real-tome data {p|
~ Strearnflow ( |
» Ground water f 1
~ water quality { )
~ Precipitation (• )
i 3
~ Ground water { )
~ Water Quality {a)
* Annual Oat# Reports:
text ft) | mas ri
water Watch (a)
* Floods/High flows f! )
National Weather Service
Siawtlrtiort # Crot«r>'jwsu«> K %-ha Mintick'vss AquUc s
Area
Cooperator. National Futrit mmnm, wmcK HiKa MOoui Forest, CJW mt Uniliff City, Wei* Dakota Watar
Dcvilofiintnt District
Exacutiva Summary
The Madison and mmmium aquifers are critically important water resources that we* a primary tocus of the Slack Mills. Hvafoioov
.SlUiilx of the 1990s, fbrnt aquifer* have a toga influence on wrftaHMHr sfslams and provide the most important source of
groundwater tor municipal, domestic, agricultural, and industrial lis* lr» the aim. Rapidly incresstoi9 demand from these aquifers may
ansae* groundwater avattatMKy and surface-water resources.
Our aim IS t» construct a groundwater flow ifcrs for It* Black Wis and surrounding area to
help address hydrologic questions on I, including the National Parts
Strwet and m Slack »«»s National forest, htm sought answers to questions concerning groundwater-the primary water supply far
»»$ area. These questions are summarized ov bmm ouesoons » drmm scooa: ft) What it the influence of trie regional aqutfer on tol
groundwater flow? (2) What Is tie aquifer suttalnaMity indWta ight? C3J Mo* might future data
collection efforts be planned most effectively? Tl or impossible, to answer objectively without rigorous
quantification of numerous iocal and regional hydrologic ;v. groundwater. A three-dimensional groundwater now model for
the Black Hills area woukJ provide these estimates Better than any ofcr known method and provide a toot that will help define
sustainable groundwater use for the Black Mills area. We U.S. Gt»te§te»J Survey (US6S) previously ha* developed stte-spectfic models
of it* Madison and Mtonetosa atjtjifefs tor ma Rapid City and Speartlsh areas. The need tor updated models tn these <«n» otter areas Is
exweted to continue »n the tano-tern future.
Developing • regional groundwater flow modal that includes the entire Mack Hilts a«w will haw several benefits over • continuation of
site-specific modeling efforts"
1. Oevetopinq # single teijionoi moiJel wcsitlil t* mora cast, affectiv* t»w« imMpkt swaiter mentis,
2. SlmuHfiftn of sit«-$pi€lf»€, hw C«-S.« R«*d City) is more accurate whtn p!»c«l wtthln • regionsi flow modal.
3. Artesian sonnos 8ft *
*!U - ' ¦¦ ¦¦' ¦ " ' <¦ h ¦«; ' ¦ ¦¦¦' ' " "¦¦¦ ¦¦¦ - ' ¦¦¦¦' - ¦¦ ' -¦ ' >¦¦ ¦ '«¦ ¦¦"¦ * ¦¦¦• ¦ ¦¦ -¦¦¦¦
recisnai rr-O-Jei
4. The modal §«ti tan »* for hi«h-resoliitton sinmimms In any araa of spaeM Wteraat or to answer wec«flc hfilriitealc
questions (e.g., the effects of pumping In a smalt area).
5. .As additional fount* quasttons mm, oilier •»na««» can 6* eost-effect.i»elf awakMad tha naad fcr naw s»l»-
*. i.
«J«fl mamttf, tfie s««ss of ilevtiopirif • maanlngM mil useful modal ft* tl* entire Mack Hilis »r*a wot*} have 6«an wnadonaWa,
Since the »»pl«llcin of a mmiOt of mm 4am ha*# bean ci»ilect;e«lt antf IWs eomMnad wi» our
i!T»pro»«»il ooncaptuai uiiclenSantfirig ef srowwlwalisf flow In itm mm and riwitS-y |tcl»ws and hydrotog»c quastlona hut »tm will (**e • ewnertc undcrtyMg
«ructure for adaptation to future objectives and model refinement, TMs model is eiwislon<-;! »!i a ¦ana-term too! ttiiit •«! be available
far numerous Mm studies and «• Sfmbiollcailf benefit rimjftlpie Manwted
¦
Ofajactlvas
Study ofejtcttves are »fil bitter understand the Mhianca of ragionM ^wmdwiter flow en !oc«i groundwater; P) assess the effects ef
r+.* •.»» a>%. li.lt St% » m.*-***. /H W ,, ,i-l— If. . ..fiK ..i. n- m.*— »I .n.li f — - *» ^ -
piimp9 ana orouQnt on Qrounowstcr 8V3H9DiiftY« dfKi (J) Rfii'p Qui06 furtnc^ odtd CQiifiCtion cttO'rtS-
Eldridge, W.6., Md Ung, AJ-, 20 IS, A greundmter-ltaw mod« at tha «a
-------
SD Water Science Center: Missouri River bank erosion
5/8/17, 9:51 AhP
This cave intercepts water from Spring Creek, which
recharges the Madison aquifer.
Three-dimensional view of the top of the Minnelusa aquifer (upper surface),
top of the Madison aquifer (middle surface), and bottom of the Madison
aquifer (lower surface) In the study area.
https://sd.water.usgs.gov/proiects/BHFIowModel/BHFIowModel.html
Page 2 of 3
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¦SO Water Science Center: Missouri River bank erosion
5/8/17, 9:51 AM
Minnelusa aquifer o 10 20 miles
Madison aquifer 0 M
pre-Devonian hydrogeoiogic unit
Map chowing study area
Some of the documents are presented in Portable Document Format (PDF); the latest version of Adobe Acrobat Reader or similar
software is required to view it Download the latret vprann nf Arrohat Rpader. free of charge.
USGS Home Water Climate Change Core Science Ecosystems Energy and Minerals Env. Health Hazards
U.S. Dpnartropnt nf the Interior | U.S. f^olomrjl Survey
URL: http://sd.water.usgs.gov/projects/BHFlowModel/BHFlowModel.html
Page Contact Information: Webmaster
Page Last Modified: Thursday, 14-Apr-2016 09:48:58 EOT
https://sd.water.usgs.gov/projects/BHFIowModel/BHFIowModel-html
Page 3 of 3
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'ntjiiCB'J t'.v thinks*. 1218|1«» 0 68 AM
US, Geological Survey - Earthquake Hazards Program
Induced Earthquakes
USGS Publications
2016
Petersen, MM, C.S. Mueller, klR Moschetti, S.M. Hoover, A.L. IJems,, W.L Ellsworth, AJ. Michael, J.L Rubinstein,
52 p., )fr20161035.
2015
Eilsw
He
Hough, S,£» and M. Page (20251A Century of induced Earthquakes in Oklahoma?, Bulletin of the Seismological
hrtpg://#arthqu«k».u»g*.O0V/r#»»erch/in<)uciKl/Fef«nerK»s.php
Pt0« 1 of 5
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1218118, 9 58 AM
i»
201A
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-dv,e-M Li, =• 121811®, ®:88 AM
Sumy, D.F. et at {2014), . iLiiMKSmmmbJiXi.: C/ieitoiiM^
» > J, Geophys. Res., 119, doi:10.1002/2013JB010612.
2013
Ellsworth, W.L (2013), . > > . Science, 341, doi:10.1126/science.l22S942.
Keranen, KM, et aL (2013), j, b . ¦ / '4; Links between wastes 4ter
injection unci the 2011 Mw 5.7 earthquake sequence. Geology, dot: 10.1230/634045,1,
Uenos, A.L and A J, Michael (2013), i
^ Bulletin of the Seismotogical Society of America, v. 2013, p 28S0-2861, doi:
hnpt://Mrthqt»k*.us8S.govfi,MMMrch/lmiuc«d/r*f»f«ncM.pftp P«#f 3 at S
-------
tntfucwi E*rthqu«kes
J0,1735/0120130017,
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McGarr, J, etai (2002), 40 Case histories.Qfi
Meremonte, M. etal. (20021 investigation of
1999
1992
Nicholson, C. and R.L Wesson (2992), ]j]gg§
Geophysics,, 13901561-578.
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Nict ' ' >sson (1990), Eartht
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Hsei d J. Bredehoeft (1981), 4 reserve
Geophys. Res,, 86(B2), 903-920,
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Raleigh, CM eiat (2976). An experiment in,
1968
http*://»»fthqu»ka.usg*-floWre*earch/in(iuc«
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Testimony of geologist stratigrapher, to NRC and ASUB 2014,
shows that there are extensive fractures, fissures, sinkholes and breccia pipes In the
area that dramatically increase permeability within confinement layers. These
geological features go unrecognized by Powertech.
Powertech was "cherrypicking" data from the first TVA exploration in the 1950's and
60's, carefully selecting only the data that supported their project. They were not
even in possession of the latest exploration TVA data from the 1970's and 80's when
they submitted their permit requests. Powertech obtained those documents in May
of 2014. In the discovery of that data in the NRC/ASLB hearing of 2014, Dr LaGarry
found that the drillers logs, notes and hydrological pump tests "did not provide a
scientifically recognized analysis that can support any hydrogeologicat conclusion
about the project area". He also concluded that "The NRC 'spot check' of 37 random
data points does not provide a statistically reliable testimony or basis for any
conclusions regarding confinement or hydrology."
BHI also added "NRC Staff presents no basis for its so-called "random"
selection. Without such information, professionals in my field cannot accept such
assertions where it is possible that the limited data set resulted in poor methodology
that is the hallmark of modern junk science. Having examined only 37 data points
out of thousands available, NRC would have failed my Math 123 Introduction to
Statistics class. None of my student researchers would be allowed to publish or
present their research findings had they made such a fundamental error."
bydrologist, testimony before NRC/ASLB thoroughly established
that, "Dewey-Burdock uranium ore zones are not hydraulically - isolated from other
geologic units, other aquifers, or zones outside the project area." He provides many
examples of what he refers to as, "NRC Staff disregarding the conclusions of
numerous hydrogeologic experts (both Powertech-funded and independent).
4. The Proximity of Igloo, Black Hills Army Depot/Black Hills Ordinance Depot
- The Black Hills Ordnance Depot was officially designated in February 1942 in Fall
River County. The site consisted of 21,095.85 acres, and was utilized for long-term
storage of ammunition. In August 1962, the site was renamed the Black Hills Army
Depot. The facility was developed with industrial storage, administrative buildings,
housing, and related support facilities and utilities. The Depot was used for the
receipt, storage, maintenance, inspection, testing, restoration, issuance and shipping
of ammunition, propellants, and chemical toxics, the unpacking and functional
packing of small arms ammunition, and the demilitarization of unsafe, obsolete and
faijti
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section 3.4,2.3,2
For the sandstone of the Fall River Formation, the laboratory core data indicate a horizontal
hydraulic conductivity of 6,1 ft/day (2.2 x 10 ? cm/s, Table 3.4-3). Based on pump test results, the
average horizontal conductivity is approximately 1.8 ft/day (6.4 x 10-4 cm/s). Within the lower
Fall River Formation, the test results indicate transmissive, rapid response (2 to 3 minutes)
between pumping and observation wells up to 467 feet apart with nearly 10 feet of drawdown.
Response was nearly 9 feet of drawdown at a 1,400-foot distance. This indicates that the aquifer
was stressed to produce good quality analytical results.
How can you have an average conductivity of 1.8 ft/day and see a 9 foot drawdown at 1/4 mile in
2-3 minutes?
section 3.8.3
Pass Creek Update
In 2007, Pass Creek had 0.503 acre ofPEM wetlands surveyed along its stretch; however due to
the recent boundary change there are now only 0.05 acre of wetlands present on Pass Creek. The
boundary change moved the boundary east of W22» and now excludes the three wetland points of
W20, W21, and W22. The wetlands present on Pass Creek are primarily due to an old open
flowing well on the other side of the road outside the permit boundary.
In 2007, Pass Creek was surveyed from the southern permit boundary to the old mine pit and no
wetlands were identified except near the spring. No surveys were conducted on Pass Creek in
2008 as the map indicated that the area is likely dry.
Has any monitoring program been instituted to insure that proposed activities will not adversely
impact this wetland and it's resident wildlife ?
section 5.3.3.1.2.2
1) The Unkpape Sandstone shows substantially higher potentiometric head than the Fall River
and Chilson throughout the permit area. During ISR operations, the potentiometric head will
be reduced (creating a cone of depression) in the Chilson and Fall River due to a net
withdrawal (production flow greater than injection flow) in order to maintain well field bleed.
Flow into the Unkpapa from production zones in the Fall River and Chilson operating at a
substantially lower potentiometric head would be impossible.
The head will only be reduced at the recovery well site, substantially higher potentiometric
pressures will exist at the injection well sites. Impossible is an inaccurate description of events in
an operating system subject to failures.
2) The Morrison Formation is prevalent across the entire permit area, with a thickness ranging
from 60 to 140 feet, and will act as an aquitard to prevent flow between the Unkpapa and the
Fall River and Chilson. This was demonstrated by the pumping tests conducted by Powertech
(USA), where no response occurred in the Unkpapa during pumping of either the Fall River or
Chilson,
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C«n W» «top Th« Surgs Of Man-M«J# E«rthqu»k«»? | Popular Sc!«nc«
12/24/76,11:01 AM
POPULAR SCIENCE
Can We Stop The Surge Of
Man-Made Earthquakes?
There's a whole lot more shaking going on In the Midwest lately—and
humans are causing it
Bv BARRY YEOMAN Posted DECEMBER 22,2015
Mark Crismon and 1 were sitting outside his Oklahoma house,
looking at the day lilies that lined his pond, when our conversation
was interrupted by a distant boom. "Did you feel that?" Crismon
asked. "Just be quiet. Sit still." He's a lanky 76-year-old, retired from
an electronics career, with gray hair combed straight back from his
ruddy face. The booms continued, once or twice per minute; I felt
them under my skin, "That's a small earthquake," he said, seconds
before the sound recurred, "There it was again. Well go and look on
the seismometer—I'll show you what it looks like."
We walked into his garage. It was July and approaching 100 degrees
in the countryside north of Stillwater. The building was filled with
freezers where Crismon and his wife store the food they grow,
catch, shoot, and smoke. Deer and coyote tails covered corrugated-
tin walls. On a desk in the corner, beside a hand-labeled bottle of
peach brandy, sat a Dell laptop connected by a cable to a buried
Mtp:/A*ww. popsci.com/caiv w«-$top-surg*"Of-'man-m*d»-earthquakes
Pate 1 of 14
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Can W« Stop Th» Surg# Of Man-Mad# Etrth<»u«kM? | Popular Sci«ne*
12/24/18, f»:Q1 AM
seismometer, Oklahoma State University scientists had given
Crismon the seismometer in 2014, as part of a project to monitor
the state's current rash of earthquakes.
He took a drag from his cigarette, then turned his attention to three
parallel bars scrolling across the screen: blue on the bottom, red in
the middle, green on top. They were mostly straight but had become
jagged for the several minutes we had felt the tremors, "How'd you
like to put up with that day and night?" he asked,
Crismon sits at this desk, on and off, for 14 hours a day. He arrives at
six in the morning and takes pictures of the spikes with a digital
camera to document what he calls a growing menace {even though
the data gets recorded regard less). There's plenty to photograph: ,
Oklahoma, which historically has had few earthquakes of
magnitude 3.0 or higher, started rumbling regularly in 2009, The
Oklahoma Geological Survey recorded 35 such quakes in 2012,109
in 2013, and 584 in 2014. (The prior annual average was fewer than
two.) By late October, the 2015 figure had already exceeded 700.
Scientists have figured out the reason; the oil-and-gas industry's
practice of injecting wastewater deep underground.
The granite basement that underlies the continent, a mile below
Oklahoma's wheat and alfalfa fields, is full of faults. Usually, natural
stresses clamp the rocks and keep them from moving—like "a vise
that's slammed on the east and west side, and someone's turning
the screw," says Todd Halihan, a hydrogeophysicist at Oklahoma
State University, Inject fluid deep enough, he says, and it travels into
the fractures in the granite, in effect lubricating the rock and
causing faults to slip.
http://www.popsci.com/ca n-wa-stop-surgt-of-man-madc-Mi-thquakM
Pag# 2 of 14
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C»n W«-Stop The Surg* Of E«rthtju»k»*? | Popular Science
12/24/16,11:01 AM
Halihan compares this to tabletop air hockey, "When it's off, the
puck doesn't move particularly well," he says, "Turn on the air, and
it's like you're injecting. That puck moves real well."
Sometimes these quakes arrive as jolts like those Crismon and I felt
outside his house. Sometimes they topple buildings and claim lives.
It's not only in Oklahoma where we're giving the proverbial puck
more room to slide. Our species, unintentionally, keeps finding new
ways to unleash earthquakes. We have rattled the ground by
impounding reservoirs, excavating mines, testing nuclear weapons,
tapping geothermal power, and pushing carbon dioxide
underground to slow global warming.
Sometimes these quakes arrive as jolts like those Crismon and I felt
outside his house. Sometimes they topple buildings and claim lives.
Whether they hit the Midwest, California, Switzerland, India, or
China, some of those who feel the shocks are asking: Can we control
the tremors, or are damaging quakes an inevitable feature of the
future?
*#*
We first recognized the problem of man-made earthquakes around
the turn of the 20th century, as they began hitting the regions
around South Africa's gold mines and Europe's coal mines. The
release of gravitational energy, when the rock above the mines
sagged, triggered them.
It took until the 1930s for Americans to notice man-made quakes
beneath our own soil. When engineers created Lake Mead behind
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the Hoover Dam, the sudden addition of 12 billion tons of water
apparently set off hundreds of small tremors along the Arizona-
Nevada border.
"This was an 'aha moment,' an important benchmark in the science"
says BiH Ellsworth, an emeritus seismologist with the U.S.
Geological Survey and geophysics professor at Stanford University.
Since then, reservoirs have been linked to devastating quakes
around the world: definitively to a magnitude-6,3 quake that killed
200 people in 1967 near India's Koyna Dam, and more speculatively
to the 2008 Sichuan quake, a magnitude-7.9 colossus that flattened
schools and hospitals in China, and left more than 80,000 people
dead or missing. The Sichuan quake was triggered less than 6 miles
from the Zipingpu Dam reservoir, says natural-hazards researcher
Christian Klose, who has linked water levels there to tremor
frequency.
The most ominous precursor to Oklahoma came in the 1960s, when
a series of earthquakes walloped the normally quiet Denver area.
During two particularly lively days in 1962, the shocks broke
windows, cracked plaster, and left electrical outlets hanging by
wires. "Children cried with fright," read a federal field report from
Dupont, a town just north of the city.
Scientists traced this seismic uptick to the Rocky Mountain Arsenal,
an Army facility that manufactured chemical weapons and rocket
fuel. Weeks before the trembling began, the arsenal had started
injecting wastewater 2 miles down into the crystalline basement
rock. After the injections stopped, in 1966, it took a year for the
shaking to cease: A magnitude-5.3 quake knocked bricks from
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chimneys in 1967 and caused more than $1 million in damage.
A geologist named David Evans found an association between the
amount of fluid injected at the arsenal and the number of
earthquakes, and suggested cause and effect. (To demonstrate how
lubricated rocks slip, Evans reportedly would perform the "Coors
experiment": He perforated the bottom of a beer can, and then
showed how the seeping liquid eased its slide' down an incline.) The
Army disputed Evans' hypothesis, but he was vindicated by USGS
researchers, who triggered seismicity soon after by methodically
injecting fluid into Colorado's Rangely oil field.
Since then, scientists have grown more sophisticated about
documenting changes in earthquake activity. About 200 miles south
of Rangely, in Colorado's Paradox Valley, the US. Bureau of
Reclamation has been injecting briny groundwater into a deep
limestone formation in order to keep it from contaminating a river.
"Somebody had the foresight to say, 'Let's see what kind of
seismicity's out there before we start injecting,'" says bureau
geophysicist Lisa Block. Six years of baseline data showed almost no
natural activity. By contrast, the agency has recorded 6,200 quakes,
most of them small, since underground disposal began in 1991.
By the time Oklahoma starting ramping up its own wastewater
injection—now more than a billion barrels a year—the notion that
humans can induce earthquakes by putting fluid underground was
already familiar. Still, Sooner State residents were caught off-guard
when that geologic principle hit home.
~~~
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Th e Surge in Shaking
A decade ago, this part of North America experienced just 14
tremors a year. In 2014,650 quakes hit the area, most of them
clustered around wastewater injection wells,
***
Todd Halihan was standing in the hallway of his Stillwater home
one night in November 2011 when he noticed glasses starting to
rattle. As the building shook, the hydrogeophysicist flashed on his
sleeping 6-year-old. "Should I get my kid out of bed and run out of
the house?" he recalls thinking. "Should I get him under a table?"
Halihan was feeling the effects of a magnitude-5.7 quake-
Oklahoma's largest, it turns out. Its center was near Prague (rhymes
with "vague"), almost 50 miles away, where it buckled a highway and
destroyed 14 homes. In one living room, rock from a fireplace and
chimney struck a woman as she watched TV. The earthquake also
toppled a historic turret at St Gregory's University in nearby
Shawnee. A team from the University of Oklahoma, Columbia
University, and USGS determined the source; a fault rupture that
began about 650 feet from active injection wells.
"That's when a lot more people started paying attention," says
Austin Holland, Oklahoma's state seismologist until this past
summer.
The idea that the oil-and-gas industry could be producing these
quakes was a touchy subject, both for companies and for the
administration of Gov, Mary Fallin. One study shows the industry
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has created one-fourth of Oklahoma's new jobs since 2010, Emails
obtained by the Energy Wire news service paint a picture of a
government that, in the words of Fallin chief of staff Denise
Northrup, tried to "make this go away." Shortly after the Prague
eartnquake, Fallin aides contacted Devon Energy, an oil-and-gas
producer, and obtained talking points to use with constituents.
Among them; "There is no current evidence that oil-and-gas
operations had anything to do with the recent large earthquakes in
Oklahoma." When Fallin addressed a National Governors
Association forum on shale-energy development in 2013, a
reference to underground injection wells was deleted from her
speech. "We had other issues we wanted to highlight," says Alex
Weintz, Fallin's communications director until this past November,
The problem doesn't stop at Oklahoma's borders; man-made
earthquakes have hit other midcontinent states too.
Weintz says Fallin's personal views were always more nuanced than
Devon Energy's talking points, even if those points were used by her
staff. Her own reticence to blame disposal wells, he says, reflected
the state of the research when she took office in 2011. "It was only
the beginning of a spike in seismic activity," he says. "Since then, the
science has evolved."
Even the Oklahoma Geological Survey, a university-affiliated state
agency, was slow to acknowledge the disposal-well connection. In a
2013 statement, it noted that the Prague earthquake appeared to
be the result of "natural causes." Holland, who worked for the
survey, says, "Oil-and-gas is a very important industry, and so,..
some of the public statements saw a lot of wordsmithing."
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As scientists dug into data, a consensus emerged that fluid injection
was indeed behind the spike in earthquake activity. Even Fall in has
come around. "We all know now there is a direct correlation
between the increase of earthquakes that we've seen in Oklahoma
and the disposal wells," she said at an August meeting of her
administration's Coordinating Council on Seismic Activity.
In fact, new research shows earthquakes now pose a risk to the oil-
and-gas industry itself. The largest crude-oil storage facility in the
world sits in Cushing, Oklahoma, right above a fault recently acti-
vated by injection. Continued injection could produce a magnitude-
5.7 earthquake, large enough to rupture oil tanks and pipelines.
The problem doesn't stop at Oklahoma's borders; man-made
earthquakes have hit other midcontinent states too.. On New Year's
Eve 2011, a magnitude-4.0 tremor in Youngstown, Ohio, shook
buildings and led to the shutdown of a disposal well that was
deemed the likely culprit. Waste injection has also been linked to
quakes in Arkansas, Colorado, Kansas, New Mexico, and Texas.
"Oii-and-gas Is a very Important industry, and so... some of the public statements saw a lot of
wordsmithlng.*
If the same quakes had happened overseas, they might have caused
far more damage. "The technologies that have been pioneered
primarily in the U.S.—to unlock gas from tight shale and to produce
oil from unconventional reservoirs—have the potential to be
applied around the world," says Ellsworth, the USGS seismologist
"Many countries will find it irresistible to produce their own
resources. Unfortunately, in many of these countries, the building
standards are not what they are in the United States, and the
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potential for severe damage and loss of life is really high."
**~
As we keep using the earth as a vault to stash our waste-and as a
tappable resource-we're creating a global-energy system that will
likely increase the risk of small and potentially large earthquakes.
Engineers will need to weigh every resource, looking at how much
power it provides, how green it is, and what type of seismic risk it
poses.
In some cases, the technologies we've engineered to ease our
impact on the environment have proved likely to shake the ground.
In a pilot project in Decatur, Illinois, carbon dioxide captured from
an ethanol plant is being injected, in liquidlike form, almost 7,000
feet down into a sandstone formation. The goal is to slow climate
change by keeping the greenhouse gas out of the atmosphere (a
tactic also advanced by proponents of "clean coal").
So far, the injections have caused only the smallest of tremors, too
faint to be felt. But Stanford University geophysicist Mark Zoback
and hydrogeologist Steven Gorelick have argued that for
underground carbon storage to benefit the climate, it must happen
at a "massive scale"—one that will likely trigger more seismicity, and
therefore potentially defeat its own purpose by discharging the
carbon into the atmosphere. "Even small to moderate earthquakes
threaten the seal integrity of a C02 repository," they wrote in a
2012 journal article. For that reason, they concluded, carbon
injection will be "an extremely expensive and risky strategy" to
reduce greenhouse gases.
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Ole Kaven—a USGS geophysicist involved in the Illinois project-
says that if researchers can map faults, fractures, and fluid
pathways using sophisticated instruments, they can reduce the
hazard, though not eliminate it entirely, "If one factors in the cost of
greenhouse-gas emissions, and what effect €02 sequestration can
have on reducing some of the long-term effects, this conversation
changes," he says, "Some of these risks might be tolerated."
That's a critical point: A technology might produce earthquakes, but
what harm might come from not using it? Take geothermal
production, a reliable and underused source of electricity that
causes little environmental damage, "If we could tap all the heat in
the earth, we wouldn't need anything else," says Ernest Majer, a
geophysicist affiliated with both the Lawrence Berkeley National
Laboratory and Sandia National Laboratories,
That was no comfort in Basel, Switzerland, where in December
2006 operators of the Deep Heat Mining project began injecting
cold water into the naturally hot granite below the city. The
following week, a magnitude-3.4 shock rattled windows and
cracked plaster. Injection was halted. A government study projected
a 15 percent chance of a man-made earthquake causing more than
$500 million in damage if production resumed. In 2009 the project
was scrapped entirely.
Geothermal production continues in rural areas—most notably at
the Geysers, north of California's Bay Area, where locals have
routinely endured minor quake damage. "Sometimes it feels like a
big truck just bumped into the house," says Jeff Gospe, who sits on a
seismic-monitoring advisory committee there. Neighbors have
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reported cracked windows and a retaining wall that crushed a van.
Majer believes that the hazard posed by geothermal fields is minor
compared with their potential to produce clean energy. (He says the
Geysers alone could power all of San Francisco.) "There's no such
thing as zero risk," Majer says. "Driving to the grocery store is a risk.
Everybody risks when they get out of bed in the morning." Compare
that, he says, with the cost of carbon emissions; "If you start looking
at the health impacts, the climate impacts—all the nasty things
coming out of the fossil-fuel economy—well, maybe we better do
something else. Induced seismicity associated with putting carbon
into the ground, associated with geothermal: Those are minor,
minor things compared with alt these other risks facing us."
«**
Assuming we're riot going to shut down energy production,
scientists now face a more complex question: whether it's possible
to minimize the hazard.
After the experiments in Colorado's Rangely oil field in the 1960s
and 70s, which showed that we could control induced seismicity by
varying the pressure of injected fluid, scientists were bursting with
hope. Not only might they reduce damage from man-made quakes,
the thinking went, but maybe they could control natural ones.
Rather than waiting for the next bridge-toppler to hit California,
USGS scientists suggested drilling wells along the San Andreas
Fault, injecting water, and releasing the accumulated stress in a
series of small, harmless quakes.
The idea never got traction. Not only would it take thousands of
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mini quakes to offset a major one, but it is also too risky. More than
a century has passed since San Francisco's deadly 1906 quake,
which means the city is sitting on highly stressed rock. Inject water
underground, says Oklahoma's Halihan, and "you might not release
100,000 small ones. You might release a big one." Even if the
experiment did work locally, he says, "you might set off the next
segment of the fault It's 3D and it's complicated: 'Hey, we didn't
cause an earthquake in San Francisco.* 'Well, you just knocked down
LA.' 'Sorry.'"
Today, nobody's talking about setting off microtremors in Oklahoma
in order to avoid the next Prague earthquake. But scientists are
talking about more-modest ways to manage seismicity.
"The toolbox is growing," says Austin Holland, who now works for
USGS in New Mexico. It includes avoiding known faults, scaling back
the volume and rate of fluid injected into the rock, injecting at a
shallower depth, improving monitoring, and preparing to abandon
wells altogether if seismicity can't be stopped, This past year, the
Oklahoma Corporation Commission—which regulates the industry
—ordered volume reductions for some wells, as wel I as "plug backs"
to limit how deep some wastewater is injected. The state's "traffic
light" system, instituted in 2013, allows regulators to scale back or
halt drilling in response to seismic activity.
Still, eight magnitude-3 and -4 quakes struck northern Oklahoma
during a 24-hour period as this story went to press. There's a lot we
haven't yet learned about what happens underground—and that
knowledge gap stymies us from managing the earthquakes we do
create.
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"Probably the greatest unknowns are the properties and processes
deep within the earth, things that are very difficult to measure
directly," Holland says. "How is pressure being communicated? Do
faults act as seals or as conduits? What are the actual stress states
deep within the earth? That's where science has to spend a
significant amount of effort and resources."
***
Back in Stillwater, Todd Halihan understands both sides. He wants
his students to find work in the energy industry when they
graduate. But he also doesn't want to have to dive for his son the
next time an earthquake shakes his house,
"We're going to make some decisions, and none of them are going to
be super-simple or super-pleasant," he says. Ideally, that means
talking levelheadedly about both the value of oil-and-gas
production and the threat of earthquakes—how to balance those
competing concerns and how much uncertainty we're willing to
tolerate.
It's not easy to talk, though, when the ground is rattling. Each side
retreats into a corner. Some industry and political leaders refuse to
acknowledge the emerging science. Some quake-zone residents,
feeling ignored and outgunned, pull out the only weapon they have:
their rhetoric. The conversations grow polarized rather than
solution-oriented.
It's not easy to talk when the ground is rattling. Each side retreats into a
comer.. .The conversations grow polarized.
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Technology, Halihan says, often carries harm. "The Titanic's a nice
example" he says. "We were developing big ships, and we sank
them. Developed airplanes; we crashed them." Addressing
unintended consequences doesn't necessarily mean scrapping
innovations. Nor does it mean pretending the consequences don't
exist.
With seismicity, as with addiction, the first step is admitting we have
a problem that's not fully within our control. "The government, as
well as these companies, should be upfront," says Leonardo Seeber,
an earthquake geologist at Columbia University's Lamont-Doherty
Earth Observatory. "You want to drive your car. It takes gasoline. To
produce that, you have to make wells. You have to pump in here and
pump out there. And when you are doing that," he says, "you are
changing the stress in the subsurface. Sometimes there could be
earthquakes that we can't predict. There could be consequences.
But we're all in it together."
This article was originally published in the Januarv/Februarv 2016 issue
of Popular Science, under the title "Earthquake Nation"
The Case for Human-Caused Earthquakes, in
Charts
Copyright © 2015 Popular Science. A Bonnier Corporation Comnanv
All rights reserved. Reproduction in whole or in part without permission
is prohibited.
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induced Ja;ti*qua«5
U.S. Geological Survey - Earthquake Hazards Program
Induced Earthquakes
f-vmiplt-1 omputatton of ground shrik'ng probability ftcrn induced scivmic ity. 1 hi^ map does not represent a final model as several
different options _ ».rui i tv> ',dzar^* eht> n*,qt i ,•*
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'Induced Earthquakes 12/8/16,10:17 AM
Seventeen areas of potentially induced seismicity considered in a preliminary estimate of seismic hazard from induced earthquakes.
Green dots represent earthquakes that occurred fall 2012 to fall 2013; red dots show earthquakes that occurred fall 2013 to fall 2014;
blue dots and blue lines represent earthquake activity prior to 2013 (areas identified but intentionally excluded from the 2014
national seismic hazard model). Red lines indicate areas where the polygons were expanded to incorporate recent (2013 and 2014)
earthquakes that fell outside of the blue polygons.
https://earthquake.usg$.gov/research/induced/hazards.php
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"Induefcd Earthquakes
12/8/16,10:17 AM
In previous editions of the NSHM, earthquakes that were attributed to human activity were not
included . The recent increase in induced earthquakes in the Central United States is so large that
induced earthquakes need to be considered in the national seismic hazard model.
1USGS
2016 On*Year Seismic Hazard Forecast for tha
Central and Eastern United States from Induced
and Natural Earthquakes
lyMnD HwHwMil—
omiH i* Juan Miwwiwf mk.mmiIiwmi
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With input from scientists, engineers, regulators, industry representatives, and the public the USGS is
developing methods to estimate the earthquake hazard from induced earthquakes. Preliminary
models display the intensity of potential ground shaking from induced earthquakes for a one-year
period based on the seismicity in the previous year. This method is a first step in accounting for the
rapid changes in seismicity that we are observing.
The USGS has released a preliminary report on methods to estimate the hazard from induced
earthquakes, Incorporating Induced Seismicity in the 2014 United States National Seismic Hazard
Model—Results of 2014 Workshop and Sensitivity Studies (OFR 2015-1070) and welcomes feedback as
work continues towards completion of a seismic hazard model that includes the hazard from induced
seismicity.
https://earthquake.usgs.gov/research/induced/hazards.phD
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Earthquake Hazard Associated
With Deep Well Injection—
A Report to the U.S. Environmental
Protection Agency
By CRAIG NICHOLSON and ROBERT L. WESSON
Prepared In cooperation with the
Environmental Protection Agency
Under certain circumstances, the increased pone pressure
resulting from fluid infection, whether lor waste disposal,
secondary recovery, geothermai energy, or solution mining,
can trigger earthquakes. This report discusses known cases
of injection-induced seiamictfy and how and why earthquakes
may be triggered, as well at conditions under which the
triggering is most likely to occur. Criteria are established
to assist in regulating well operations so as to minimize
the seismic hazard associated with deep wail fluid infection
U.S. GEOLOGICAL SURVEY BULLETIN 1951
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Simulation of groundwater flow in the Madison and
Minnelusa aquifers, Black Hills area
21 November 2012
US. Geological Survey, Rapid City, South Dakota
Principle investigator an# Project Chief: Andrew J, long, PhD
Executive summary
The Madison and Minnelusa aquifers are critically important water resources that were a primary focus
of the Black Hilfs Hydrology Study of the 1990s. These aquifers have a large influence on surface-water
systems and provide the most important source of groundwater for municipal, domestic, agricultural,
and industrial use in the area. Rapidly Increasing demand from these aquifers may affect groundwater
availability and surface-water resources.
This document describes a proposed study to construct a groundwater flow model of the Madison and
Minnelusa aquifers for the Black Hills and surrounding area to help address hydrologic questions on
local and regional scales. Several parties in the Black Hills area, including the National Park Service and
the Black Hills National Forest, have sought answers to questions concerning groundwater—the
primary water supply for this area. These questions are summarized by three questions of broad scope:
(1} What is the influence of regional groundwater flow on local groundwater flow? (2) What Is the
aquifer sensitivity in different areas to pumping and drought? {3f How might future data collection
efforts be planned most effectively? These questions are difficult, or Impossible, to answer objectively
without rigorous quantification of numerous local and regional hydrologic influences on groundwater.
A three-dimensional groundwater flow model for the Black Hills area would provide these estimates
better than any other known method. The U.S. Geological Survey (056$) previously has developed site-
specific models of the Madison and Minnelusa aquifers for the Rapid City and Spearfish areas. The
need for updated models in these and other areas is expected to continue in the future. For example,
the National Park Service recently has expressed a desire for a groundwater model of the southern
Black Hills.
Developing a regional groundwater flow model that includes the entire Black Hills area will have
several benefits over a continualton of site-specific modeling efforts:
1. Developing a single regional model would be morr cost effective than multiple smaller models.
2. Simulation of site-specific areas {e.g., Rapid City) is more accurate when placed within a
regional flow model.
3. Artesian springs are critical water sources that capture groundwater from regional areas and
thus are best simulated with a regional model.
4. The model grid can be modified for high-resolution simulations In any area of special interest or
to answer specific hydrologic questions {e.g., the effects of pumping in a small area).
1
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5. j%acWiti«aJ future questions arise other hydrology scenarios can be oost-effecttaly
evaluated without the need for new ate-spedftc models*
Until recently. the success of deveiooina a i " ' model for the entire Back Nils area
would have been questionable Fourteen yeas of data collection have occurred anoe the Back Wis
ttydrology 3udy resulting in a weaith of available data, and thisoombined with our improved
conceptual understanding of groundwater flow in the area and the recently developed modeling
caoabtli ties make this effort now f& Thei ves
aid h'/drotogc questions but also will ha«ac^wicurete1yingdruclurefof adaptation to future
objectives and model refinement. This model >senvisoned as a long-term tew! that wilt be aval Ate for
miffwousfuture atufiesand wlH ipnbioticalf benefit multiple interested parties, Gtyecttaeare to (1)
better understand the influence of regional groundwater flow on local groundwater (2) assess the
effects erf pumping and drought on groundwater availability; and (3) Wp guide further data collection
. «Hf Jt ,...
6froft&
If multiple interested parties contribute to this effort, the cost to any one party will be minimized, and
ail will benefit For 2011 aid 2012, the combined contributions from II* National Park Service and the
Back H!ls National fixest were $101,650, or 11%of the total estimated cost of $960,000 Contingent
on amiability of funding through its Cooperative Water Rogram, USGSwiH plan to contribute
matching funds for contnbutionsfrom local or state governmenls inaratioofat ie^aat 40 percent U83S
funds to 90 percent local/si ate funds The remaining funding will be spread over the next four years
(2013-2016) or moie depending on annual funding levels Several local agerraeshave expressed
potential interest in participation, including the atiesof Rjpa5 may affect groundwater availrfjilily and
surface-water resouroes, Amiability of groundwater varies with annual, decadal or longer-term
changes in dimate In response to climatic changes and posably groundwater withdrawal water
levels for the Madison aquifer have changed by more than 100 ft in aome pfacesin leas than a decade,
both inareatinQ and «**""Understtfidinci ®*owidtiistef flow is essential for and
managing gFoundvrater r^air« smulMiai of groundwater flow to the moat oornmon
methcxj for assessng the effects of multiple irrfluenoes on aquifer^ ir>dudtng groundwater uae, natural
2
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spring flow, variability in precipitation and streamflow, population growth, long- and tfwrt-ierm
dimatic changes, artel contaminant transport.
His proposal describes an apt h for construction and application of a numerical groundwater flow
model of the Madison and Minnelusa aquifers for the Hack Mils and surrounding area The
overarching approach is to develop a generalizec Back Wis flow model that will help to answer
cumerrt hydrofogcquestions asweiiasto serw as the underlying framework for current and future
focused studesand refined flow simulation in loca/iaod areas Sjcn a model will benefit multiple
governmental agenaesand other parties interested in water management, will be available for future
Studies, and ax/Id be refined and updated for any particular area of interest. Until recently, the success
of developing a meaningful and useful numerical model for the entire Back Hills area would have been
questionable. However, the current wealth of data for the area combined with the most recent
modeling and optimization software and computing power such as dood computing, results in a high
likelihood of success.
A wealth of new data useful for modeling has been affected since the Back HHs Hydrology Sucfywas
completed, which included datathrou^i 1998 New datasetsir>dude(i} 14 years of streamflow, spring
flow, and prooodwater levels for continuous gages and manual measurement* which adds an
additional wet and dry cycle to the record; (2) multiple groundwater tracers (ag, chiorofluorocarbon*
stable isotope* tritium, major ions) collected at about 70 sites and used to better characterize
grounctwater flow, conduit networks, art potjKfwater transit time* (3) mjcrog-avity measurements
to estimate effective porosity and better characterize unconfined aquifer anes; and (4) several years
of stable-isotope time-aeries data for selected wells and streams.
Problem
Local and federal agencies in the Back Hills area are seeking answers to questions regarding
jyourxlwater waBabitf, the effects of current or future groundwater extraction or drou^rt, the
proportions of regional groundwater inflow and local recharge in particular areas, the capture zones of
springs and weite, and the influence of springs and wells on flow directions and hydraulic gradients.
These questions are difficult, or impossible, to ana#* objectively without a thorough quantification of
myriad hydraulic influences and stresses on any gven area The mfluenoe of regonal groundwater flow
on local hycfrofogic responses is particularly difficult to quantify. Athre^dimensional ^oundwater flow
model would provide these estimates better than any other known method, but such a model does not
ait for the entire Sack Hills area Wthout the awaflabilitf of a calibrated regional model, smaller
models would need to be developed independently to address issues in site specific areas, which is an
Inefficient approach. Brtatter areas for which modela previously have been da^opeci include part of
the northern Back Hits (Greene and others^ 1909) aid the Rapid aty area (fWrtam aid Long, 2009).
Considering the complexity of the Back HWshydrogeoiosjtoframewQrk, the value of the water
resources, and the abundance of hydrologc issues and questions, many needs for additional modeling
efforts are foreseen in the near future. Developing one regional model has several advantages over
developing separate smaller models for spealcareaa These advantages are (1) it would be a more
coflt effective approach, (2) simulation of site-specific areas is more tfif rel©§etf ty accurate when
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nested within the context of regional flow, and (3) artesian springs capture groundwater flow from
large, possibly regional, areas that can be simulated with a regonal model but not with small-area
models. "The latter item is particularly important in the northern and soot hem Back Hll% where
regional flow sweeps around the Back Hills toward the east and mixes with local recharge.
Objectives »*§ 2£0»
3udy objectives are to (t) better understand the influence of regional groundwater flew on local
groundwater; (2) assess the effects of pumping and drought on groundwater availability; and (3) help
guide further data collection efforts
The primary focus of the proposed model will be in and near the Back Hills where water from the
Madison and Mmnelusa aquifers is used extensiuaiy. Areas of complex hydrogaology. such as where
Tertiary iftrutiveroctotaNe disrupted parts of the Madison art Mimelusa aquifers, will be simplified
to a level that can be represented by the model. When constructing a model, one of the first
coniderations is the locations of boundaries, which frequently are set arbitrarily if a natural aquifer
boundary, such as a recharge area, does not exist in proximity to the area of interest. "These arbitrary
boundaries generally are flux boundaries across which simulated groundwater flows horizontally
through a cross-section of an aquifer, To minimize artificial boundary effects, flux boundaries will be
set far from populated areas of interest and much wider than the limits of the Back Hlls hydrology
Study (Figure 1). The focus area near the Back Hits (figure 2) will have smaller model cells and will be
given more wei^it in model calibration than of her areas of t he model.
Specifically, this model will be a t hree-dimensional numerical groundwater flow model for the Madison
and Mmneiusa aqmferein and near the Back Wis of South Dakota, constructed in MOOFLCW
(Harbaugh, 2005). The model for the Rapid Qty area (FUtnam and Long, 2009) will be incorporated into
the figortaf model, with a similar model oeii size Modi! grid calls will imams in size outside of the
Rapid Qty area, Ajtomated promluresfor from an independent geospstiai
database in ArcGSwi! ailow for efficient grid refinement in particular areas of interest for future
focused modeling studies. These automated procedures will consist of utilities that interfaoe between
the geospatiai database and MGDRXW. Hydrogeotogicdata or ettffiates, inducing aquifer top*
aquifer bottoms, potentiometrfc surfaces, well locations;, rectargs, and , win be
stored in ttepospatial database.
The scope of the project includes a d at selection component .which will provide hydrochemical
tracer data useful for calibrating the model to flow directions and groundwater mixing The project
consists of two phases: (1) a hydrogeologcframewo
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©^a^ie^aty %°d°wf• §•¥»
In developing numerical flow models, a large pat of the effort involves effecting aid arcing data,
constructing surfaces for aquifer top* bottoms, aid potamiomttrtesurfeo* art ® forth. However, as
a resn/t of va-tousprewowfn^l^iofi^ many of the base data components necessary for
<***<**"9 a numerical flow model already exist. The Back Hits Hydrology 3udy (area shown in Rgure
1) included numerous investigations that were summarised by Grter and others (2002, 2003) and
Cnscoll aid ottais(20Qg. aher proximo* igtf ionswfth detailed inforoatioo for focused areas of
*uayin the northern, southern, and eastern Back Hffs include Long and Putnam (2002), Wfwn and
Long (2007a 2007b 2009), and long and others (2008,2012) Ftegjonal data beyond the Back t-ilisalso
are available from numerous other investigations listed in the "References Cited* section. Geologic
maps and cross secttonifor the Bat Wis to available from Srobel and others (1999) and FteckJen
and OeMJttt (2006).
Hydrologici^ ° §§<•>£•§
used to assess and better under st and regonal goundwater flow in relation to the Back ttlls area and
the relative mixture of focal recharge and regorial flow, whicfc ffiigt aig«*#from as far avayasthe
eastern flankaof the Fbcky Mountains in Wyoming. This is of particular importance at the northam and
Iii-ir |l; 111Y As-iste ¦&&*. Iff!!! »SSs^ n - I " 1-111 ir.i 111. ;ia®, ,w-!, ¦Til ,1-1 #¦ ,. mtiiii III- '."i „»v -I rr- n nnv —til
southern lips of the aack rills, where local and regional now converges the capture zones or artesan
sorincfiL the influence of these sennas on the mi)ono of recaonal and loed flow aid It* ratal we
proportions of regonai aid iocai springftow will be assessed Also, the corrvergng and mixing of
¦«.—.» >- tmJL Aim a Ft fn n t r JC11 .m. s sj .»sA lias. -¦»¦—• ¦—»* — ¦¦¦>-¦* ;£'! ..sua «. £ *— ¦- iif 4 4 'W. ..I*, 11 I,-. ¦ -I,- .-III # . * *S 11 JUt js»
recharge on tne western nam of the Mack riliswitrt regionaf flow from taftr^ei to tr>e west wilt be
I >4yr -feV>efe^0fe*t3F-%i/Ur r^"-p<3 The effects of inaeaaed
groundwater demand asaresuit of f.x)tential population growth will be evaluated by srnulating
addtionfll pumping from existing or hypothetical production wells. One trw«l MfMiaklm will be
executed for each of 5 to 7 areas on the eastern srde of the 3a* Hills between SpearfiA and Hbt
^xings. Fbtentiaf evaluation areas indude ^)eafi#i, Surgs, R3pid Qty. Hermosa, l-to! ^nngs. or
other areas belween these cities (eg near Wiitewood, Summer a*, or Buffalo Gap), lie find
selection of evaluation sites and pumping rates will be determined by conajftingwith project
oooparatofs A pumping period of 10 to 30 years will be simulated for each area {not to exceed the
length of tbefratsert calibration period). ^i»Inh^rai(ct^«J^)firigff«®ar«iioflte
additional pumping will be evaluated Meaan springs to be evaluated are described by Qrtscofl and
Garter (2001«fig. 12 and tabie 2). Wafer table springs for the Madison aquifer lo be evaluated include
springs at the hoadw*fter s of strearns on the w®fit0rn outcrop of the Madieon Limestone (limestone
heactwater springs, &im>H and Carter, 2001). At the end of the pumping periods, the amulated
squiferswilf be allowed to reoovet. ml the recovery time for hydraulic head and spring fiow will be
evaluated for e^i of the pumping areas. Aquifer reoomy will be simulated until full roomy is
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achieved. OHM is groundwater management process (Ahffeld and others, 2005) developed for
MOOFHW that might be useful for this purpose.
One or more drought periods similar to those that occurred in western 3xxth Dakota between 1930
and 1960 fDrisool and others, 2000) will be smuiated. and the resulting declines in hydraulic head will
toe shown on a map of the fans area, and spring-flow dedineswill be evaluated
I odiW iMtfif Because data collection can be
costly, an elective assessment of data collection scenarios would be useful.
Model predictive uncertainty analysis, as described in Doherty (2010) and R mm and others(2010),
will beuaedto assa® possible 9oenario& ^eafically, thlswl mdkatewhat
model's uncertainty if these data were aoqured at some future time Future revisions of the model, as
W0R as other future bydrologcstudkss, will benefit from this assessment. QMS might be useful in this
application.
Approach
The MOOFLOW finite-difference g-ouodwater flow modeltng software will be used to oonatruct the
model and smuiate youndwater flow (Harbaugft 2005). The gid will be coarse near model
boundaries (-15-tan sparing) and finer within the focus area (300-500-m spacing; Rgjre 2). The highest
resolution will occur in the ftapd Qty area, with a grid spacing of about 150m. The ooarae-gndded
areas will tow© few model ceNewfth a small effect on ^oecution times but will frtniffii® artificial
boundary effects, One method for varyingthe size of grid cells is to vary the widths of model rem® and
columns in the desired area as described in Harbaudh {?GQ5"I "TWsmethod wasu%d by Lena aid
Rjtnam (2008) a*! Rjtnam and long (2009). Another method isto yse the local Grid Refinement
(U3F$ capability that isiWMl^ for MOORTW-2005 fMehf and HI!. 2007). fMsoption <*lows
nested gndsof fine resolution within an otherwise coarse^ridded modei. Also, the USGSsoon piansto
release a new version of MCORXW that allows for much more freedom in the structure of the model's
grid and will allow gid cells to be almost any shape desired For example, small triangular grid cells
oould be used for the Rapid Qty area and oould irKreaae in siae outward in ail directions. This versatility
would easily accommodate small cells in any area of interest where hi# resolution simulation is
desired.
The full extent of the Madison and Mtnneiusa aquifers in the model area will be simuiated. each with
two model layers, similarly to the apfyoach of Rrtnam and Long (2006) Outside of the feojsarisa, the
Marfson and Minneiusa aquifers each will be simulated as one layer unless additional information
indicates benentstoamUto^thamiMth two layaraeaitL IheBitfeMrood imestore underliesand
has similar propertiasto the Madison Limestone, and this format ion will be combined with the lower
Macfison aquifer layer Upward flow into the Madison aquifer iayer from underlying aquiferswill be
simulated but the model will not be calibrated for these underiyina aauifecs, which ocnsst of the
VUhitewood, Wnmpeg. aid PeadwoocJ aquifers. This method was used in the numerical model by
Putnam and long (2009). loBthni aqt*fa*will be combined into one ma« layer, hereafter
referred to as thesuty-Madaon layer and will be inducted in themodd for the purpose of providing a
6
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lower model inflow boundary only The rate of this flow component will be estimated by the method
used by Long and Ritnam (2002) for the eastern-central Hack Hffs, which was also was uaed in the
numerical model by FUfnarn and long (200$. This met hod uses Oarers law and the difference In
hydraulic head between the Madison and DeadwoocJ aquifers to estimate a i«f rate Ihfeatfimated
flow rate mil be assigned as recterge to outcrops of the W*tewood, VUnnspeg. aid Cteadwood
aqufersandatlowed to leak upward into the Madison aquttar. Aaaminlmum areal erfent, the sub-
Maciaon layer will be included Wow exposed areas of the Madison aquifer, with tt® option of a large-
area' extent if necessary for upward flew.
Sbme of the Phase 1 tasks have Doer, oampleted Of are in progesa , .act
initS6ntlraty,indudingoomptetedtaBlc&
0&* G^~( rr§"
Ahydrogaolagjcframework will be assembled primarily on the bass of existingiatafrofft msmms
sources (see Rsferenoesatod! The first step is to (Mine the mode* area and hycsrogeologc boundary
condrtions(e g, head-dependent no-How, specrfied-flux, or const am-head boundaries) Figure 2
shows the approximate mode* area The exact model area md foots area wii be. finaiia&3 after further
examination of data and literature. The seoood step is to define aftftudaaof thetopsarid bottoms of
the hydropoioglcunitaasthay will be represented by modal layer* lie third step is to define general
potent tometric surfaces for the hvdroaeoloac units Fourth redharae from direct oreaoitation and
tfNtingstraamSt evapotransptrahoo. and discharge to springs and streams will be estimated on the
baas of available data Q-ourxtwater pumping will be obtained from pufalicaliy available water use data
(U S Geoiogcai Survey. 2011), if necessary. data on water permitting for Sfcith Q*ota. Wyoming a*!
Montana will be acquired Manual flow measurements w>li bemade at selected springs and streams
where continuous gages do no! exist «« or moratimssdurinethe study aid wil! be used as model
calsbrat'on data Gfcochern.'cai data consisting of stable isotopes of oxygen and hydrogen <>'H)
and major ionawMI be collected at anking streams, well* and springs for uae as natural tracers
Sbrnplas will be analyasd at the US3S Isotope Laboratory in Fteston, Virginia and the US3SNat.onal
Water Oiahty laboratory in Denver, Cbiorado Sampling will oonast of about 50-70 samples, ootlacted
either once at each ate or muiipte times at few sites These data, together with existing poctericaf
data will be '.'***1 to better characterize crounotwater flaw directions aid mi»na and also in model
caiibrat'.on or to hdp a^» mcKtel uncertainty |e.f., how weii does the imuMeltmr dfanscNons
andmixinadetermined bv'natural tracjersi Hydrauitccooducfivitvesti Tttrfwtw#
mm. 11 w#** Wh# %M9me%-%t&K * * w® wvm •# jr * * • *¦«%" My « * •* w» %*»**%# «*»%*%#%• * w*%w fSIH s 1*1 ®wi *#
avaitabte from aquifer teat sand pr e^ous cy oundwater fksw rrxxkiv Qecause these est u nates are
atxyse bydraLilic conducttvtty will t*) estim marilv durirxi the r npham* aii
nhied data and estimates will be iised to describe the oroundwater tai system oonoeotuallv.
which wili then become the baas for a numaricai flow model.
Grourxjwater rechargswiil be estimated using the method of V\toatenbroek and others (2010), which is
a soil-water -trance (3^ model that uses preopitation, temperature, land-use, arxj soil !ype data
Mothodss»rntiar to SWJaiao are avaiafcie axi cx^ssibsv will be useo as a comoarison to 3/vB
'*• * * •»' • wV 'wf'V. w %"® %r*W %P» » f prwr^lp *m\ w WW » Wlr\0 * «p»V"USr * S V \00t W
Ffechargc rievr anking streams antl hydrologcprocesQesfn serm-saturated caverrxMis iiquifef Axxism
the Back Hiis are poorly understood oecai^se of :ack of data and co.-npJexjty of these areas A pilot
7
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project to test tte capabilities of microgravity measurements for assessment of transient groundwater
storage processes in recharge areas of the Back hilis currently isnear oompletion. Results indicate that
miarogravity methods are useful for characterizing physrcal properties and low processes tn recharge
areas of the Madison and Minnelusa aquifers (Koth and Long, 2012 tonwfew), and this information
oouid not be obtained from previotttty applied methods. Mkxogravrty investigations will continue in
previously studied areas because longer data records for these areas will better constrain gravity-
based effective porosity estimates and other flow characterizations. Microgravity investigations may
be applied to areas not previouely Studied if, at some time, this is determined to be more ussful than
continuation at current measurement locations
Nuclear mapetic resonanos (NMty is a geophysical method that has been used successfully in karst
aquifers. Ttusisthe same technology that isrouttneiy used in medical imaging; i.e., magnetic
reaonanoe imapng (MR). NMRcanbe used to determine the depth and volume of groundwater,
particularly in aquifers with large porosity and large voids, such as karst aquifers. NMRcan be applied
ovw an area of the land surface, imaging to depths of 150 meters in some cases, or as a down-hole
tool in boreholes. NMRinitUily will be tested in areas where microgravity methods have been applied,
and the combination of these two methods to character.'® recharge areas will be tested. Additional
NMRwork may be usad with or without microg-avity, depending on what is found to be useful.
Sbme combination of microgravity and NMRimreatigationswill be conducted at existing microgravity
survey areas, are! additional measurement The number of measurement areas
and the relative effort invested in the two methods will be determined as data are collected and
analysed Effort will be allocated aoxrcfingtowhat ismost efficient for obtaining useful data to
diaradifi® recharge areas.
Rami tasks
1. Identify end assemble existing data sources ~ Several categories of data have been previously
described
2. Oafine mot** a«» aocf boundary conations-The approximate mode* area shown in Figure 2
will be revised as neoessary after further examination of previous studies* which describe the
geology and hydrology of the model area Reticular attention will be given to the southern
model extent, at or near the limit of the Madison aquifer.
3. Construct datasets for aquifer tops and bottoms Several contour maps of formation tops and
thicknesses cover different oats of the model a"©a Tb rner oad or matched at the
edges ofthe individual map extents for continuous surfaces across the modei area These will
be checked for consistency In the three-dimenaonal hydrogedo^c framework.
4. QwMmet daia8et8torpatatiametrkimrfaoas~ Sfewd contour existing maps erf
potentiometricsurfaoesoover different parts of the moctt area and will be merged similarly to
what is described for the aquifer tops and bottoms.
8
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5, Qwfiuef MasetstfrhydrauttcconductMty-Bttmatasfromprerfous modelingstudiisand
aquifer teats wilt be assembled. These will provide initial values that will be refined during
model calibration.
8 interpolate spatial and temporal precipitation for Black Hits- Data from prsdpttation gages will
need to be interpolated between gages. This has been completed for 1931-1998 (Msec* and
other, 2000) but will need to be updated for 1999-2012.
7. Apply the soil water batmm (St# method to estimate arml nc&uwgt> from.pmtiflftatn - lis
method isdeacribed by Weatenbroek and others (2010).
8 Estimate groundwater recharge from sinking Streams- This will involve assembling streamlet*
records for existing gages and estimating recharge rates on the basis of majdmum atreamflow
loss rates indicated by Wariness and Driaoofi (1998). Ffecharge rates also wilt need to be
estimated for ungeged streams and when maximum toss rate estimates are not available.
9. Estimate and aonstnxi dntovts for $pfmj mid s/r&im discharge - Qscharge records for springs
and gaining streams will be assembled when avaiabte In some cms, these will h*» determtnad
by estimating stream base flow at gages downstream from springs or gaining streams
10. Acquire or ozt imate groundwater-vsa data
11. Qjfucf geochemicat and flow data - Geochemical data mdude stable isotopes of oxy^n and
hydrogen (S,eO, S 2H) and major ion& Row rates will be rneasured at selected springs and
streams,
12. Analym geoohemtcat mmpim Samples wM be sent U33S laboratory
13. ApttymicmgnMyan(tNMRin6ttKXl&~ Geophysical methods primarily inckxto mlcrogratfty
work but new goophyscaf methods are oootinualfy being developed and might be found useful
for this project. Wells will be ateviated when ne ryfor quality oontrol of elevation or
•~4311*3* VCI %JIOE.H*U
14 wrrtnigtodudngfigum art tabto preparation.
15 f o rewew comments and reciprocate reviews - The review process is essential to a
quality saentlc report,
0<8r* &-3»°§nn** /tmouf* W * «§•"
Data and estimates from 1 will be used to develop a numerical groundwater flow n*x?y, ror the
regional area shown in Figure 2 usng MOORCW-2006 (Harbau^i, 2005) or an updated version of
MOOFLCW if available. The model of the Rapid Qty area (FUtnam and Long, 2000) and the model of
the ^earfish area (Qreene and other* 1999) will be incorporated into the regional model Hydraulic
conductivity vriuesutKl in these models will be used as initial, or pe^feation, valuetfor the
figoir*l model. These values may change during calibration of the regional model because of
rtffsfifwgsin boundary oondltions between the small modelsand the regonat model. The regional
9
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model first will be calibrated to steady-state flow conditions, where all inflows aid outflows are
oonatant in lime. Initial estimates of model parameters, such as hydrauHcconductivity values, will be
refined by adjusting these values to achieve similarity between observed and smutated hpfratjiictoad
and flow values. "The abundance of hydrau!iohead values makesthtsan effective method for
estimating hydraulic oorviuctivity. The parameter optimization software RESTwill be used to achieve
thteoalibration (Doherty, 2005). TWs state-of-the-art software eliminates the need for inefficient triai-
and-error parameter edguatment, A relatively new and powerful method known as plot points
described in Doherty (2005) will be used in rmxW calibration. "Thismethod interpolates hydraulic
conductivity values in each model cell between pilot point* where the optimiatton oooutfii
Onoe the steady-state calibration isowriptete, the model will teeeeuted in transent mode, which will
amutate a gpeafic historical time period of up to 20-30 years of record for annual data. Model
calibration will be refined in this mode to achieve optimum ifrttafif between temporal changes in
observed and simulated hydrauiiobead and flow values on an annual bass.
Phase 2 tasks
1. fbrmaf all data for MCDFLCWinput files and construct model - Data Stored in ArcQISwill be
exported to populate model oetla Data stored in other formatswill be formatted for MOOflXW
input.
2. Link MODR.CWmodel to PESToptimization softwam - PEST runs as a parent program to
MOOftXM Several instruction files need to be aealed so that PBT can read UOOF10V
output, Debugging the REST" instruction files generally is part of this process.
3. CMMe eteacty-Qtate model to measured cilia - "The model is calibrated to average flow
oonditkxwin this step. This is a lengthy process with many stages of increasing model
compiewty and parameter definition and categorization.
4 Sfecwf # antf calibrate transient nswiaf to MMmmf tfaf# - "This prows is similar to Task 3,
exoeot t hat the model is calibrated to lono-term records Rrameter estimates from the ateadv-
tfate calibration will be used as initial estifnatiR
5 DafiiHspringcBptummgBmidr&toaftvgtonaltlcw-Backward particle traddno fromaprfrtg
discharge points will be oanducted on the calibrated mode* to determine spring capture zones.
The point of origin for these particles will determine the ratio of regional flow for each spring
6 Assess spatial aquifer senaft/vrty to pumping and drought - A aeries of model exeafltanswNI be
conducted, well wilt be pumped for each execution, in
pro*mai oetts will be Mmmima for eech pumped wen, art a map of relative drawdown will
be created An extended drought period will be smulated as previously described. and a map
ahowingthe resulting hydraulic-head decline at the end of this period will be aeated.
7. MmmMtimfmm^fatMrnaalfmilmefforts-ArrHMpnikthmuncataMtyanatyss
wilt be conducted to determine awes and types of fMa that, if ooHadted would dbowem the
model's predictive uncertainty.
10
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8. Rspon writingincludtogffgunandtabbpnpamtion
9. fespond to review comments and reciprocate reviews
Potential ffyj* afi§#>
htydrologfc soenarios related to increased water use. additional pumping wells, or extreme climatic
conditions, such as drougfit. oould be smuiated for particular areas of interest. Ftefined model
calibration for these areas migfrt be necessary, and grids with finer resolution oould be nested into
these areas, Cbntaminant-transport simulations oould be conducted to investigate water-quality
issues. One potential approach for these investigations wig* be to simulate flow in discrete oorx*its
in the Madison aquifer for areas where knowledge of conduit location e»st. Theoonduit-flow prooeaB
for M
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BudgetVMmeiineVtr4§ »3Z§H0fe
"Theprq planned for completion within a 6-year period at an estimated exist of $960,000 (Table
1). The budget represents the project in its entirety, inducting ait completed tasks Assuming that the
USQBQwperative Water Rogram continues in the future, the USB will contribute matching funds for
arry axrtributiorwfrom local or stale government* Funding provided by Federal agencies cannot be
matched by the US3S For 2011 and 2012, the combined oontribcit ions from the National Park Smnoe
and the Back Hils National Forest are equal to $101,650, or 11 %of the total oost. Additionally, several
local agencies have expressed potential interest in participation, including the dties of Ffepid atyand
^earfish, iawrefioe County, aid the West Dakota Water Dw^oprort ~strict. The LKBareJ Rapid
Oty currently are engapad in a cooperative program involved groundwater flow modeling and Ffepid
Qtv tiasexDfOTd esoecialfv keen interest in reciorid model deveioD!T}eftt
Two USGSSbentffic Investigations fteports to document data ana results for each of the two phases of
this study and are planned for publication in 2014 and 2016, respectively. The first report will desenbe
the hydrogsologlc framework and conceptual model on which the numerical model will be built. The
second report will document calibration of the numoriCBf model, nssultsof graunMter flow
simulations, and an assessment of future data needs.
12
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Hgjre 1, Area of imeatigptian far the Back HUs Hydnotow Study (Rom Driacoi and other* 2002).
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION 8
1595 Wynkoop Street
DENVER, CO 80202-1129
Phone 800-227-8917
https://www.epa. gov/region8
EPA PUBLIC HEARING
WRITTEN COMMENT CARD
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LOCAL & REGION ^ 11
RAPID CITY JOURNAL
Colorado considers statewide
gas-well map after deadly blast
IfiMCTC Hi MWiTT
WiMlfalfcll ViKtt ¦
DENVER — Colorado
lawmakers are considering
the nation's first statewide
gas well map requirement
in response to a deadly home
explosion traced to an inac-
tive line.
The proposal would force
energy drillers to provide
state regulators the loca-
tions of all their gas lines, a
national 'first, A Democratic
House committee approved
the idea 6-3 Friday.
The measure is inspired by
a home explosion that killed
two people last month in
Firestone, a small town in
northern Colorado. The
April 17 blast was traced to
gas seeping from an old sev-
ered underground pipeline,
called a flow line.
The well was dialled in
1993. State records show
it was shut down all of last
year and resumed produc-
tion in January, although
the records do not show the
reasons,
"IMs transparency has
never been more urgent.
We simply cannot go on this
way," said Sophia Guerre-
ro-Murphy of Conservation
Colorado, aa environmental
group that supports the bill.
But the measure faces long
odds of becoming law.
First, Colorado oil-and-
gas regulators have already
ordered safety reviews of the
state's 54,000 wells, with
ASSOCIATED PRESS
Workers dismantle the charred remains of a home May 4 at the location where an unrefined
petroleum industry gas line leak explosion killed two people inside their home, In Firestone,
Colo. Two state lawmakers have proposed a bill to force energy drillers to provide state
regulators the locations of all their gas lines.
additional testing over the
next two months. And the
Ml doesn't addles old well
lines whose owners are out
of business.
Colorado has a Democratic
House and a Republican
Senate, making bipartisan
agreement crucial for any
measure. That bipartisan
agreement seemed elusive
Friday, with some Repub-
licans calling the proposal
a knee-jerk reaction that
won't improve well safety.
This is about politics.
It's not about safety," said
Repablcan Rep. Lori Saine,
who is from Firestone.
The state Legislature has
just three working days left
— the minimum amount
of time that a bill can pass
and head to the governor's
desk. And Democrat* Gm,
John Hickenlooper, a for-
mer geologist, told reporters
Wednesday that improved
well maps are important but
may be better kept by county
and local authorities, not
state regulators.
"I don't think It's unrea -
sellable to want to know
where those ines are. I'm
not compelled that It's got
to be the state that controls
that," Hickenlooper said.
A representative of the ad-
ministration testified Friday
that the state agency over-
seeing drilling Hgutotas is
neutral on the hflL
Supporters insisted the
state shouldn't wait for
regulators' safety checks
to demand comprehensive
nuqpping.
"People have no way of
knowing what's going on,
what's near their homes. ...I
think that's important" said
Democratic Rep. Adrienne
Benavidez.
Marijuana found stashed in shipment of Ford Fusions
NOG ALES, Ariz. - A
shipment of Ford Fusions
traveling by rail from Mex-
ico to Minnesota has been
found to have marijuana
hidden inside the vehicles.
the other 13.
Each of the first two cars
had 40 pounds of marijuana
molded into the shape of
spare tires and tucked inside
plastic wrap, aluminum foil,
coffee grounds and embtute
Nogales, Arizona.
Police do not have any
suspects, said Stave landers,
aspokwnnanfortheSt.Paul,
Minnesota, poice.
A spokeswoman for Ford
said till" mmrwtTwlc rawa of
from Mexico.
Police searched more
than 400 other vehicles in
the Dilworth rail yard and
found 217 pounds of mari-
juana packaged and J
4*0 1 r
-si'
-------
LOCAL & REGION
RAPID CITY JOURNAL
l.
Small gas pipeline blamed for
fatal Colorado home explosion
Associated Press
FIRESTONE, Colo. - A
home explosion that killed
two people was caused by
unrefined natural gas that
was leaking from a. small
abandoned pipeline torn a
nearby well, fire officials said.
Hie Apr! 17 explosion In
Firestone about 30 miles
north of Denver happened
when the odorless gas in the
old line leaked into the sol
and made its way into the
home's basement, Tted Po-
szywak, chief of the Fred-
erick-Firestone fire depart-
ment, said Tuesday.
Investigators do not know
how or when the small pipe
was cut. The house was
within 200 feet of the wefl,
and the pipeline was bur-
ied about seven feet under-
ground.
Hie we! was drilled
in 1993 and is owned by
Anadarko Petroleum. In-
vestigators are still trying to
detenito who is responsible
for the abandoned line.
Anadadtoand Great West-
ern Oil & Gas said last week
they would shut down aid
inspect more than 3,060
similar weDs as a precaution
daring the investigation.
State records show the
wefl near tM home that ex-
ploded was shut down all of
last year and resumed pro-
duction in January, although
the records do not show the
reasons. Anadarko has previ-
ously declined to comment,
citing the ongoing investi-
gation.
Tfaeweawaslastfaspected
in2014andreceivedausatis-
factory" rating.
Mark Martinet and Joseph
William Irwin m ware kilted
in the blast and resulting
fire. Erin Martinez, who was
married to Mark Martinez,
was bally burned. Irwin was
her brother.
Anadarko and Great
Western's actions prompted
nearby Boulder County to
aAenergy»mpim«toslmt
down and inspect all vertical
wells there, about 300total.
Adams. County, which is
Just south of Firestone also
asked ol and gas companies
to inspect-vertical weflsnear
occupied buildings, but the
county did not call for any
wells to be shut down. It
wasn't known if any opera-
tors complied.
The proximity of subdi-
visions and wells is a source
of contention in Colorado,
where fast-growing cities
sometimes overlap with lu-
crative ofl and gas fields.
Conflicts have generated
lawsuits and attempts to
overhaul state rote. The
Legislature killed a proposal
this yeair that would have
increased the nintamim
distance between
andnewoftanigBfcfltiBS.
The state Oil and Gas Con-
seivationCommisskHi reg-
ulates the distance between
new ofl aid gas watts from
existing staefaies, tat lo-
cal governments set the rules
firtl»,#stoP«bc^w^Bnew
fta§tQnfittbeiiiiritaora
-------
#ar mat oegan 16 years after
Jackson's death. Having, let us
fancifully imagine, considered
and found unconvincing William
Seward's 1858 judgment that the
approaching Civil War was "an
irrepressible conflict," Trump
says:
"People don't realize, you
know, the Civil War, if you think
about it, why? People don't ask
that question, but why was there
the Civil War? Why could that
one not have been worked out?"
Library shelves groan beneath
the weight of books asking ques-
tions about that war's origins,
so who, one wonders, are these
Korea should reciprocate this
worry. Yes, a 70-year-old can
be callow if he speaks as soph-
omorically as Trump did when
explaining his solution to Mid-
dle Eastern terrorism: "I would
bomb the s - - out of them....
I'd blowup the pipes, I'd blow
up the refineries, I'd blow up
every single inch, there would be
nothing left."
As a candidate, Trump did
not know what the nuclear triad
is. Asked about it, he said: "We
have to be extremely vigilant and
extremely careful when it comes
to nuclear. Nuclear changes the
whole balgamef Invited to elab-
of this mind, a presidential dis-
cretion that is largely immune
to restraint by the Madisonian
system of institutional checks
and balances. So, it is up to the
public to quarantine this presi-
dency by insistently communi-
cating to its elected represen-
tatives a steady, rational fear of
this man whose combination of
impulsivity and credulity render
him uniquely unfit to take the
nation into a military conflict.
George Will is a nationally syn-
dicated columnist. He can be
reached by ^mailing georgewitl®
washpost.com.
YOURS
Why in-situ mining needs many permits
Recently, I have heard two
themes in the discussion of
the potential for uranium
mining in the southwestern Black
Hffls.
One is that some people believe
that the mining has akeady received
a go-ahead, which is far from true.
The company that wants to mine
in Custer and Fall River counties —
Azajfga/Powertech — must get at
I least ten permits of
bfr. various types before
fcf it can begin mining,
rjj And to date, they
f j have exactly one -
L and that one is tied
up in court.
The second
theme is that some
people, mainly the
company, think
that the permitting process is too
hard. But the number of permits
needed is a result of three things.
First, it's a result of our nation's
division into counties, states and a
federal government. {Each level of
government has different respon-
sibilities under our Constitutional
system of government.) Second, it
is a result of the fact that uranium
is both radioactive and toxic, so we
need protection from its impacts,
tod third, the number of permits
is a result of the nature of in-situ
each uranium mining, which lias
mpacts on water, land and air.
This type of mining involves
huge amounts of witter — 9,000
gallons per minute — so it needs
permits to use water. The pro-
posed project would pump from
two groundwater aquifers, the
Inyan Kara and the Madison. The
mine would tear up the surface of
the ground, so it needs a milling
permit. And it can pollute the air,
so it needs an air quality permit.
Equally important, this type of
mine needs to get rid of wastewa-
ter. In this case, the company's first
choice is to pump wastewater into
the Mhmelusa aquifer. Note that
the Inyan Kara, Madison and Min-
nelusa aquifers are our three major
drinking water sources in the Black
Hills, so it's important that some
branch of government tracks the
things that go into or out of them.
If the company can't get per-
mission to pump its wastes into
our groundwater, then it wants to
spray them on the ground. This
would impact over 1,000 acres.
So, if the company wasn't
threatening our air, land and water
to do something that is inherently
dangerous, there wouldn't be as
much need for permits. Radioac-
tivity is, after all, permanent. And
there is no alternative to water. I say
if you want to use and pollute our
natural resources, there should be a
process in place that is designed to
protect public health, our economy
and our environment.
This is especially urgent when we
are dealing with a Canada-based,
China-led uranium company
whose biggest stockholder (seven
of whose leaders are under federal
charges for such things as fraud) is
basedin the Cayman Islands.
It is also especially urgent be-
cause the mining industry pro-
duces one-third of the nation's
total toxic pollution, and taxpay-
ers end up holding the bag when
companies go bankrupt - which
happens regularly, as the history of
the Black Hills shows.
Luckily, in one case, each of us
has the opportunity to be part of
the permit process — when the
Environmental Protection Agency
holds public comment hearings on
May 8-9 at the Ramkota in Rapid
City, May 10 at the Mueller Center
in Hot Springs, and May 11 at St.
lames Church in Edgemont (1 to
8 p.m. each day, with a break from
5 to 6 p.m.). Anyone can have their
say.
So if you have an opinion about
the proposed uranium mine and
waste disposal, bring it to the hear-
ings, or Just come to observe. We
are, in this case, part of the permit
process.
Lilias larding is a member of the
Rapid City-based Clean water Alli-
ance.
-------
¦
JaJfauae
m
Thomsen
look
—"I'll remem-
1 be
ber how great
tappy
my i friends
jvery-
looked all
went.
dressed up and
«rs, I
how much hard
i two
work the parents
t guy
put in so we
d I'm
could have a
hat it
nice prom."
awk-
date.
n and
ght."
Logan Block
- "1 will
remember it as
being one of the
most decorated
ones I have been
to so far. It was
an amazing
• night spent with
all my closest
Mends."
SkylarDekker
- "I will think
about how awe-
some my date
was and how I
couldn't have
had a better
group of friends
to go with."
IfariGtaricr
- "I will
remember how I
had a blast at
prom making
memories with
my best
friends"
apitol
It doesn't make sense
lfire with the intention of
pping the gunfire by tak-
; out (killing) the shooter.
t officer will be able to
anguish the bad guy,
bably because the good
joter will look ike
paloog Cassidy or Gene
try, or even maybe a bit
: John Wayne type. Or
1 the officer just take out
h shooters?
rhe governor in this
tsion made the right
Ice to veto the propos-
itus subject reminds me
the Johnny Cash song;
m't tie your guns to
n son, (or the Capitol or
courthouse). Leave your
i at home, (or at the
a! detector and screen-
i.
Screening to prevent
s in the Capitol or court-
se would seem to be the
st solution for all.
John D. Murphy
Custer
Dear Editor,
Renewable energy is
now cheaper than coal, oil,
gas and nuclear power.
Since October 2012, U.S.
nuclear plant owners have
closed about a dozen reac-
tor units.
The EPA issued draft
permits to
Powertech/Azarga for a
proposed in-situ leach ura-
nium mine in Custer and
Fall River Counties that
proposes to opcode for 10
years. No such mine has
been successfully cleaned
up, despite sincere efforts.
When the mining ends the
pumps are turned off, mid
the heavy metals such as
uranium which were loos-
ened by ihe mining solution
continue flowing through
the aquifer.
Yes, in-situ leach mining
occurs within an aquifer. In
this case, mining would
occur in the Inyan Kara
aquifer via 4,000 wells.
Waste would be injected
into the Minnelusa aquifer.
People are using the water
in these aquifers!
Do we risk precious
water for a type of mining
that historically has deplet-
ed and contaminated water
in exchange for a handful of
jobs to provide fuel to the
dying nuclear power indus-
try?
Or do we think beyond
10 years and reserve our
water to support the sus-
tainable economic growth
that is happening in the
Black Hills? The econom-
ics of uranium mining do
not make sense here.
Gina Parkhurst
Custer
Subscribe to the Chronicle!
673-2217
-------
buj
(|
POWERTECH WATER PERMITS*
My name is
and my wife and i live on a
small ranch south of Pringle and have been there for 23
years. Thank you for this opportunity to speak today.
1 do not receive payment of any kind for being here. I am
not a for profit corporation. Unlike P/T, 1 have no loyalties
or any responsibilities to show a profit to any stockholders.
I am free to do the right thing and I have only the truth as I
see it to give.
Men of my age are usually referred to as "old men" but 50
years ago when I was "young and in my natural prime" I
was a Naval Aviator on a carrier in the Gulf of Tonkin flying
low level photo reconaissance missions over North
Vietnam. When commissioned by Congress as an officer,
I swore an oath to uphold and defend the Constitution as
maybe some in this room have done. The Constitution and
the Bill of Rights of course support a prime directive:
Clarify the responsibilities of the government and the
rights of the people. Not businesses nor corporations"
rights but citizen's rights. Our governments' responsibility
is to the health and welfare of the citizens. This is
ostensibly why our military is asked to get in harm's way:
to make sure these rights, our rights are protected and
secured. Every civil servant, every citizen's board, every
governor is accountable to the citizens who have allowed
-------
them to serve and if they do not protect the public
interest , if they forget about protecting the health and
welfare of all the citizens and the rights of the people then
they have abrogated their prime directive and can and
should be removed. If it is not in the PUBLIC INTEREST,
it should not be done. This hearing is all about the water.
That is the heart of this matter. Because the water will be
nollutpd mntaminatpd radioantivp marninali7fid and
knf V# 11 vf IrVa# VJI j KjfKmJ I I I»v4>l 1 111 I v*l VJ j I QiVJl IV/ l>K V \*s | 111 vA I Vg 111 CAI I V*4 vi*lI I Vm
made unusable, this permit application is not in the public
interest.
State law says that all surface and ground water belongs
to the people. To the public. Not miners, not corporations,
not polluters. Polluters should have no rights to the
people's water. Ever. We all know that the world is
warming. We all know that our climate is changing. We
all know that we have had dangerous droughts,
tremendous storms with massive flooding and hail
damage. We all know that the world's supply of fresh
water is being depleted faster than it can regenerate by
overuse from an ever expanding population. We all know
that we cannot waste what water we have, that we must
conserve it, use it wisely and conservatively in order to
provide for the following generations. To do otherwise is
irresponsible in the extreme.
I have a series of questions to ask this board in the hopes
that they will be spurred to answer them and find therein
the courage to deny this permit application.
-------
^Why allow mining in soils where the hazards for erosion
are extreme?
Why allow mining where the winds will disperse
contaminants into Edgemont and Hot Springs.
* Why allow a company to contaminate three of the four
aquifers in the area and risk the contamination of the
fourth?
Why risk contaminating of the best source of water in the
Black Hills; the Madison?
Why allow a company that has no ISL experience to risk
all four aquifers?
Why even consider allowing a company to spread
contaminated effluent onto hundreds of acres of land that
slopes 2 to 6 degrees into Pass Creek and Beaver Creek
and thence to the Cheyenne, Angostora, Pine Ridge and
the Missouri?
How can this board allow the withdrawal of millions, no,
even billions of gallons of water and still be able to state
that it would be in the public interest?
Why allow this permit when PT admits that millions of
gallons of water in the Inyan Kara will be contaminated?
* Why think that 551 gpm from the Madison, which is almost
800 thousand gpd is possibly in the public interest?
Why consider that the use of this water which will allow
PT to mine is socioeconomically valid when the funds
garnered by the counties and the state will in most
scenarios provide only $30 or so dollars a year for the
citizens affected?
-------
*Why allow mining if PT cannot clean the water for human
or livestock or wildlife use but rather has to inject it into the
ground, into existing aquifers so it will not contaminate
anything other than that aquifer, which of course, makes it
totally unusable, possibly forever? or until our sun goes
z*red giant?
Show many heads of livestock could be watered with
250,000 gallons per day? 25,000 maybe?
How many gardens could that amount of water serve?
How much food could be grown utilizing this amount of
„ water? How much hay?
£ How much does water cost and why should millions, no,
billions of gallons of water be given to PT at no charge at
all? Is this in the public interest?
Mi Why allow aquifer injection when it is known that the
I aquifers can communicate, moving water between them?
/ How can this board allow a permit if a table in the
( application,Table 3.4-10 of the NRC applicatioin, shows
\ that the water quality in the formations includes such
poisons as thorium, uranium, arsenic, cadmium, mercury,
i thallium, polonium, radium, and radon all of which are
dangerous and all of which will be released by the mining
and released to the air or into solution into aquifers or
spread upon the ground to blow away or seep into ground
| waters?
Why allow a company to mine if it has only planned for
V, one 100 year 24 hour precipitation event when we can
-------
expect at the very least a 100 year event every ten years
and not just for 24 hours but for 72 or more as recently
experienced by eastern Colorado? Will a 72 hour
downpour cause dangerous erosion and contamination of
the flood plain and the watershed?
|K5an this board approve a permit when it is impossible for
j PT to remediate an aquifer to an original state, as made
clear by the NRC and it's minimum standard of ALARA
[^hich means AS LOW AS REASONABLY ACHIEVABLE?
(Is anyone going to be comfortable with PT having taken
the samples with no independent oversight by DENR,
EPA or NRC? In fact, as we cannot depend on the DENR
or the EPA or the NRC to protect our water, is it not up to
this board to do so?)
As PT has no idea of the total available space for aquifer
injection or an appreciation for aquifer regeneration, how
can this board approve of the practice without
acknowledgement that the aquifer may be overfilled, and
therefore over pressured producing the real risk of
leakage, earthquake and external contamination? Why
take any water from the Madison, why 551 gpm? Why not
use all the Inyan Kara 100% again and again? If the water
is treated, why must it be injected or sprayed? Why is it
not clean from the treatment? How is it treated? Is this
waste drinkable? Why not?
5.4.1.1.4.1 "The typical water quality during land
application will be better than shown.....since the water
-------
quality will be continually improving during aquifer
restoration." Is this board comfortable with the idea that
by putting clean water into a radioactive and contaminated
aquifer that the aquifer will be cleaner rather than the
clean water becoming contaminated?
Phrases such as "Anticipated....application water quality,"
"Estimated worse case", "typical land application water
quality." "Improving to approximate base line water
quality", "in addition, Madison water mav be used at am
time to improve the land application water qualih/\
"anticipated that trace metal concentrations at or
below.,...human health standards." Referenced table 5.4-2
and 5.4-3 were estimated. Also estimated chloride,
magnesium, arsenic, barium, cadmium, chromium,
selenium, lead, radium, thorium, etc.
Figure 5.4-4 Estimated process waste water quality;
arsenic, chloride, Carbonate, Hydrogen Carbonate,
ammonium, selenium, radium, sulphate, TH230, U.
Should not these provisional statements cause grave
concern?
5.5.4.1 "Anticipated land application rate of 297 to 653
gprrf The land application is the 2%170 gpm bleed from
the Inyan Kara. Where does the 297 to 653 come from?
Figure 5.3-2 Should the board be concerned that PT can
only "clean" 5000 gallons per day while they are producing
a minimum of 250000 gallons of waste a day?
-------
"Potential radiological impacts demonstrate no significant
exposure pathway from vegetable garden to potential
human receptors." Is this the kind of double speak with
which we should be comfortable?
5.5.1.3 I am concerned that in referencing ground water
restoration that FT has admitted that this will contaminate
millions of gallons in the l/K and make a large area of the
aquifer unusable for many of the existing users? Is it not
worrisome that the Minnelusa and Deadwood are the two
injection sites and therefore wholly contaminated leaving
only the Madison with the hope of remaining clear but
overused?
5.6.5.1.3 Should the board be concerned that PT accepts
the potential for accidents, leaks and spills which could
release pollutants; bulk chemical products, uranium
loaded resin, dry yellow cake, solid by-product material.
PT says it will simply remove the contamination. That they
admit that the consequences of these spills range from
minor exposures to "significant"? That these spills and
leaks and accidents can result in runoff into the
watershed?
5.7.2.4 Will the permit area, the water and the land, be
contaminated as a result of the reality that ANY AREA
WITHIN THIS FACILITY MAY CONTAIN RADIOACTIVE
MATERIAL?
-------
6.0 Should it concern this board that the reclamation plan
is produced by WWC Engineering, which is on the PT
payroll, and VPs Blubaugh and Mays who have no
experience in ISL mining operations when ARSD
74:29:07:18 requires that "The individual who develops the
reclamation plan must be competent in the management
and planning of the specific type or types of reclamation
selected."?
NRC states that'The primary goal of ground water
restoration is to protect present or potential future sources
of drinking water....." "However, restoration to pre-mining
may not be practicable or feasible...." Is this really in the
public interest?
6.3 Decontamination and decommissioning. PT has said
that radiation can simply be hosed off with high pressure
water or steam cleaning. If, indeed, it is even
possible ,there is no mention of what to do with the now
contaminated water that is the result. PT says it can
decontaminate the soil. NRC indicates that that cannot be
done. Are these contradictions not of concern?
PT gives it's"95% confidence that the ...units...meet the
clean up guidelines or action levels." Would the public
interest find 95% lacking?
6.4.3.6 Erosion control practices will be removed when no
longer needed. As long as the soil is contaminated and
as long as it rains, would it not serve the public interest to
maintain all anti erosion systems?
-------
Finally, how cart this board approve these permits when it
would appear that this company does not have the
financing to even start construction, that the personnel
responsible for the operation do not have the necessary
experience or the competence or the ability to operate the
system, that this company has left unanswered how it
plans to assure the safety of the public from the disposal
of truly dangerous chemicals and compounds, that has
yet to find the one management position that will oversee
the mining itself, that failed to produce a completed
application on time, that has made incorrect, misleading
and confusing statements, that cannot guarantee what it
has to guarantee, that will abuse and possibly ruin three
aquifers, while threatening the fourth? Simply put, it
cannot. The USGS clarifies that there are no ISL
operations that have ever cleaned or remediated or
treated returned the mining back to baseline or original
condition, none that have not contaminated the mining
area and none that have not left ruined aquifers and other
waters. The Dewey/Burdock area will not be cleaned. It
may never be safe. The NRC estimates that the
reclamation will cost upwards of $65 to 70 million. PT will
not have that amount available based on foreseeable
yellow cake pricing. It will be left in a contaminated
condition and will most likely be left to the state and/or the
counties to attempt the impossible and bankrupting clean
up.
-------
*AII numerical numbers refer to the NRG application filed
by Powertech/AZARGA.
-------
To: The Environmental Protection Agency
From:
May 10, 2017
Re: Azarga plan for deep well imjection
There are many reasons why the EPA should deny Azarga any permit to mine uranium
and/or inject toxic fluids into curremtly used aquifers in the Dewey Burdock area of
South Dakota, including the inyan Kara, Minnelusa, Deadwood and the Madison.
1: There is no market for yellow cake. There is no profit to be made by mining
Uranium.. Therefore, there is no reason for Powertech to drill deep injection wells
for toxic fluid that they will not be creating. It would appear that the only way for
Powertech/Azarga to profit by their permits is to make deep injection wells
available to outside sources of toxic waste. Powertech denies the idea of outside
sources of waste saying they do not "plan" to take in outsude toxic waste despite
the fact that their permit allows it and profit demands it.And remember,
Powertech cannot do any mining at all unless the laws protecting the water
and the land are put aside and waivers issued allowing the contamination which
is by law not allowed. These new permits will allow Powertech to pollute the
Inyan Kara and Minnelusa aquifers directly and the Deadwood and Madison
aquifers by transmissivity. Once these aquifers are contaminated, there will be
no remedy. They say they only need 1 1/2% bleed replacement, so why ask for
thousands of gallons per minute. If they will not take in outside waste, why
allow for it ? They say the waste to be injuected into the aquifers is just salt
water. The laws of chemistry refute tha claim. The application to the NRC by
Powertech shows that the waste will! be impregnated with Radium, Cadmium,
Chromium and Arsenic among many other poisons. These chemicals will
absolutely be part of the so called lixiviant.
New bore holes for toxic waste disposal are being requested because the
original plan to mine uranium In Situ is now irrelevant due to the low value of the
material and the lack of demand worldwide. Also, alternative energy
sources such as wind and solar are now employing more new workers than
the oil and gas industries combined.
2. Professional geologists and chemists from the South Dakoata School of Mines,
Chadron State and private practice have testified most effectively as to the
danger of this plan for all the residents in the area due to the irreparable damage
done to the water supply. The misuse or contamination of the aquifers in the
Black Hills flies in the face of good judgment due to the increasing importance
of usable water not just in drought affected South Dakota but the nation as
well. We are depleting our water supplies by allowing the very kind of
destruction envisioned by Azarga and the EPA. With the demand f o r water
ever increasing due to continued world population increases, it is imperative
that the protection and careful usge of our water supplies be our guiding light.
To actually embrace the opposite behavior is to violate the EPA stated
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purpose of actually protecting the environment. It is no longer possible to deny
the threats to our remaining water supplies driven by In Situ mining and water
ruination. It is the EPAs responsibility to make sure the water and environment
remain safe. The Black Hills Hydrology Study availble from the USGS is a fine
and revealing scientific paper available for your review.
3, The fact that Platinum Partners, which is Azarga's largest share-holder, is being
charged with a variety of misdeeds which if convicted could provide prison
terms for the guilty, should be a wake-up call to the EPA as to the kind of
ethics embraced by Azarga. With tie company based in China, overseeing a
Canadian company with offices in Colorado, one can easily guess how Azarga
feels about the long term health of the citizens in this area when compared to
the drive for profit at all costs.
4. How am I to explain to my granddaughter how her government decided that it
was safe and reasonable to exchange her healthy drinking water for a few pieces
of silver in the pockets of a few profiteers?
Thank you for your attention.
Sincerely,
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5-g-
EPA testimony
May 08, 2017
Good afternoon, My name Is and I've been a homeowner in Rapid City for the
past 11 years.
I oppose ISL uranium mining in Custer and Fall River counties because I am very concerned
about contamination of our groundwater. This area is prone to drought, so water conservation is
a priority. South Dakota's two largest industries, agriculture and tourism, depend on adequate
supplies of clean water.
The United States Geological Survey also known as USGS has found that no ISL uranium
mining operation has been able to return water quality to pre-mining cleanliness. The U.S.
Nuclear Regulatory Commission has been quoted saying that "the restoration of an ISL-mined
aquifer to pre-mining water quality is ... an impossibility.
There are a number of factors that indicate a mine in the Dewey-Burdock area would likely result
in contaminated groundwater.
There are old uranium mines in the Dewey-Burdock area that are not fully reclaimed, enhancing
the risk of groundwater water contamination.
It will be impossible to have adequate oversight of the quality of liquid wastes pumped into the
Minnelusa formation through the proposed deep disposal wells, resulting in likely groundwater
contamination.
The proposed mine and deep disposal wells are in an area that is documented to have faults,
fractures, breccia pipes. In addition, over 7,000 old boreholes have not been properly plugged in
the proposed project area. It will be impossible to contain mining fluids or waste liquids and
contamination of our groundwater is very likely.
I urge you not to exempt a portion of the Invan Kara aquifer from the Safe Drinking Water Act.
The Inyan Kara is used by many people and livestock and given the aforementioned risk factors,
water contamination is likely. I've heard that the Minnelusa aquifer contains 125 drinking water
wells - please verify with the South Dakota Department of Environment and Natural Resources.
With uranium mining we need to keep in mind that fact that the half-life of uranium is 4.5 billion
years. Yes, that is billion with a B as in boy.
Untold numbers of people living now and those yet to be born could be affected.
As you are probably aware, in the 2011 legislature, SD gave up its statutory authority to oversee
wastewater aquifer injection in ISL uranium mines at the urging of Powertech now Azarga
Uranium. Other types of mining in South Dakota such as gold, oil/gas are regulated much more
thoroughly than ISL uranium mining.
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If a petition for review of the new permits is filed, the new permits are not in effect pending final agency
action. If a petition for review of the permit modifications is filed, the permit conditions subject to the
modification would be deemed not to be in effect pending a final agency action.
Within a reasonable time of receipt of the petition for review, the HA B wi! I either grant or deny the appeal.
The EAB will decide the appeal on the basis of the written briefs and the total administrative record of the
permit actions. If the EAB denies the petition, EPA wi!! notify the petitioner of the final permit decisions. The
petitioner may, thereafter, challenge the permit decisions in Federal Court.
If the EAB grants the appeal, it may direct the Region III office to implement its decision by permit issuance,
modification or denial. The EAB may order all or part of the permit decisions back to the EPA Region 111
office for reconsideration.
In either case, a final agency decision has occurred when a permit is issued, modified or denied and that
decision is announced. After this time, all administrative appeals have been exhausted, and any further
challenges to the permit decision must be made to Federal Court.
-------
Good afternoon Judge Sutton and EPA officials,
My name and 1 >ive 'n Rapid City. I'd (ike to clarify a comment I
made yesterday about the number of drinking water wells in the Minnelusa aquifer after
speaking with Ken Buhler of the South Dakota Department of Environment and Natural
Resources (or DENR).
In November 2014 the DENR started identifying which aquifer a well draws from on the
permit forms. This means that for many wells in use, it is unknown which aquifer they
drawn from. Mr, Buhler said there are hundreds to thousands of domestic wells using
water from the Minnelusa aquifer. The exact number is unknown at this time.
However, Mr. Buhler aid it is known that there are 196 appropriated water rights
permits in the Minnelusa which include municipal, commercial, industrial and housing
use.
In addition, the USGS Water Resources Investigations Report 01-4119 Abstract starts
with this statement "The Madison and Minnelusa aquifers are two of the most important
aquifers in the Black Hills area of South Dakota and Wyoming."
The USGS Water Resources Investigations Report 01-4226 Abstract begins with u77?e
Black Hills are an important recharge area for aquifers in the northern Great Plains, The
surface-water hydrology of the area is highly influenced by interactions with the
Madison and Minnelusa aquifers, including large springs and streamflow loss zones."
In Valois Shea's presentation yesterday she mentioned that a Class V injection well
permit could not be issued for an aquifer that is an Underground Source of Drinking
Water. The Minnelusa is being used as such, so I think it is safe to say it is considered
an Underground Source of Drinking Water.
The EPA's website defines an Underground Source of Drinking Water as following:
1) it supplies any public water system, which the Minnelusa does, 2) the source of
water contains a sufficient quantity of ground water to supply a public water system
which the Minnelusa does, 3) it currently supplies drinking water for human
consumption which the Minnelusa does, 4) it contains fewer than 10,000 mg/1 total
dissolved solids which according to USGS tables I've found online applies to most parts
of the Minnelusa, and 5) the source of water Is not an exempted aquifer which the
Minnelusa is not as far as I know.
Thank you for listening.
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Background information
nttps://www.epa.gov/uic/general-information-about-injection-wells
Definition of underground sources of drinking water
An underground source of drinking water (USDW) is an aquifer
aquifer \s a geological formation or group of formations or part of a formation that is
capable of yielding a significant amount of water to a drinking water well or spring, or a
part of an aquifer that is currently used as a drinking water source, A USDW may also
be ground water needed as a drinking water source in the future. A USDW is defined in
the Cole of Federal Regulations (40 CFR 144.3) as;
an aquifer or its portion: (a)(1) Which supplies any public water system; or (2) Which
contains a sufficient quantity of ground water to supply a public water system; and (i)
Currently supplies drinking water for human consumption; or (ii) Contains fewer than
10,000 mg/l total dissolved solids; and (b) Which is not an exempted aquifer.
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5-
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NOW THEREFORE, BE IT RESOLVED, by the City of Rapid City that due to the potential risk to the
Madison Aquifer the City expresses grave concern about the proposed in situ mining of uranium in the
Black Hills.
Dated this 19th day of August, 2013,
CITY OF RAPID CITY
s/|
Mayor
(SEAL)
Thank you for listening.
-------
May 10,201.7
To the EPA,
We are present at today's meeting because we have deep concern over the
proposed Dewey-Burdock uranium mining in Custer and Fall River Counties of
South Dakota,
We bought our home in Fall River County in 2015. One of the main reasons for
purchasing this particular home was the fact that it had it's own well. To our
knowledge our well is 400 feet deep and likely in the Minnelusa aquifer. If we had
known at the time of the proposed uranium mining and the pumping of the waste
into the Minnelusa aquifer, we would not have purchased this property and have
concern for it's resale in the future.
It makes no sense for any kind of waste to be pumped into the drinking water
supply of an aquifer let alone possible radioactive and or toxic waste.
The only other alternatives for our water supply would be to hook up to rural water
which is very expensive or put in a cistern and haul in water which is also
expensive. This is why we wanted to purchase a property with an established well
which currently has safe and good drinking water. We are not even sure where
rural or hauled water comes from and if it may also me affected.
We don't need another "Flint Michigan" in the Black Hills. We don't want to wait
for children and adults in the area to become ill in future years due to this
incomprehensible proposal.
It appears to us that the EPA has more concern to protect gophers, toads and mice
than people.
We pay taxes for you to PROTECT US the PEOPLE.
WE ARE OPPOSED' TO THIS PLAN, WE WANT OUR WATER SUPPLY
LEFT ALONE!
Sincerely
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Dear EPA, Region 8:
Here are my comments on the Underground Injection Control Program's Draft. Permits for the
Proposed Dewey-Burdock Uranium Mire and Deep Disposal Wells:
• Old uranium mines in the Dewey-Burdock area should be fully reclaimed before new
mining is permitted,
• Adequate oversight of the quality of liquid wastes pumped into the Minnelusa Formation
through the proposed deep disposal wells will be impossible, and our groundwater is
likely to be contaminated,
• A full survey of cultural and historical sites is needed before mining or deep disposal is
allowed. Cultural and historical sites must be protected,
• The proposed mine and deep disposal wells are in an area that is documented to have
faults, fractures, breccia pipes, and over 7000 old boreholes that have not. been properly
plugged. It will be impossible to contain mining fluids or waste liquids, and contamination
of our groundwater is very likely.
• The history of uranium mining indicates that uranium mining cannot be done without
creating and leaving contamination. This project should be stopped until it can be proved
to be safe, rather than reiving on imperfect protection and i
Sincerely,
Name (Print;
Name (Signature)
Mailing Address (Print)
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Comments from Hearing Comment Cards
Name
Email
Comment
1
Building uranium mines will not only affect the environmental
but the people surrounding. The release of metals and
radionuclides can equal to having 100 X-rays in one hour.
Therefore, it can cause many health concerns.
2
1 believe there is no need for uranium. It is used for nuclear
weapons. We need to STOP going to war. STOP damaging the
Earth. But mostly we need to STOP treating the Earth like its
replaceable...
3
Water is Life, Stop polluting!
4
No email address
One of my favorite pass times was exploring the Black Hill with
my family & children, until 1 discovered just out of sight from Hwy
385, several abandoned mine sites, old tools & equipment & very
odd looking dirt, like they just walked away, when the market
price of whatever (uranium/gold - etc.) they were mining fell
below profitability. This was all after the last E.P.A. promises to
not harm the sacred Black Hills. 1 have recent tests of water
flowing from the Black Hills is still contaminated/radiated/ All of
a sudden it's supposed to be all good/credible! 1 don't believe it.
Leave the Hills alone. NO approval
5
Not control over 'bleed production;' manmade disasters;
corporations monitoring corporations; no oversight; abandoned
uranium mines; Can you put your 'Climate Change' site back up?
Actions to address: abrupt climate change involving water; when
will foreign companies be held accountable for restoration of
water, groundwater and aquifers?
6
Email blank
Who is Powertech? Who makes procedures? What is half-life of
constituents going into the deep injection wells?
7
As an educator, 1 support his project. 1 hope that the decision
towards this project listens to the science and realizes that this
moves us closer to a better and cleaner way of using our sacred
earth's resources and can help make our future better for our
future students.
8
1 am a teacher in the Edgemont School District. 1 was born here,
attended school and graduated from here, and have lived here
my entire professional career. 1 do my best to respect the cultural
traditions of all nations. It is a hard decision to choose right and
wrong in disputes of culture and tradition vs. changes. 1 do not
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envy your decision-making. As an educator and an optimist, 1
choose to trust science and the studies that the EPA has
conducted. 1 trust the EPA to make these hard decisions. There is
no easy fix to cultural differences. Science and technology has
changed a lot over the years and will continue to change. It has
improved and will continue to improve. Again, 1 ask you with an
optimistic view to use science to guide your decisions. Thank you
for what you do.
9
1 trust the science and research behind this project. Please move
forward with the project if it is safe and best for our community
and country.
10
The Black Hills have been awarded to the Lakota People by
Supreme Court decision
11
1 am a science teacher and an environmentalist. The uranium
mining is a safe method based on the facts presented. These
decisions should be based on the facts and not on emotions.
Believe in the science and trust the science experts. Good science
is unbiased and this is good science.
12
Name blank
Email blank
There are protestors outside trying to save their land. It is not
your land it is our land.
13
Name blank
Email blank
1 am a resident of Edgemont and have been for several years. 1
have two children and 1 am employed at the Edgemont School. 1
believe the uranium project is an excellent thing and will boost
our economy. 1 fully support this project as 1 believe the check
and balances are in place for safety
14
1 support the science and I'm in favor of this project.
15
1 am a teacher in the Edgemont School District. 1 have lived in the
area for over 24 years. 1 have a strong belief in science and
bettering our world - clean fuel is the way! Please use SCINCE
and a real common sense in your decisions-not illogical
statements and feelings fueled by emotions. Please understand
and use science and not emotions in decisions. Yes to Powertech
and the harvesting of uranium for clean fuel.
16
1 do support this project and can see no reason not to except for
being misled.
17
NO URANIUM!
18
Name blank
Email blank
Have you even been to Evans Plunge? It is a water park. If you
mine the uranium it can poison water so water parks will close.
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19
DO NOT allow Powertech to mine or dispose of waste. There is
no company that will keep our water safe. This company in
particular has no experience and no history of performance.
Throughout the U.S .there has been a tragic history of
environmental threats and leaks. We cannot afford to risk our
future.
20
Stand up to the corporate interests. Water is precious and
unreplaceable. Save the water for our residents; don't pollute it
for generations.
21
If permits are granted we will stop it what ever means necessary.
We will fight...P.S. FUCK YOU
22
We had enough uranium to allow Obama & Clinton to give them
uranium. Our water is a limited resource. 1 don't see any sensible
reason to risk it for foreign interest.
23
My family depend on well water from this area. It's outrageous
that our water safety, and that of future generations, is being put
at risk for short-term gains by a few.
24
No email
1 see no compelling reason or need for uranium mine. 1 have
neither heard nor read about a shortage of or more demand for
uranium. To my mind, the only ones to benefit are the out of
state and out of country companies. Figure out what to do with
the waste we already have.
25
Is Powertech and their owner able to afford cleanup costs" Need
guarantee! Am very concerned about water migration from the
Minnelusa to the Madison,. How does Powertech plan to remove
all particulates and chemicals, heavy metals, etc.? The drilling
presentation charts from Powertech (?) do not show the severe
faulting of the aquifers. Although Powertech is based in Canada,
the main stockholders are Chinese-based. Yellowcake demand
has declined except for proposed nuclear reactor construction in
China.
How about bonding each well (extraction) @ $40,000 per well
and $10+million for the injection wells? How about
payments/royalties for the minerals extracted? What process
does Powertech or Arzarga propose to purify the wastewater?
90% vs 100% (Hollenbeck describes water usage but avoids
discussion of reclamation). If monitoring wells detect
contaminants in the aquifer (which is tilted) how does one stop
the migration? The underground water flows in Jewel Cave
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originates somewhere and flows where? The Madison aquifer
pressures are much lower at the recharge location in the Black
Hills. Are the Minnelusa pressures lower at the recharge level?
Lower than the Madison? Well beyond the perimeters indicated
in the EPA study and Powertech proposal. A small portion of the
Inyan Kara, Madison and Minnelusa area. The Madison aquifer is
used in five states, Water flows where it wants to.
26
Don't grant a permit for extracting uranium. 1 few up close to the
Grand Junction vanadium facility. The tailings there proved to
have radon. They had been used under my relative's house.
Radon causes lung cancer. The tailings had to be removed & my
relatives may get cancer. Our water is at risk. Don't take a chance
with the aquifer. Likely bad pollution will result.
27
1 am strongly opposed to this.
28
1. 1 heard that uranium contamination has been reported in
Angostura. Could you address this question? (Dr. Jim
Stone at SDSMT, Dept Civil & Environmental Engineering)
2. How critical is our need for uranium.
29
The EPA is suDDOsed to Drotect the environment and wild life. In
what part of extracting water to get uranium and then putting
the contaminated water back into the aquifer safe? Our
landscape and wildlife is what makes the Black Hills and
surrounding area beautiful. By poisoning our water, you are
poisoning our plant life, wildlife, crops, cattle, and the people.
Water is our first medicine, and without it there can be not life. It
does not take a lot of common sense to say not to this proposed
project. Please take into consideration AU of the comments
opposing this. Money is not more important than our lives.
30
1 am opposed to the proposed uranium mining in the Black Hills.
We cannot afford to allow this to happen to our land, people,
animals. It is common sense to deny this permit. Do the right
thing - we must protect the water and the future. This is an issue
that crosses all races and boundaries. Please protect us.
31
N/A
After all the hearing. does it even matter to what we think? Are
no not eoine to mine?? Is that is done deal alreadv?? If we all sav
NO?? will you go away?? Who did the big money people already
buy out?? Will you drink the water? After you leave - we will be
here after you all to home. Listen to the people. NO MINING!!
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You're destroying our earth, water, environment. Listen B-4 it's
too late. NO URANIUM MINING.
32
Email blank
Veteran, deployed to Afghanistan & Kyrgyzstan - Kyrgyzstan &
the base water (ground & tap) were contaminated with uranium.
Azarga's holdings are in Kyrgyzstan & the U.S. Kyrgyzstan does
not heavily regulate uranium. Most there don't even know all the
water is contaminated -> crops, animals, drinking water. World
Nuclear Association (world-nuclear.org) discusses this. Business
intelligence-wise "Azarga uranium spills" google search brings up
Azarga's website 3 times & articles of this hearing/project. That is
a controlled search (i.e., Ararga is controlling their media news).
Uranium can stay in bodies (bones & kidneys) for years. It doesn't
always leave visible signs until it is too late. Why now, ,why
expedited by Azarga? Consequences for a quick business deal are
always more costly.
33
N/A
Thank you for providing this public form in which to speak. 1
forgot to mention in my comments that it has been 11 long years
of trying to permit the Dewey-Burdock Project by
Powertech/Azarga. It took years to secure the NRC license., It is
too slow, and 1 fear America today could not even build the
Hoover Dam. With the EPA, multiple state and BLM blessing yet
to come to initiate the Dewey-Burdock Project.; this extreme
slowness is unacceptable and is a huge deterrent for new
projects desiring and probably deserving permission to proceed.
Use common sense, conservation, not radical environmentalism
in determining worthiness of these projects and future projects. 1
heartily recommend approval of the Dewey-Burdock mine. It is
past time for the green pendulum to swing back toward common
sense and let America prosper and advance in the future by
mining God-given resources. Thank you for your consideration.
34
^
NO MINING! The risk to the water is far too great!
35
Am adamantly opposed to any uranium mining in SD.
36
Do Not pollute the water - No uranium? Protect our Lands-
Waters-Habitat
37
1 live within the proposed area. 1 am old, 1 am a landowner. This is
all about the monev. The land, the water is priceless. Monev
cannot bring back the clean water or pristine land. Money is
useless when the water is not good. The land is no good for
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ranching or growing. The power behind the uranium mining is
not even American. It will not create jobs for our people. No one
but the mine owners will make money, and they do not live here.
Our major income is derived from ranching and tourism. If you
approve the permits you will be responsible for destroying our
economy and our lives. It is time for all of us to do the right thing
& this includes the EPA. You can telephone
Thank you
38
President Trump has signed an executive order to "ease
burdensome regulations," gutted the EPA's budget & personnel,
& fired the advisory committee of scientists who will most likely
be replaced with members of industry, whose interests are not
those of the residents who live & work near polluting industries.
Given the current political climate, it is high likely that the few
protections for clean water & regulations for radioactive waste
cleanup will be relaxed or abolished entirely, leaving SD with
contaminated land, water, ill citizens & little legal recourse. A
further implication of Trump's dismantling of the EPA is the
question of policing & inspecting the uranium mining & water
cleanup. If the EPA does not have the funding or staff to inspect,
test, & monitor the wells & water quality, it will be up to SD
taxpayers to pay for monitoring, & it is also highly likely that
inspections will be fewer or less thorough, resulting in
contamination not being discovered & arrested quickly. The
supposed millions of increased tax revenue to the county & the
state resulting from the min will quickly evaporate.
If the EPA cannot guarantee thorough oversight of the mine for
the next 12 years proposed by Powertech, it really should not in
good conscience, approve the permits.
Further, the EPA's 2015 site inspection only sampled surface
water & sediments; if the mine source areas have not been
inspected, how can we know that t the deep in-situ mining, &
previous mining that has already occurred will not further pollute
the entire water table? There is a guaranteed bleed of just under
1% with in-situ mining; it may meet the legal threshold of <3x
background concentrations, but that does not mean this water is
safe for the land, much less potable.
Regarding the aquifer exemption, if the Safe Drinking Water Act
can be readily set aside with an exemption, what is the point of
the Act at all? The entire point the Act is to prevent the types of
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contamination under proposal here. Water in western SD is so
precious & scarce that even if some wells are not used for human
or animal consumption now, that is not to say they will not be
desperately needed in future & should be protected. Especially
since if there are unanticipated malfunctions, natural disasters,
or simple shoddy workmanship that result in cracks in the
aquifers, leaking in the pumping & reclamation process, the
entire water table can be irrevocably contaminated for not just
our lifetimes, but those of our grandchildren's grandchildren. The
only benefits of the Dewey-Burdock project will be realized by
Powertech's China-based parent company; the costs, however,
will be borne by SD's residents; Please reject the mining permits.
30
The history of mining in the Black Hills includes corporations that
have dissolved and left the American taxpayers to foot the bill of
cleanup - Brohm caused a superfund site at the Gilt Edge Mine,
Susquehanna & its subsidiaries left TVA & the U.S. Dept of Energy
to cover the costs of cleanup associated with the mines and mill
at Edgemont, There is still cleanup of abandoned mines that have
not done because the area are on private land. 1 would ask that
you enter the five series of articles the Rapid City Journal
published (available at
htto://raDidcitviournal.com/aDD/Dages/uranium) into the record
for information on the history of uranium mining at Edgemont,
including Dewey-Burdock.
40
mm
1 am against uranium mining. We need to protect our waters. We
cannot stand to lose any of our aquifers. We need to protect our
land & environment.
41
As a father & teacher that lives near the Black Hills 1 am strongly
opposed to uranium mining here. 1 remain unconvinced as to the
safety of this project. Additionally 1 believe the Black Hills are
rightfully the land of the Lakota & should be returned. Honor the
Treaties.
42
Capitalism will be the death of the environment.
43
1 listened to Powertech and their plan to monitor contamination.
1 do not believe they can do what they say they can. 1 do not
believe that the contamination cab be contained in one area.
There are too many porous areas, cracks, fissures, caves. We get
our water from a well. The underground water is a treasure and a
necessity for our life. The southern part of the Black Hill's water
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needs to be protected. The EPA should be protecting us form the
many corporations that would take advantage of our resources
and use our area as their toxic waste dump. Do not allow this
permit or any others for Powertech. Kendra Wright 5/9/17
44
In 1979, we the people of SD passed an initiative into law that
states that anyone who wants to mine uranium in SD has to go to
a statewide vote for a license. Has that happened?
45
Do not drill for uranium in SD. It is harmful to the people.
46
EPA-Environmental Protection Agency
Please do your job and protect the environment - that means no
polluting. This project pollutes! Say No!
47
1 am a mother of three and a farmer in Allen, SD on the Pine
Ridge Indian Reservation. 1 am standing in opposition to the
proposed Dewey-Burdock uranium mining project. It has been
proven through history that uranium mining has disastrous
consequences to human health. And it has to be said and cannot
be ignored that the United States Government has used control
and contamination the water supply to contain and exterminate
the Lakota people for generations. If the US Government has a
shred of integrity left, it will put a stop to the Dewey-Burdock
Uranium Project and any future proposed uranium drilling
projects in the Black Hills. Thank you
48
1 am against the mining discharge into the water supply. We have
so little water out here as it is, and we do not want toxins
discharged into our water, especially for those who benefit
without having any relationship to western South Dakota. You
are dumping your externalities(?) on us.
49
NO URANIUM
50
1 would appreciate being kept up to date with the decision that
are being made that the potential to affect, not only this
generation, but also genetically, many generations to come.
51
No Uranium Mining!!!
52
1. Do a complete analysis of abandoned uranium mines, to
evaluate potential and current impacts to the
environment, to the water, to wildlife, and to humans.
Clean up the existing abandoned sites. Prove that it can
be restored. Show and share all the process and data.
2. Deny the exemption, deny the injection, deny the
mining. The water cannot be restored. NRC can draft
-------
requirements, but cannot ensure restoration. Do not use
any water for extraction.
Protect our water. Protect our wildlife. Protect our
people-future.
Educate all on how harmful this process is to our future.
Educate on reusable energies and renewables. Do not
use uranium.
53
Email Blank
No uranium mining. No deep disposal of waste. We need clean
drinking water please. Thank your.
54
Please listen to the many united voices of all colors & all faiths,
who are against the permit to Azarga/Powertech for the Dewey-
Burdock uranium mine. The Lakota people cry for the water -
Mni Wiconi - water is life. An international company should not
come before the wishes of U.S. residents.
55
m
Just because there are not many people out here - does that
mean we have to be a dumping spot for hazardous waste?
56
We're gonna all be walking dead soon enuf, esp. if we drink sick
water.
57
none
There haven't been any speakers who support the proposed
mining. So why should it be done? If it is approved, it is for
money only at the expense of all life? Cleanup is impossible. No
mining please/
58
Email blank
1 feel that our water needs to be clean. 1 am not wanting mining.
We need clean water. Please don't do any mining. Thank you.
Jeff Iron Cloud
59
1 am opposed to the UIC Draft Area Permits and the one
associated proposed aquifer exemption decision for the
Edgemont site. 1 am also opposed to wells to dispose of waste
fluids into the Minnelusa Formation after treatment. 1 am
opposed to any aquifer exemption approval related to the Class
III permit application. 1 oppose the injection of lixiviant into the
Inyan Kara aquifers. 1 want these to continue to be protected
against contamination provided under the Safe Drinking Water
Act. 1 oppose Powertech plans to use groundwater to replace the
groundwater removed from the Inyan Kara aquifers. Sincerely,
Ebun Adelona
60
none
Radon daughter remediation?
Security of storage and transport of yellowcake.
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61
Big problem with one well in Wasa but no problem with
hundreds of wells in Provo area?
62
EPA & other scientific studies can only go so far to predict results.
No one knows what shifts in the earth structure might lie ahead.
As a country, we are slow to learn from history. Our water is too
precious to experiment with.
63
Let me get this straight - For a few temporary jobs we risk losing
our most precious resource? Worldwide there are problems due
to tracking. Haven't you learned a thing? Follow the money!!
Do not force us to move away from the beautiful Black Hills if you
contaminate our water.
64
If Powertech owners in China and you give these permits and
Powertech granted, then these get sent to China. Then China can
sell this uranium to North Korea. Then North Korea can turn this
into bomb, send it back over here and blow us up.
65
How much of this uranium stay in the US? If this is a Chinese Co.
- do they sell to N. Korea. Japan bought up our scrap steel prior
to WWII. Also my well is in the Minnelusa aquifer. 1 would like to
keep it pure.
66
1 am here in opposition of the uranium mine & waste disposal
wells. My letter with detailed position is coming in the mail.
67
NO! NO! NO! 1 am a republican and say NO! No risk to water-
none. It is too precious here - delicate geology. We the people
have a say!
68
N/A
1 believe there are plenty of other uranium rich places that would
not harm a place as beautiful as the Black Hills.
69
N/A
-NO- We do not need this to happen, believe it will only hurt the
land and water & us! -NO-
70
no protection
71
NO URANIUM MINING AT DEWEY BURDOCK IN THE BLACK HILLS
OF S.D! NOT NOW, NOT EVER.
72
NO uranium mining in the Black Hills! As an indigenous woman, a
human being and giver of life, 1 am comoletelv against uranium
mining in the Black Hills. Not only will this poison the water, this
does great destruction to my home, my birth place and many of
our sacred sites. 1 want a sustainable and healthy future for my
children. Uranium mining hurts everyone's future!
73
As stated in literature & facts - there is NO guarantee of safe
potable water. Too many lives & livelihoods are at stake to take a
-------
chance. No amount of money (for the clean-ups or buy-offs) is
worth any of this bull-crap!
74
The potential damage to our aquifers is too great to let this
project continue. The worldwide shift should be away from Nuke
plants for energy. It is unsafe and potential problems can be
disastrous, citing Chernobyl & Three Mile Island.
75
No uranium dumping in our area or anywhere in the mid-west.
We have to take care of Mother Earth for use by generations to
come. The Lakota medicine wheel has four parts. They are each a
different color and represent a race of people and their purpose.
The east is yellow, representing Asian and/or Oriental people
who are responsible for spirituality. The south is white,
representing Caucasian people who are responsible for the
physical self or going inward to find self. The west is black for
African Americans who are responsible for the emotional or
psychological and the water. The north is the color red, for
Native Americans who are responsible for the land and the
mental aspect of life. Caring for Mother Earth.
76
m
1 am an old guy and 1 am tired of "experts" saying don't worry we
know what we are doing and them 5-10-15-20-25 years
later woops, this is a problem, what now?
77
Against in situ mining because of water quality and geologic
stability issues. Against uranium mining because of pollution
issues - dangerous material! Also not needed as alternative
energy is developing.
78
NO permit for uranium mining should be granted & certainly not
before all previous mines have been cleaned up! Have genuine
consultation with the tribes and tribal approved archaeological
and cultural surveys!
79
They keep saying this is for economic good, jobs etc. Back in the
40s & 50s they said electricity would be so cheap they wouldn't
bother to meter it, that hasn't happened and they have made a
mess. Around the world a poaier(?) is dying.
80
Email blank
We want to have pure water no contamination
81
There is no way you can give a 100% guarantee that nothing bad
will happen to the water. If this goes through, you will mine, take
you money, and then leave. Local residents will be left holding
the bag. Will there be seismic events with the pumping like there
is with fracking? What will climate change do to the supply of
-------
water in the future? Population changes will change the need for
water. This does not seem like a good business decision so 1
wonder what else might be in store if this venture doesn't work
out. Is this going to be like the Hanford site in WA state, (1 known
it's not that type of waste) where a generation or so people will
look back on now and think "what morons." This will not affect
me or any of my family, but I'm concerned for the others who
will be affected.
82
Why the use of water? If this proposed area was next to Rapid
City would it still get the green light from EPA? There needs to be
a cleanup plan for each drilling.
83
Please explain why a mill tailings pile must be sequestered
forever to prevent leaching into the groundwater, yet it's
acceptable to create the same pile inside the aquifer.
84
100% against uranium mining in the Black Hills. Not worth it! No
amount of S is!
85
IF groundwater is contaminated - what does the "clean-up"
process entail? It's a given that water quality will be "monitored"
with what is done to clean up the mess? How long from the time
"contamination" is detected till mining is stopped?
86
1 am against the permits of any kind and any numbers given to
any company that would by any means endanger the land, air
and water to contaminate anything in South Dakota, the World,
or persons of Fall River County. 1 moved here from Ohio to
improve my health, which has happened, no longer on numerous
pain medication or need of a brace. Please do not allow permits
for mining uranium in Edgemont, stop and do not permit
incoming contaminated products into Edgemont from other
states. Thank you!
-------
May 9, 201?
To Whom This May Concern:
I am writing to express my grave concerns in allowing Arzaga to receive a permit to mine in our precious,
sacred Black Hills. Water is a precious resource that belongs to all of us and needs our protection.
State regulations do not duplicate federal regulations. Our state regulations are more detailed and tailored to
our area. They require ongoing monitoring for safety, notification of state officials in case of an accident (and
accidents are common in this industry), insure that in situ mine facilities are built according to strict safety
standards, and insure that mine sites are cleaned up properly. Uranium mining pollutes groundwater. While
the water in a uranium deposit may have high levels of uranium, the surrounding groundwater may be
good quality. In fact, six dozen wells are found directly in the aquifer a company wants to mine in the southern
Black Hills - and within 1-1/4 miles of the planned mine site. Many of these wells are used for livestock and for
homes, and they need protection.
The South Dakota Department of Environment and Natural Resources has a responsibility to regulate the local
mining permit process. Federal government offices are hundreds of miles away. This is why this uranium
company wanted to stop state regulation and push for federal approvals.
Arzaga (formerly Powertech), is an international uranium company and this permit would benefit a foreign
corporation at the expense of South Dakota residents. A mistake was previously made to allow uranium mining
in our state. We do not want this to happen again. This company is on very shaky financial footing. Do we want
this company to dictate the rules for doing business in South Dakota? Will the federal government pay for the
cost of cleaning up the areas that will most likely be affected? We do not want to take that chance.
The Black Hills are a special place to all of us. Water is sacred to all of us. The Lakota people say, mni wiconi
- water is life. Water is our first medicine and common sense should prevail in this water protection issue.
Please deny this permit.
Pilamiyaye. Thank you for listening to the people.
Sincerely,
-------
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-------
Hello members of this hearing on the proposed mining and dumping site in the Dewey Burdock
area. Thank you for givining me this time to express my concerns with the mining and dumping
proposal.
My name , I hold a Bachelors of Science degree from Black Hills State University,
and I am opposed to the EPA granting any license to not only mine uranium but also to permit
dumping of toxic waste into the Minilusa aquafer or any place here in the Black Hills or the world
for that matter.
Your reports claim that there is no potable water in the Minilusa aquifer is untrue, if what our well
driller told us about our well over 20 years ago, here in the outskirts of Hot Springs which was,
was water from the Minilusa aquifer and more importantly that our water from the well was
deemed the best in the county when tested, then I have a major concern about your proposed
license to mine and dump toxic and radioactive waste into any aquifer. We have been living on
this water for many years and it taste delicious. Our live stock, plants and anything living on our
property benefits from this clean nourishing water.
Members of this hearing, we all are living in a symbiotic relationship with all living beings on this
planet, be it microscopic or macroscopic. Our actions have an effect on all. it is important that
any action made should benefit all. not just the majority or not just the the minority, but all
concerned. Any decision to pollute the water, anymore than you claim it already is, will affect
the balance of life on this planet. You can not control radioactive material which typically has a
half life of 4.5 billion years and there are many such sites that have failed and lead to birth
defects and illness in humans and animals alike.
After reading research of hazardous waste water purification treatments and the effect of Heavy
metal salts and other hazardous chemicals on biological systems from Linsey McLean, I teamed
that Heavy metal poisoning affects the the hormonal balance by not only acting as hormone
disruptors but also creating xenohormones which can and does lead to cancers and other
severe illnesses.
Water is essential to all living organisms and should be protected not polluted. If you allow any
dumping of toxic and radioactive waste here int he Black Hills or anywhere you will have to
endure the Karma for such actions. The law of karma is exacting and no one has the right to
pollute the water in which we all must partake in to survive.
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Good Afternoon, Your Honor and Ms. Shea,
Thank you for the opportunity to make a statement here today in support of the
draft permits and in support of the Dewey-Burdock Project,
My name
i am here to present you with a copy of this Resolution of Support for the Dewey-
Burdock Project from Argentine Township,
My bet is that not one of the opponents who spoke at the other hearings this
week have even heard of Argentine Township. But 1 can tell you it is the MOST
IMPORTANT name you will hear this week.
You see, much of the Dewey-Burdock ISR project is located on and below
Argentine Township.
It is where we live and ranch. We and our families depend on the groundwater for
our livelihood and everyday life.
If anyone's livelihood or quality of life were at risk with this project, it would be
us.
There is not a single person who has ever testified who has more at stake than
us and WE SUPPORT the licensing, construction and operation of the Dewev-
Burdock Project.
As property owners, we have RIGHTS as well as a vested interest being good
stewards of our land and respecting the property rights of others. I've lived my
whole life here and taken good care of my property and will continue to do so
during ISR operations and long after the project has been completed.
Before I close, there is one more issue I'd like to address and that is regarding
Powertech, the company. While opponents have done their best to denigrate
them, I'd like you to know that the Powertech folks I've met over the years have
been good, honest people.
I especially want you to know about Mark Hollenbeck, the Dewey-Burdock project
manager. I grew up with Mark. He's is my neighbor and my friend. He is honest
and trustworthy. He's a topnotch engineer, a community leader and a nice guy.
The land, the water and the quality of life here is foremost to him and his family
and I have no doubt that his support of the project is based on science and fact. I
trust him and I trust that this project will be good for our area.
-------
ARGENTINE TOWNSHIP; SOUTH DAKOTA
RESOLUTION OF SUPPORT FOR
POWERTECH (USA) INC. DEWEY-BURDOCK URANIUM PROJECT
WHEREAS Powertech desires to extract uranium utilizing the in situ recovery method from ore bodies located
under the land owned by the residents of Argentine Township; and
WHEREAS this is the land where we ranch and depend on groundwater for our livelihood; and
WHEREAS we, along with our families, live here and depend on groundwater for everyday life; and
WHEREAS our research indicates the Dewey-Burdock Project has been analyzed by knowledgeable
independent parties and demonstrates safe and environmentally sound capacity to be mined such that it
meets the requirements of South Dakota and Federal oversight agencies; and
WHEREAS mining activities that occur at the Dewey-Burdock Project will be strictly regulated and overseen by
the State of South Dakota, the U.S. Nuclear Regulatory Commission and the U.S. Environmental Protection
Agency so as to protect our families' health, our livelihoods, the environment and most all, the water
resources we use for ranching and our families' personal use.
NOW THEREFORE BE IT RESOLVED that the Argentine Township supports and encourages the
granting of state and federal licenses and permits to Powertech (USA) Inc. to commence in
situ uranium recovery activities on our land at the Dewey-Burdock Project in South Dakota,
Date: 3
Date: C'jfal
Date: froVl?
Date:
Argentine Township Board of Directors
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May 10, 2017
My name We own and operate a cattle ranch in eastern Fall River
County.
We are against the proposed mining and injection wells in the Dewey-Burdock
area.
The water for our ranch comes from the Madison Aquifer by way of pipeline. We
cannot afford to take a chance on polluting the water that sustains our livelihood.
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Fall River Conservation District; 341S Chicago Street; Hot Springs SD 57747;
605-745-5716 extension 121
May 10, 2017
My name is^^BIIIH'am the Chairman of the board of directors for the Fall River
Conservation District, As a conservation organization, we are strongly opposed to the proposed
uranium mining and injection wells at the site of the Dewey Burdock project near Edgemont,
SD.
Conservation District Boards are mandated to protect the land, air and water quality. Because
of this, the Fall River Conservation District board of directors wrote a resolution that went on to
become the State of South Dakota's House Concurrent Resolution number 1025. This resolution
reaffirms the value of South Dakota's groundwater resources and recognizes the need for
ongoing evaluation of our groundwater management. This resolution in its entirety is attached
to this statement.
This uranium and injection well project could have disastrous effects on the lives and economy
of all the people of Fall River County. There are too many unanswered questions about this
project; such as possible earthquakes and contamination of the Minnelusa and Inyan Kara
aquifers. These two major aquifers supply water to at least 125 private wells, providing
essential water to families and livestock. Chemical waste contamination would prove
devastating to the many people who rely on the Minnelusa and Inyan Kara aquifers.
In addition, the heavy truck traffic that is essential for a mining project will be very damaging to
the road system of the county. This would cost the county and taxpayers extra dollars that it
simply does not have for road repairs and maintenance.
The population of this county cannot afford the mistakes that could come with this project. The
lack of clean, usable water could easily turn our towns in to ghost towns and productive range
land into waste lands. We need to protect our water sources for the well-being of all livestock,
wild life and human life.
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State of South Dakota
EIGHTY-NINTH SESSION
LEGISLATIVE ASSEMBLY, 2014
543V0824
HOUSE CONCURRENT RESOLUTION NO. 1025
Introduced by;
1
2
3
4
5
6
?
8
9
10
11
12
13
14
15
A CONCURRENT RESOLUTION, Reaffirming the value of South Dakota's groundwater
resources and recognizing the need for ongoing evaluation of our groundwater management.
WHEREAS, groundwater is a resource of immeasurable value to public health and welfare;
and
WHEREAS, it is the public policy of this state to conserve the waters of the state and to
protect, maintain, and improve the quality thereof for water supplies; for the propagation of
wildlife, fish, and aquatic life; and for domestic, agricultural, industrial, recreational, and other
legitimate uses; and
WHEREAS, it is the public policy of this state to provide that no waste be discharged into
any waters of the state without first receiving the necessary treatment or other corrective action
to protect the legitimate and beneficial uses of such waters; and
WHEREAS, it is the public policy of this state to provide for the prevention, abatement, and
control of new and existing water pollution; and
WHEREAS, the State of South Dakota has limited groundwater resources, and any impact
to such resources may be detrimental and permanent; and
170 copies were printed on recycled paper by the South Dakota Insertions into existing statutes are indicated by underscore;
Legislative Research Council at a cost of $.098 per page.
Deletions torn existing statutes are indicated by wwtrito.
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-2- HCR1025
WHEREAS, technology changes rapidly and technological development in all of South
Dakota's industries changes the way in which our groundwater is used:
NOW, THEREFORE, BE IT RESOLVED, by the House of Representatives of the Eighty-
Ninth Legislature of the State of South Dakota, the Senate concurring therein, that the value of
our groundwater resources is reaffirmed; and
BE IT FURTHER RESOLVED, that this Legislature recognizes the need for ongoing
evaluation of our groundwater management based on rapidly changing technology and the
impacts of technological advances on our groundwater resources.
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Valois Shea
U.S. EPA Region 8
Mail Code: 8WP-SUI
1595 Wvnkoop Street
Denver, CO. 80202-1129
Recent history has made it clear that our government does not have adequate systems Id place to keep
uranium mining companies accountable for how their projects negatively impact the public.
Why should we approve a project that is going to benefit a few financially in exchange for irreparable
damage to water supplies, untold suffering from the health impacts of radioactive coniaminaiion, and
the resulting expensive healthcare costs shouldered by both individuals and by the community?
There are still old uranium mines in the Dewey-Burdock area that haven't been fully reclaimed. We
need to see that old mines in our community will be cleaned up before we permit new ones.
There are many other reasons to not allow this permit, but for me the most compelling is the fact that
he mine and deep disposal wells is cannot be completely contained and will very likely impact our
water supplies. The proposed area is documented to have faults, fractures, breccia pipes, and over 7000
old boreholes that have not been properly plugged.
Thank you for considering the needs of the whole community. I have two children I am raising in this
community and I am concerned about their future and the future of all of my neighbors and all of the
surrounding communities in the Black Hills. This project will not benefit us, and it will do irreparable
damage.
Sincerely,
RECEIVED MAY 1 9 2017
-------
lb
May 9, 2017
To: U.S. EPA Region 8
1595 Wynkoop Street
Denver, Colorado 80202-1129
Re: Permits for uranium mining and deposit of mining waste liquids in the southern Black Hills
Hello.
This letter is from a concerned resident of this area. 1 l ive at the home of my sister on Lariat Road, situated in
Custer County, as shown on the map below. I've attended public information presentations and investigated the
history of the uranium mining operations. Given the mining industry's past infractions of environmental
safeguards, it appears that our well is at risk of contamination if the company is granted the permits to proceed.
For instance, according to one report, between 2008-2010 there were 60,467 wells with violations. Uranium
leakage poses a serious irreparable hazard to our health. Water is essential to life and needs to be protected.
Here is the location of our Canyon Calm home, where the health of livestock, children and adults is at risk if the
mining is allowed to proceed.
GD
Sanator
Prlngle (j
©
Burdock
© He
•CANYOfJCalm ,,V;
<§>
Got gle EdQemom
Custer County
South Dakota, USA
Thank you for respecting this educated request.
e
-------
by HHH
EPA Scheduled Public Meetings, 05/08/10 and 05/09/17 Rapid City SD, 05/10/17 Hot Springs SD, and
05/11/17 Edgemont SD.
RE: Two Underground injection Control (UIC) Draft Area Permits, and one associated Proposed Aquifer
Exemption Decision for the Dewey-Burdock Uranium In-Situ Recovery (ISR) Site located near Edgemont,
South Dakota under the Authority of the Safe Drinking Water Act and UIC Program Regulations in
connection with the Class III Area Permit to exempt the uranium bearing portions of the Inyan Kara
Group Aquifers.
Note - Powertech is now owned by AZARGA. I have used Powertech and/or AZARGA-Powertech in my
document.
Fellow Public Attendees and EPA representatives,
I, ¦¦¦ from Englewood Colorado, stand here today to loudly and clearly oppose the
proposed Aquifer Exemption decision for the Dewey-Burdock uranium in-situ recovery (ISR) site located
near Edgemont, South Dakota under the Authority of the Safe Drinking Water Act and UIC program
regulations in connection with the Class III area permit to exempt the uranium barring portions of the
Inyan Kara Group Aquifers.
The EPA has proven itself to have devolved into nothing more than an 8 billion dollar agency dedicated
to supporting and promoting EXEMPTIONS for the very industries that continue to cause massive
environmental contamination - the legacy of which is left to the local residents for generations.
AT ISSUE - The portions of the Inyan Kara Group aquifers the EPA proposes to exempt have historically
been used as a source of drinking water, are currently used as a source of drinking water, and can be a
future source of drinking water.
EPA's current Title 40146.4 declares "The proposed aquifer exemption area must not be a current or
future source of drinking water using the criteria at 40 CFR146.4".
This latest grotesque and alarming action by the EPA to propose exemption of these portions of the
Inyan Kara Group aquifers blatantly ignores the existing original EPA aquifer exemption criteria found
In Title 40146.4, and sets a disastrous new precedence for opening up our ever more scarce and
precious life sustaining clean water Aquifers that can be use
-------
"future source of drinking water" protection will be eliminated by this precedent setting Aquifer
Exemption.
Currently there are multiple wells drawn from the targeted portions of the Inyan Kara Group Aquifers
that were historically and currently used for both human and livestock consumption. Many of these
residences are currently abandoned and therefore the EPA and AZARGA-Powerteck can say are not
currently using the water for drinking water. But at least one residence continues to use well water (well
16) from this targeted portion of the Aquifer. To create a "no current use status" from which the EPA
and AZARGA-Powerteck are trying to base this AE Proposal, Powerteck promised to permanently
provide the resident with bottled water for drinking if they agreed to let Powerteck severe and seal off
the water line from the well to the home. The resident agreed and the water line from the well to the
house was severed and sealed. However, well 16 water continues to be used for this resident's livestock
- Which under SD laws is still considered the same as well water used for human consumption - A fact
that the EPA is also willing to ignore!
But this was sufficient for the EPA to approve consideration for the proposed Aquifer Exemption
concluding their 11/17/16 Memorandum;
"Based on the CZA calculations, the EPA has concluded that the portions of the Inyan Kara aquifers
proposed for exemption 'do not currently serve' as a source of drinking water." <
/3>t -**1 S/et-//7 A. Am--Ot? fy UJMJ /£ ,
I publicly denounce this current effort by the EPA, and I demand that the EPA follow its own laws and
Environmental Protection mandate and not approve this Inyan Kara Aquifer group for exemption,
because in fact this Inyan Kara Aquifer Group is indeed a "current and future source of drinking water"
that requires an mandates protection!
I wish to state two additional alarming facts;
What the EPA also won't tell you is that uranium in-situ recovery mining has consistently resulted in
contamination. And per the US Geological Survey (USGS), to date there has been no successful
mitigation of the contamination resulting from uranium in-situ recovery mining. So your current status
of future source of drinking water will be permanently lost if this exemption is approved.
What the EPA has also not disclosed to local residents is that once approved, the class III underground
injection disposal wells approved for uranium mining waste water disposal will also be made available
for injection disposal of other radioactive waste fluids from other sources such as Municipal water
treatment plants well past when uranium mining activities stop.
Thank you,
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Denver earthquakes 40 years ago were
caused by Uncle Sam, not Mother Nature
BY PATOCtA CALHOUN \Wl!f$®W,ltMJ$f24,2®l(M 6=51 Mi
s 1 « Aa
Despite yesterday's earthquake that hrt (he Trinidad region, 'Colorado Is
considered a rogion of minor earthquake activity,* according to Ilia U-S.
Geologlent Survey. But forty years ago, a .series of quakes rocked the Denver
area -- quakes caused not by Mother Nature, but by Uncle Sam.
How? The Array was dumping dangerous chemicals itiu, a deep injection well
out al the Rocky Mountain Arsennl
The Hoek\ Mountain Arsenal was created out of farmland on tbe eastern edge of
metro Denver during World War II to arm the US. Array, After the war, it
( —|x>rame a bustling center of industrial activity — a top-secret center thai created
¦ ¦' n lot i!| dangerous waste.
j ,\i f." (J\:\ V ¦ V U C u,V^ 1 IcM^I 17
http://www.westword.cora/eews/deiiver-eartliciuakes-40-years-ago-were-caiiscd-by-iificte-sa.
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Here's the hi>t->rv of (Ik Arsenal quakes lr> >tn die
8 -* In 1961, a 12,000-foot well was drilled at the Rocky Mountain Arsenal,
_ - L{1. v northeast of Denver, for disposing of waste fluids from Arsenal operations,
. % . Injection was commenced March 1962, and an unusual series of earthquakes
! j 1 p v \ erupted in the area shortly after.
It was 32 minutes after 4 am on April 24 when the first shock, of the Denver
series was recorded at the Cecil H. Green Geophysical Observatory at Bergen
rl f t Park, Colorado, Rated magnitude 1.5, it was not strong enough to be felt by
, ei \i" area residents. By the end of December 1962,100 earthquakes had occurred,
' * Several were fell, but none caused damage until the window breaker that
surprised Dupont and lrondale on the night of December 4 The shock
- — — . —shuffled furniture araundJnJbomes. anjjeft electrical wall outlets hangingby
iat Irondaie.
Over l»300yearllic|«,akes were recorded at Bergen Park between January 1963
-*AJwglist 0,196?. Three shocks in 19&5 - February 16, September 2S» and
-•-j November 20 — caused intensity Vt damage in Commerce City and environs,
1 , The Denver series was forgotten, however temporarily, in October 1068,
t. »; when a southeast Colorado tremor rocked a 15,000 square-mile area of thai
1 j(. fState and bordering New Mexico. Minor damage, in the form of broken
* 1 v windows and dishes arytarsekegi walls and plaster, occurred at Aguilar,
Segundo, Trinchera, ar
t- V
'41# f J
Another strong shock rmmm through the Denver area on November 14,
1988, causing some damage at Commerce City and Eastlake. Slighter
rumblings (below magnitude 3.0) occurred throughout the remainder of
1966, and through the first week of April 1967.
Then, on April 10. the largest since the series hegan in 1962 occurred; 118
,4 windowpanes were broken in buildings at the Rocky Mountain Arsenal, a
crack III an asphalt parking lot was noted in the Derby area, and schools were
,« . . . - dismissed in Boulder, where walls sustained cracks. Legislators quickly
, ¦ * \ d* , moved from beneath chandeliers in the Denver Capitoi Building, fearing they
/<. v * * might fail. The Colorado School of Mines rated this shock magnitude 5.0.
Boulder sustained minor damage to walls and acoustical tile ceilings on April
27,1967, as result of a magnitude 4.4 earthquake. Then a year and half after
the Rocky Mountain Arsenal waste dumping practice stopped, the strongest
and most widely felt shock in Denver's history struck that area an August 9,
v }' > 1967, at 6:25 in the momtng, The magnitude SJ tremor caused the most
serious damage at Northglenn, where concrete pillar supports to a church
n roof were weakened, and 20 windows were broken. An acoustical ceiling and
light fixtures fell at one school Many homeowners reported wail, ceiling,
floor, patio, sidewalk, and foundation cracks. Several reported basement
floors separated from walls. Extremely loud, explosivelike earth noises were
heard. Damage on a lesser scale occurred throughout the area.
During November 1967, the Denver region was shaken by five moderate
earthquakes. Two early morning shocks occurred November 14, They
awakened many residents, but were not widely felt. A similar shock,
magnitude 4,1, centered in the Denver area November 15. Residents were
generally .shaken, but no damage was sustained. A local shock awakened a
few persons in Commerce City November 25, Houses creaked and objects
rattled during this magnitude 2.1 earthquake.
The second largest earthquake in the Denver series occurred on November
26,1967, The magnitude 52 event caused widespread minor damage In the
suburban areas of northeast Denver. Many residents ref
strongest earthquake they had ever experienced. It was felfitt Laramie,'
Wyoming, to the northwest, east to Goodland, Kansas, and sbulfe to giietfto,
Colorado. At Commerce Qty merchandise fell in several stipermaSSs and
walls cracked in larger buildings. Several persons scurried into the streets
when buildings started shaking back and forth.
During 1968, ten slight shocks were felt in Colorado, Only one. oh July 15,
caused minor damage at Commerce City. In September of that year, the Army
began removing fluid from the Arsenal well at a very slow rate, in hope that
earthquake activity would lessen. The program consisted of four tests
between September 3 and October 28, Many slight shocks occurred near the
well during this period.
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In its own account of the cleanup at the Rocky Mountain Arsenal, the V; >
offers this explanation:
Deep well injection for liquid waste has beer,
•..ifcly used for many ye,us at sites
throughout the United States without
documented damage to human health or I he
environment. After an extensive study of
deep injection wells across the country by the
> U.S. Environmental Protection Agency (EPA),
il was concluded thai this procedure is
effective and protective of the environment.
The Rocky Mountain Arscii.il deep injection
well was constructed in 1961, and was drilled
to a depth of 12.045 feet. The well was cased
and sealed to a depth of 11,975 feel, with the
remaining 70 feet left as an open hole for the
injection of Basin K liquids. For testing
purposes, the well was injected with
approximately 5(58,000 gallons of city water
prior to injecting any waste. However, when the Basin I" liquids were actually
introduced, the process required more lime than anticipated to complete
because of the impermeability of the rock. Hie end result was approximately
185 million gallons of Basin F liquid waste being injected into the well during
the period from 1962 through 1986,
The waste fluid chemistry is not known precisely. However, the At my
estimates that the waste was a more dilute version of the Basin F liquid which
is now being incinerated Current Basin F liquid consists of very salty water
that includes some metals, chlorides, wastewater and toxic organics From
1962 — 1963, the fluids were pumped from Basin Pinto the well. From 1964 ••
1968, waste was removed from an Isolated section of Basin P and was
combined with waste from a prc-lrcntment plant, located near Basin P, and
then pumped into the well Hie waste from the pre-treatment plant was
generally a solution containing 13,000 parts per million sodium chloride
(salt), with a pi I ranging from 3.5 to 115. The organic content of the solution
was high but is largely unknown.
The injected fluids had very little potential for reaching the surface or useable
groundwater supply since the injection point had 11,900 feet of rock above, ti _
, < atitf-was sealed at the opening. The Army discontinued use of the writ tp Feb
( 1966 because of the possibility that the fluid injection was triggering 1
- ^arfht^akes in the area. The well remained unused for nearly 20 years,
In 198§ lhe Armf permanently sealed the disposal well in stages. First, the
x wdlcas-ing was tested to evaluate its integrity. Any detected voids behind the
easing were cemented to prevent possible contamination of other formations.
Ncxl, the injection zone at the bottom 70 feet of the well was closed by
plugging with cement. Additional cement barriers were placed inside the
casing across zones that could access water-bearing formations (aquifers).
The fitt.il step was adding Benlonite, a heavy clay mud that later solidified, to
close the rest of the hole up to the ground surface.
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CShmony May &/ 20\J
I dont believe that ISL uranium mining is a beneficial use of our
groundwater or that disposal of wastewater via land application or in Class
V disposal wells is in the public interest. I am not a hydrogeologist or
geochemisi However f can and do read scientific research and three
areas of the proposed project concern me:
-The fate of contaminated mine waste materials,
-Aquifer restoration following ISL uranium mining.
-Our choice of uranium as an energy source.
My first concern is the fate of the toxic waste produced by ISL uranium
mining.
According to the Powertech Ground Water Discharge Permit Application,
(section 3.7.1.2), the proposed perimeter of operational pollution lies at the
base of the Beaver Creek Basin and the Pass Creek sub-basin,
watersheds that drain approx. 1,400 square miles. Three miles
downstream, these basins empty into the Cheyenne River. I believe that
what happens in one part of a watershed can affect everyone who lives
within the basin.
In the description of "land application water properties" (section 5.8)
wastewater will be treated with ion exchange for uranium removal followed
by radium removal through co-precipitation with barium sulfate in radium
settling ponds. There is mention of leak detection systems in these ponds,
but no plan for repairing these leaks. Radium is a dangerous waste
material and little information is provided about how it will be handled.
The proposed well fields are located approx. 2 miles southeast of a large
fault. I've witnessed the consequences of an excursion of contaminated
groundwater along a fault near Nemo, SD, where I live. This excursion
event was only discovered some 20 years after the contaminant was
disposed of. Costs for water transport and water treatment were
considered to be too high and the community has relied on a single, remote
well for the past 15 years.
(Contaminant Survey and Site Characterization Report; Executive Report,
USDA Forest Service Nemo Work Center, Nemo.SD September 3,1997.)
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I believe that Powertech is overconfident in stating that they will simply
"pump back" any excursions of lixiviant that occur.
The contaminated mine wastewater disposal method has not been
finalized. Powertech's preferred disposal method is injection of treated
wastewater into 4 to 8 Class V deep disposal wells drilled into the
Minnelusa and/or Deadwood formations. They have stated they will
perform the necessary feasibility tests for this method only AFTER the EPA
has issued the permit for the Class V deep disposal wells,
(Powertech report on the Inyan Kara and Madison Water Rights Permit
applications.)
I am concerned that even if a monitoring plan seems adequate, there is
significant potential for surface leaks, accidental spills, well casing failures
and excursions of production and wastewater. Government responsibility
for permitting and oversight is fragmented. The high cost of reclamation
has often fallen on the taxpayer in the fong run. This project cannot be in
the public interest.
(According to the 2002 USGS Atlas of Water Resources in the Black Hills
Area: "Human influences have the potential to degrade water quality for
both ground water and surface water. For ground water, the potential for
contamination can be large. For surface water, various land-use practices
can affect water quality. Two Superfund sites have been listed in the BH
area primarily related to concentrations of various trace elements resulting
from mining activities*1.)
My second concern has to do with the aquifer restoration plan.
According to the Powertech report on both the Inyan Kara and Madison
Water Rights Permit applications:
Powertech proposes to restore the contaminated aquifers by treating water
pumped .from production wells using reverse osmosis membranes under
high pressure, thus removing 90% of dissolved constituents. Restored
water will then be returned to injection wells and the RO reject (brine) will
be disposed of in Class V wells,
Powertech has concluded that minimal benefit, if any, is derived from the
groundwater sweep prior to deep well infection and suggests eliminating
groundwater sweep as an unnecessary, ineffective and consumptive step in
the restoration process.
(Section 6.2.2.2 of the Powertech Scale Mine permit application)
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According to the EPA "High pressure reverse osmosis can only be
employed after groundwater sweeping, because the high concentration of
contaminants during the initial stages of the restoration process tend to
disrupt the RO membranes".
(Appendix III. Occupational and Public Health Risks Associated with in-Situ
Leaching, in: Technical Report on Technologically Enhanced Naturally
Occurring Radioactive Materials from Uranium Mining Volume 2; EPA 402-
R-08-005; 2008)
My third concern is the assumption that ISL uranium mining will contribute
to clean energy and a reduction in greenhouse gas emissions.
According to the Powertech website, Powertech Uranium is "well-
positioned for rapid growth in the burgeoning US nuclear power industry".
In 2002 the Bush/Cheney administration's "Nuclear Power 2010 Program"
provided large subsidies for a handful of Generation III+ demonstration
plants. The expectation that these plants would be built and come online
by 2010 has not been met.
There has been no ground-breaking on new nuclear plants in the United
States since 1974. Until 2013, there had been no ground-breaking on new
nuclear reactors at existing power plants since 1977. As of 2012, nuclear
industry officials say they expect five new reactors to enter service by 2020;
these are all at existing plants. As of August 2013, there are construction
delays at two new reactor projects. In 2013, four aging reactors were
permanently closed before their licenses expired because of high
maintenance and repair costs at a time when natural gas prices have
fallen. The state of Vermont is trying to close Vermont Yankee. New York
State is seeking to close Indian Point, 30 miles from New York City. As of
the present date, there appears to be a net loss of nuclear reactor numbers
in the US, rather than a so-called "burgeoning industry".
(New York Times, June, 2013)
Powertech has also stated that the company would like to sell uranium
oxide on the world market, especially to the BRIG nations; Brazil, Russia,
India and China... Nearly all of the reactors that have been built or are under
construction in these countries are light water reactors. (International
Atomic Energy Agency website, October, 2013)
-------
The hope that breeder reactors would replace light water reactors and that
more economic means of reprocessing spent fuel would be developed has
not been realized. At present, it is generally found to be cheaper to mine
new uranium, which is then used in a "once-through" process that creates
spent fuel, the radioactive waste that is considered to be the "Achilles heel"
of nuclear energy.
The nuclear industry seeks the cheapest ore, for use in the least efficient
way, by an energy industry energy that is fraught with dangerous waste
and high costs associated with construction, operation, repair,
decommissioning and clean-up after accidents.
Various agencies have tried to estimate how long all of these primary
sources of uranium will last, assuming a once-through cycle. The European
Commission said in 2001 that at the current level of uranium consumption,
known uranium resources would last 42 years.
(The Times: London "Uranium Shortage Poses Threat" August, 2005).
Thus, in order to provide nuclear power for a period ending during the
lifetimes of many living today, we leave permanent, potential increased
contamination of soils, river systems and aquifers.
The problems of global warming that the nuclear industry hopes to alleviate
have also driven the development of renewable energy. The
Intergovernmental Panel on Climate Change has said that there are few
fundamental technological limits to integrating a portfolio of renewable
energy technologies to meet most of total global energy demand.
In a 2009 Scientific American article entitled "A Path to Sustainable
Energy", researchers write that producing all new energy with wind power,
solar power, and hydropower by 2030 is feasible and that existing energy
supply arrangements could be replaced by 2050. Barriers to implementing
the renewable energy plan are seen to be "primarily social and political, not
technological or economic". The authors say that energy costs with a wind,
solar, water system should be similar to today's energy costs. Tav ixulhmn
only consider technologies that have near-zero emissions of greenhouse
-------
gases arid other pollutants over their entire life cycle, including
construction, operation and decommissioning. Similarly, they only consider
technologies that do not present significant waste disposal or terrorism
threats.
An intriguing result of their planwould be a decline in global power demand.
That would occur because, in most cases, electrification is a more efficient
way to use energy. For example, only 17 to 20 percent of the energy in
gasoline is used to move a vehicle (the rest is wasted as heat), whereas 75
to 86 percent of the electricity delivered to an electric vehicle goes into
motion. They note that the world manufactures approx. 73 million cars and
light trucks every year. (Scientific American; November, 2009; Mark
Jacobson and Mark Delucchi)
The International Energy Agency has stated that the deployment of
renewable technologies usually increases the diversity of electricity sources
m»*J. ywwalfon, contributes to the flexibility of the system and
its resistance to central shocks. Bringing these possibilities into present
perspective, my husband and I have lived ........."... «
house exclusively powered by solar electricity for the past 5 years.
If we run out of oil, coal, natural gas or uranium, we can make use of many
other energy sources. There are no alternatives to water.
For these reasons, I do not believe that erupioyii «tj Iftl'tJK t.gl.UW iSlitKK Ul WHIKl
to mine uranium is a beneficial use of water. The risk of cte^nding 'argc
"oJr
quantities of water, for the private gain of a few, is not in the public interest.
©
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CONTAMINANT SURVEY AND
SITE CHARACTERIZATION REPORT
EXECUTIVE REPORT
US DA FOREST SERVICE
NEMO WORK CENTER
Nemo, South Dakota
September 3,1997
Submitted to:
Bill Schleining
On-Site Coordinator
U. S, Department of Agriculture, Nemo Forest Service
RR 2 Box 200
Highway 385 North
Custer, South Dakota 57730-9501
Prepared by:
EnviroSearch International
2319 South Foothill Drive, Suite 180
Salt Lake City, Utah 84109
Ph. (801)461-0888
Fx. (801)481-0008
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1
INTRODUCTION
EnviroSearch International was contracted by the U. S. Department of
Agriculture / Forest Service (USDA-FS), Rocky Mountain Region, to conduct a
contaminant survey and hydrogeologic characterization at the USDA-FS Nemo,
South Dakota Work Center, This work was initiated after pesticides were
detected in the local domestic water supply aquifer. All work was performed
from January 1997 through June 1997.
A three volume Contaminant Survey and Site Characterization Report was
submitted to the USDA-FS on September 3, 1997. The purpose of the three
volume report was to; (1) summarize previous work relevant to the pesticide
investigation; {2) acquire data needed to delineate contaminated groundwater,
identify contaminant migration pathways and evaluate potential sources or
source areas of pesticide contamination; and (3) provide information the would
aid the design and construction of a domestic water supply system for impacted
residents in the town of Nemo, South Dakota. This Executive Report provides a
summary of the three volume Contaminant Survey and Site Characterization
Report. Tables and figures that summarize pertinent information referenced to
in this report are attached.
BACKGROUND
In the mid 1970s Forest Service personnel reportedly mixed and applied
pesticides to trees in the Black Hills National Forest to fend off a bark beetle
infestation in the area. Reported information indicated that containers and left
over pesticides (EDB and lindane mixed with diesel fuel and water) were
disposed of behind the USDA-FS Nemo Work Center. Initial sampling of
drinking water supply wells in the Nemo area was conducted by USDA-FS
personnel. Initial analytical results indicated the pesticide EDB was detected in
nine domestic supply wells in the area. Sixteen additional water supply wells
were identified in the vicinity of Nemo (within two miles of town) and sampled by
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USDA-FS personnel Analytical results indicate EDB was not detected in any of
the additional 18 wells.
In addition to EDB, other volatile organic compounds were detected in the
Langley, Post Office, and Spieiss wells but were below maximum contaminant
levels (MCLs) for safe drinking water. The source of these compounds is
unknown; however, possible sources include a byproduct of chemical
disinfection of drinking water in the Spliess well or degradation of other
chemicals. The solvent trichloroethene (TCE) was also detected in the Post
Office well at low concentrations below MCLs. TCE is commonly used as a parts
cleaner/degreaser. Due to the low concentrations of these organic compounds,
initial groundwater sampling and analysis efforts by the USDA-FS focused on
EDB; however, these compounds continued to be monitored.
SOURCE INVESTIGATION
EnviroSearch conducted excavation activities in October 1996, to locate and
remove the containers reported to have been buried behind the work center.
Twelve areas were excavated. Buried debris was encountered at several
locations, however, no pesticide containers or contaminated soils were
identified. Excavation efforts were subsequently halted to assist the Forest
Service with the installation of an alternative community water distribution
system. Further efforts to identify potential pesticide container burial locations
employed geophysical methods to measure subsurface electrical conductivity
within selected locations. However, upon excavating those locations no
containers of pesticides or evidence of residual soil contamination were
observed.
MONITORING WELL INSTALLATION AND SAMPLING
During March 1997, EnviroSearch International supervised the drilling and
construction of eight monitoring wells in the Nemo area. After reviewing the
analytical results and the initial drilling data, an additional five monitoring wells
were installed in May 1997. The five additional wells were sampled -and
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analyzed to belter delineate the contaminant plume. Some of these wells were
also evaluated as potential domestic water supply wells for affected residents.
The location of each monitoring well is identified on Figure 1. In addition to
monitoring wells, spring seeps identified adjacent to the Flak property, near
MW-12 and a tree stump located southwest of Troxell (northwest of MW-1) on
the south side of the road were also sampled. The results of monitoring well
sample analyses are summarized in Table 1.
Analytical results indicate the presence of EDB in groundwater samples
collected from six of the thirteen monitoring wells and in the seep sample
collected from the Flak property. The highest concentration (18.5 ug/l) was
detected in the sample collected from MW-10. This concentration is at least 10
times higher than concentrations detected in any other monitoring well, EDB
concentrations ranging from 0,13 ug/l to 1,0 ug/l were detected in groundwater
samples collected from MW-1, MW-3, MW-4, and MW-12. These wells are all
located adjacent to what has been interpreted as a northwest-southeast
trending fault located to the southwest of the banded iron formation which forms
a prominent ridge in the project area. The fault appears to extend from at least
Boxelder Creek north of MW-1, to the open valley near MW-12, To the
southeast (see Figure 2) Lower concentrations of EDB were detected in
samples collected from the Flak seep (0,069 ug/l) and MW-11 (0.057 ug/l).
EDB was not detected in samples collected from MW-2, MW-5, MW-6, MW-7,
MW—8, MW-3 or MW-13. These observations indicate that: (1) there is a likely
source area upgradient (northwest) of MW-10; (2) EDB concentrations in
groundwater decrease to the east and west of the fault; and (3) the fault appears
to control EDB migration in the project area.
Toluene concentrations ranging from 0.7 ug/l to 5.1 ug/l were detected in
groundwater samples collected from four wells. Two of these wells (MW-8 and
MW-9) are located to the southwest of the inferred fault line and are not
impacted by EDB, Toluene is a common degreaser and a relatively volatile
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4
compound that could have been inadvertently introduced into the samples
during drilling and/or introduced due to the presence of petroleum fuels in field
vehicles and generators. Toluene is not considered a chemical of concern
because of the low concentrations and sporadic presence,
DOMESTIC SUPPLY WELL SAMPLING AND ANALYSIS
Domestic water supply well sampling was initiated by the USDA-FS in October,
1996. Subsequent sampling activities conducted by EnviroSearch included the
sampling of six domestic supply wells in March 1997 (Langely, Kaberna, Flak,
4T Old well, an unnamed well south of the Hooper well and the Pete Lien &
Sons Mine) and nine domestic supply wells in May 199? (Adams, Deverman #1,
Deverman #2, Flak, Kaberna, Nemo Church, Post Office/Fire Department,
Troxell/Keogh, and Weston). The May 1997 sampling reflected peak flow
conditions and was conducted to evaluate seasonal trends in concentrations.
The analytical results for domestic supply well samples collected by the USDA-
FS and EnviroSearch are summarized on Table 2.
The results of domestic supply well analyses are discussed in order of
decreasing magnitude. The highest EDB concentrations were detected in
groundwater samples from the Kaberna well (9.4 ug/l to 12 ug/l) and the
Troxel/Keough well (3.5 ug/l to 5.4 ug/l). These concentrations are consistent
with those previously detected by the USDA-FS in October 1996. Groundwater
samples collected by EnviroSearch from the Adams, Weston and Nemo Church
wells contained EDB concentrations of 0.73 ug/l, 0.28 ug/l and 0.29 ug/l,
respectively. A groundwater sample collected from the Post Office/Fire
Department well contained 0.023 ug/l EDB. Groundwater samples collected
from the Deverman and Flak wells were below laboratory detection limits with
respect to EDB. The EDB concentrations in groundwater samples collected from
Weston, Church and Krahn are an order of magnitude less than those previously
detected by the USDA-FS likely due to dilution and flushing caused by
increased precipitation. The Kaberna and Weston wells, and possibly the
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5
Troxell/Keough wells, are hydraulically connected to the linear fault southwest of
the ridge. However, Troxell/Keough is farther from the fault than MW-1 and
exhibits EDB impact that is an order of magnitude higher. The presence of EDB
in samples from the Adams, Church and Post Office wells and previous samples
collected by USDA-FS personnel from the Spleiss, Krahn, and School wells
suggests the presence of a separate source area to the east of the northwest-
southeast fault line. The Troxell/Keough well is likely hydraulically connected to
this separate source.
DISTRIBUTION OF EDB IN GROUNDWATER
Based on the observations presented thus far, it is likely that two EDB plumes
are present within the project area (Figure 2). One plume is related to and
controlled by the northwest-southeast trending fault previously discussed.
Impacted wells associated with this plume include Weston, Kabema, MW-4,
MW-10, MW-3 and possibly MW-1 and Troxell/Keough. The second plume is
likely controlled by local topography, bedrock structure, an east-west trending
fault to the north of Troxell and structural contact that may cross Nemo Road in
between MW-11 and the Fire Department.
The property owned by Homestake Mining does not appear to be impacted,
based on the absence of EDB in wells MW-5, MW-8 and MW-13. The valley to
the east and south of Nemo does not appear to be impacted by migration of EDB
from the community of Nemo, based on the absence of this chemical in wells
MW-6 and MW-7.
Groundwater appears to be in direct communication with Boxelder Creek where
the northwest-southeast trending fault intersects the Creek, to the south of
Kaberna. Contaminated groundwater has been identified flowing from a seep
(Flak Seep) near MW-12 in this area.
EDB concentrations in groundwater appear to be relatively stable for samples
collected from water supply wells between October 1996 and Jul / 1997, with the
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exception of samples collected from three wells (Church, Krahn and Weston).
Analytical results for groundwater samples collected from the Church and
Weston wells in May 1997 and the Krahn wei! in July 1997 show an order of
magnitude decrease in EDB concentrations. The decrease of EDB
concentrations in these wells is likely due to increased precipitation and flushing
of shallow groundwater resulting in EDB dilution at these locations.
Continued detection of EDB in impacted supply welts is anticipated due to the
low analytical method detection limits, the inability to locate and abate the
source(s), and the probability of continued contaminant presence in
groundwater.
AQUIFER TESTING AND WATER LEVEL ANALYSIS
Aquifer tests and water level analysis were conducted to evaluate local
groundwater flow patterns, fracture connectivity, and preferred contaminant
migration. These activities also provided data to evaluate the degree of isolation
of potential water supply development areas from those areas known to be
impacted by EDB. Additional short-term aquifer tests were performed to
evaluate the pumping capacity of specific wells.
Water levels in groundwater monitoring wells were gauged in March, May and
June 1997 to determine baseline water level conditions and evaluate local
groundwater gradients. The resulting piezometric surface contour and
groundwater flow direction map for water levels collected on May 29, 1997 is
presented as Figure 3.
Some of the pertinent conclusions resulting from the aquifer tests include:
• Some wells in the shallow bedrock aquifer responds rapidly to aerial
recharge while others do not This phenomenon could possibly be used to
further distinguish wells into separate systems.
• The primary water bearing zones in the vicinity of Nemo are located within
structural and lithological geologic features.
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7
• The Spleiss wed, Church well and possible the Adams well, are completed in
a similar hydrogeologic regime,
• The Deverman wells appear to be hydraulically isolated from the EDB
impacted groundwater within the community of Nemo.
• MW-13 is not currently impacted and does not appear to affect water levels
in wells within the EDB plume when pumped. However, continued pumping
of MW-13 may result in the appearance of EDB in this well due to; 1) the
close proximity to the EDB plume; 2) groundwater recharge to this well from
the highly permeable fault zone; and 3) the quantity of water that is
produced.
• The rate of groundwater movement is estimated as 0.5 to 1.0 feet/day.
CONCEPTUAL HYDROGEOLOGIC MODEL
The primary mechanisms which control groundwater movement in the Nemo
area include preferential flow paths created by structural and lithological
geologic features, groundwater recharge from precipitation on higher slopes
surrounding the site and from Boxelder Creek, and groundwater discharge at
lower elevations where structural features converge and intersect Boxelder
Creek.
The primary water bearing zones and groundwater transmission zones m the
vicinity of Nemo are located within structurally and lithologically controlled
geologic features including; 1) a northwest-southeast trending fault west and
south of Nemo, 2) a northwest-southeast trending lithologic contact in Nemo
and east of the bedrock ridge; and 3) east-west trending normal faults south of
the town site.
Recharge to the shallow bedrock aquifer west of the iron rich bedrock ridge is
provided by precipitation on the higher slopes west of Nemo. Groundwater west
of the iron rich bedrock ridge generally flows from the northwest to the southeast
following the strike-slip fault and southeast from MW-3 towards the Kabema
and Weston residences where geologic structures converge and groundwater
discharges to Boxelder Creek at their intersection. Groundwater contaminated
EnwraSearefi intemaBoiai
Septembers, 1097
C:\NEMO\1752£3-5\CSSCR EX REPORT, DOC
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8
with EDB was observed flowing to the surface (Flak seep) at this location,
therefore Boxelder Creek is in direct communication with the shallow bedrock
aquifer.
The bedrock aquifer north arid east of the bedrock ridge and beneath Nemo,
exhibits sufficient permeability to promote infiltration of surface water from
Boxelder Creek and transmission of groundwater to the southeast towards the
Church well. The groundwater east of the bedrock ridge is interpreted to exhibit
limited communication with the groundwater west of the ridge due to the
presence of the fault and steeply dipping tower permeability strata which
hydrauiically separate the two flow regimes.
Within the town of Nemo, adjacent to the Troxell residence, Boxelder Creek is
interpreted to exhibit a losing section where surface water discharges into the
shallow bedrock aquifer and is transmitted southeast through preferential flow
paths created by northwest-southeast trending fault and steepiy dipping
lithologic contacts. Water levels in wells located in the northern portion of Nemo
(Troxell, Adams, Spleiss) appear lower than the elevation of Boxelder Creek
throughout this reach and generally follow areas of high conductivity. The
direction of groundwater flow from the Church would be influenced by
northwest-southeast oriented lithologic contacts directing flow to the southeast'
and by drainage to Boxelder Creek to the east. Significant flow to the east would
be limited by low permeability lithologic units present between Nemo Road and
Boxelder Creek.
Boxelder Creek is interpreted to be a gaining stream as it enters the valley west
of Nemo where recharge is largely controlled by local topography and the creek
drains the topographically confined valley. East of Nemo, Boxelder Creek again
becomes a gaining stream in the open valley towards the Kaberna residence.
Groundwater conditions and the predominant gradient in the valley would be
controlled by recharge from areas of elevated topography to the east and
groundwater discharge into Boxelder Creek,
ErwiroSwch Intemafanal
September 3,1997
C:\NEMO\l752e3-5\CSSCR EXREPORT.DOC
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9
Based on the water quality data from groundwater monitoring wells, two
independent sources of EDB appear to create two separate plumes which follow
preferential flow paths created by regional geologic features. One source area
is suspected to be located on the bedrock ridge between MW-3 and MW-10
with groundwater and contaminant migration controlled by the northwest-
southeast trending fault and recharge from the higher slopes to the west. A
second source area is likely located west of Troxell and MW-1 with groundwater
movement controlled by discharge from Boxelder Creek to the northwest-
southeast trending lithologic contact creating preferential flow paths towards the
southeast The EDB plume in the area east of the bedrock ridge would continue
to migrate southeast in the direction of primary permeability. Migration of EDB
east of the Church to Boxelder Creek could occur but is expected to be limited
by steeply dipping lower permeability units in this area.
CONCLUSIONS
Key issues that affect the shallow bedrock aquifer system and the distribution of
EDB in groundwater are discussed as follows:
• The open valley east and southeast of Nemo does not currently appear to be
impacted by migration of EDB from the community of Nemo; the orientation of
permeable geologic structures and primary gradient in the open valley is
towards the east-southeast with some groundwater discharge occurring into
Boxelder Creek throughout this reach; water supply welis directly east of
Nemo do not appear impacted by migration of EDB; however, continued
migration of EDB south and southeast of the Nemo Church is expected.
• The EDB contamination observed in the Kaberna and Weston residences is
primarily due to contaminant migration in the strike-slip fault west of their
properties; groundwater is in direct communication with Boxelder Creek
where the northwest-southeast trending fault intersects the creek south of
Kaberna; the distribution of EDB in the shallow bedrock aquifer south of
Boxelder Creek and downgradient from MW-12 is unknown and this area
does appear to be a groundwater discharge zone.
ErwiraSeafch Intematkral
Septembtr 3,1997
C:\NEMQ\1752E3-S\C5SCR EX REPORT.DOC
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10
• Based on the water level and water quality data observed to date, the
Devermari wells supplying the Nemo Guest Ranch appears to be upgradient
and hydraulically isolated from the EDB impacted groundwater within the
community of Nemo.
• The property owned by the iron mine is hydraulically cross gradient from the
EDB plume and therefore is not impacted by EDB in groundwater as defined
by the absence of EDB in wells MW-5, MW-8 and MW-13.
• Limited groundwater development potential for a moderate capacity
alternative water supply well exists outside of the regional structural and
lithologic features discussed above, most wells completed outside structural
geologic features produce less than 5 gallons per minute (gpm) whereas
wells completed near structural contacts produce up to 20 gpm. Well MW-3,
adjacent to the northwest-southeast trending fault, has proven to be the best
producer at 20 gpm.
• The rate of groundwater movement is estimated as 0.5 to 1.0 feet/day.
ALTERNATE WATER SUPPLY
Detailed discussions concerning the feasibility of various water supply options
were presented in the Alternative Water Supply analysis (EnviroSearch, 1997a)
provided to the Forest Service January 23, 1997. Results of the water supply
alternatives analysis indicate development of a suitable alternative groundwater
supply for the impacted residents of Nemo is feasible. The analysis also
indicates several alternatives are more promising than others from a cost,
reliability and public/regulatory acceptance point of view. Following completion
of the subsurface investigation, the options for alternative water supply were
reevaluated considering the revised hydrogeologic model, the contaminant
distribution, and available groundwater yield data from the groundwater
monitoring and pilot water supply wells.
Viable options for replacement of Nemo's drinking water revolve around
installation of replacement wells near private users. Specific options for
alternative replacement wells for the residents of Nemo include developing and
fcnviroo^arcn international
September 3,1997
C:\NEMO\1732E3-5\CSSCR EX REPORT.DOC
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11
treating groundwater from one or more monitoring wells including MW-3, MW-7,
or MW-8, developing the Hooper well or an alternate water supply well north of
Boxelder Creek and west of Nemo or treatment of an existing impacted water
supply well. Specific options for alternative wells for the Weston residence
include developing and likely treating MW-13, developing MW-8 or treatment of
the original Weston well or other nearby impacted water supply well. Specific
options for alternative wells for the Kaberna residence include developing MW-
3, developing MW-7, installation of a new water supply well in the Kaberna
valley, or treatment of the Kaberna well or other nearby impacted water supply
well.
The criteria for selecting interim and final water supply options includes the
following:
• Presence and availability of developable groundwater.
• Water usage needs/demands.
• Need to treat groundwater for EDB and possibly coliform.
• Reliability of a single alternative to provide a long term source of clean
drinking water.
• Location of the developable groundwater; private vs. public land,
• Cost to transport the water to the distribution location,
• Requirements of the individual impacted residents.
• Risk and liability of any single alternative.
Key factors limiting the ability to provide local replacement wells for each
residence includes: the presence of EDB beneath the town site, availability of
developable groundwater in the immediate vicinity, costs associated with
constructing conveyance systems over large distances or across Boxelder
Creek, and the need to treat contaminated groundwater developed close to the
existing EDB plume. Installation of replacement wells within property boundaries
for residents within Nemo is not viable due to the distribution of EDB beneath the
EiwiraSwrch Intematioral
Stptembw 3,1997
C:\NEMO\1732ES-5\CSSCR EX REPORT.DOC
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12
town. Installation of replacement wells on individual properties within Nemo is
not cost effective or technically feasible without anticipating treatment of each
individual welt. Treatment of numerous wells is not cost effective or
operationally desirable.
Sufficient developable groundwater supplies are not present in the Nemo area to
provide individual replacement wells for each impacted resident within Nemo. In
addition, construction of multiple conveyance systems to each individual
impacted residence from replacement wells located in more remote areas is not
cost effective. For these reasons, multiple users are anticipated to be required
to share replacement wells at areas that can be developed safely and cost
effectively. Sufficient groundwater (greater than 3 gpm) available for
development is present southwest of Nemo near MW-3, MW-9, south of Nemo
near MW-8, East of Nemo near MW-7 and across Boxelder Creek near the
Hooper well which is interpreted to be completed in the east-west trending fault
north of the creek. Development of MW-3 as a water supply well will require
treatment to remove EDB and chlorination to remove bacteria. Development of a
well near Hooper would require access to private property, piping of drinking
water over considerable distances (3000-4000 ft), and crossing Boxelder Creek.
Treatment of one or several water supply wells may be more cost effective than
conveying groundwater over considerable distances. Development of shallow
groundwater or surface water from Boxelder Creek is likely not cost effective and
undesirable due to excess operation, maintenance, and treatment costs.
Installation of replacement wells for the Kaberna and Weston residence is also
considered a viable alternative. Similarly, placing a well as close as possible to
affected users is desirable, however developing water at distances from the EDB
plume will minimize future risk of contaminating drinking water supplies.
Installation of a community water supply well or wells as close to affected users
as practical to minimize conveyance costs yet far enough away from the EDB
plume to minimize future risk of contaminating drinking water supplies is
EnvfroSearch
September 3,1997
C:\NEMO\1752E3-5VCSSCR EX REPORT.DOC
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13
preferred. Developing MW-13 as a replacement water supply well without
treatment is not believed to be a reliable alternative due to the close proximity of
MW-13 to the EDB plume and high permeability associated with the fault zone.
Less risk of impacting future water supplies would occur with increasing lateral
distance from the fault zone.
Conceptually, the lowest cost alternatives are for providing an alternative
groundwater source from an area hydraulically isolated from the zone of
contamination or treating an existing well capable of providing ample drinking
water. The initial capital costs of treating a single water supply well are
comparable to constructing a pipeline to convey water approximately 1000 to
1500 feet from a source outside the impacted area. Reliability of the various
alternatives needs to be carefully considered. A water supply well (or wells)
confidently located in an area hydraulically isolated from contamination or
treatment of groundwater from a non-isolated source is the most reliable water
supply option. Removal of EDB from groundwater via carbon adsorption is also
considered reliable although the number of treatment units considered affects
the financial viability of this alternative,
RECOMMENDATIONS
Given that limited options are available for developing an alternative drinking
water system and there is a recognized desire to terminate continued trucking of
potable water as soon as possible, EnviroSearch recommends implementation of
an interim water supply system while identifying long term options for impacted
residences. The interim measures would develop the identified water supplies
with the highest probability of successfully supplying the residents with drinking
water.
Based on the information available to date,. EnviroSearch recommends
developing MW-8 as an interim water supply the Weston residence while
exploring the presence of developable groundwater in the Kaberna valley with
an additional pilot well. In addition, development of MW-3, MW-7, or MW-8 as
EnviroSearch International
Sepfetnbtr 3,1987
C:\NEMO\1752E3-5VCSSCR EX REPORT.DOC
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14
an interim water supply well for the community of Nemo should be considered
and compared to developing groundwater supplies north of Boxelder Creek.
The community and USDA-FS reactions to or positions regarding a treated
water supply should be considered. In addition, the cost of treatment vs. piping
of water and associated risk management aspects of specific alternatives should
be evaluated, EnviroSearch also recommends that the USDA-FS:
• Propose a design for an interim water supply system to the residents of
Nemo as a basis for further discussion of the existing limitations, conditions,
and decision factors. A public meeting is proposed to convey the results of
the site characterization program to the residents of Nemo with an interim
water supply proposal to initiate the public participation process,
• Determine the fate of EDB impacted groundwater below, adjacent to (Flak
property), and downgradient of Boxelder Creek.
• Determine the alternative water supply options and requirements.
• Determine the final water supply requirements for the impacted residents.
• Develop a standard policy, in conjunction with the State of South Dakota and
EPA, on usage of EDB impacted water supply wells by residents of Nemo.
• Develop an approach to continued monitoring of groundwater wells, water
supply wells, and if necessary, surface water.
• Consider a limited soil gas survey along the roads near the suspected
sources of groundwater contamination and conduct limited soil sampling at
selected locations (i.e. suspected former mixing/staging locations).
• Identify long term remedial requirements, options and limitations for impacted
groundwater.
EnviroSearch International
September 3,1®?
C:\NEMO\1752E3-5\CSSCR EX REPORT.DOC
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Table 1
Summary of Laboratory Analysis for Nemo
Monitoring Well and Seep Samples
(mrn
Sampling
Date of
ED8
Benzene
Ethyl-
Naphtha-
Toluene
Total
Isopropyl-
Locsti o n
Laboratory
Submittal
benzene
lene
Xylenes
benzene
(Cumene)
MW-1
3/27/97
0.13
<0.50
<0.50
<0.50
<0.50
<1.00
<0.50
MW-2
3/31/97
<0.020
<0.50
<0.50
<0.50
<0.50
<1.00
<0.50
3/25/97
0.025
<0.50
<0.50
<0.50
<0.50
<1.00
<0.50
MW-3
5/14/97
<0.020
<0.50
<0 50
<0.50
<0.50
<1.00
<0.50
6/20/97
0.16
<0.50
<0.50
<0.50
1.10
<1.00
<0.50
7/1/97
0.091
<0.50
<0.50
<0.50
<0.50
<1.00
0.69
MW—4
3/17/97
1.0
<0.50
<0.50
<0.50
<0.50
<1 00
<0.50
MW-5
3/15/97
0.021
<0.50
<0.50
<0.50
<0.50
<1.00
<0.50
3/28/97
<0.020
<0.50
<0.50
<0.50
<0.50
<1.00
<0.50
MW-6
3/31/97
<0.020
<0.50
<0.50
<0.50
<0.50
<1.00
<0.50
MW-7
3/31/97
<0.020
<0.50
<0.50
<0.50
<0.50
<1.00
<0.50
MW-8
3/14/97
<0.020
<0.50
<0.50
<0.50
0.74
<0.50
<0.50
MW-9
5/12/97
<0.020
<0.50
<0.50
<0.50
5.10
<1.00
<0.50
MW-10
5/12/97
18.5
<0.50
<0.50
<0.50
tr
<1.00
<0.50
MW-11
5/14/97
0.057
<0.50
<0.50
<0.50
1.20
<1.00
<0.50
MW-12
5/14/97
0.55
<0.50
<0.50
<0.50
tr
<1.00
<0.50
MW-13
6/20/97
<0.020
<0.50
<0.50
<0.50
<0.50
<1.00
<0.50
MW-13
6/25/97
<0.020
<0.50
<0.50
<0.50
<0.50
<1.00
<0.50
post pump
Seep Flak
5/12/97
0.069
<0.50
<0.50
<0,50
<0.50
<1.00
<0.50
Stump
5/14/97
<0.020
<0.50
<0.50
<0.50
<0.50
<1.00
<0.50
Seep
MCL
0.05
5
700
NA
1000
10000
NA
RBC
0.00075
0.36
1300
1500
750.00
1400
1500
NOTES:
NA - Not Analyzed or Not applicable *1 ugrt is spproximotty equal to 1 ppb
tr - trace; detected below the quantification limit MCI - Federal Drinking Water Maximum Contaminant Level
RBC - Risk Based' Concentrations from EPA Region III Table,
Concentrations assume residential exposure by tap water ingestion.
CiatAIUkPutlMk 1 •4_ •rji • jlli'LIL-mt
tnviro^earcn internauonai
September 3. 1997
C:\NEMO\t 752E J-5VCSSCR EX REPORT.DOC
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Table 2
Summary of Laboratory Analyses
For Nemo Well Water Samples (ug/I*)
Sampling Location
Date of
EDB
Benzene
Toluene
Ethyl-
Total
Naphtha-
1,2,3-
isopropyl-
Trichloro-i
Bromo-
Bromo-
Chloro-
Dibromo-
Laboratory
benzene
Xylenes
lene
Trichloro-
benzene
ethene
dichloro-
form
form
chloro-
Submittal
benzene
(Cumene)
methane
methane
Adams Eton
10/08/96
0.92-0.93
NA
NA
NA
NA
NA
NA
NA
NA
MA
NA
NA
NA
10/16/96
0.36
<0.®
<0.20
<0,20
<0.20
<0.50
<0.50
<0,20
<0.®
<0,20
<0.20
<0.20
<0.20
05/27/97
0.73
<0.50
<0.50
<0.50
<1.00
<0.50
<0,50
<0,50
<0,50
<0,50
<0.50
<0.50
<0.50
Atkinson
10/22/96
<0.010
NA
NA
NA
NA
NA
NA
NA
NA
NA
MA
NA
NA
Church
10/08/96
1.3-1 J
NA
NA
NA
NA
NA
NA
NA
MA
NA
NA
NA
NA
10/16/98
1.4
<0 20
<0,20
<0,20
<0.40
<0.50
<0.50
<0,20
<0.20
<0.20
<0.20
<0.20
<0.20
05/27/97
0.29
<0.50
<0.50
<0.50
<1.00
<0.50
<0 50
<0,50
<0,50
<0.50
<0 50
<0,50
<0.50
Cooper Derral)
10/08/98
<0.010
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Deverman #1
10/08/96
<0.010
NA
NA
NA
NA
NA
NA
NA
MA
NA
NA
NA
NA
OS/27/97
<0.020
<0.50
<0,50
<0.50
<1,00
<0.50
<0.50
<0.50
<0.50
<0,50
<0.50
<0.50
<0,50
Deverman #2
10/08/96
<0.010
NA
NA
NA
MA
NA
NA
NA
NA
NA
NA
NA
NA
05/27/97
<0.020
<0.50
<0.50
<0.50
<1,00
<0.50
<0,50
<0 50
<0,50
<0,50
<0.50
<0.50
<0,50
Esaere
07/01/97
<0.020
<0.50
<0,50
<0,50
<1.00
<0.50
<0,50
<0 50
<050
<0.50
<0.50
<0 50
<0.50
Fieron
10/22/96
<0.010
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Fieron 2nd House
10/22/96
<0.010
NA
MA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Flak
03/28/97
<0.020
<0.50
<0.50
<0.50
<1.00
<0,50
<050
<0,50
<0,50
<0.50
<0.50
<0.50
<0.50
05/19/97
0.018
<0.50
<0.50
<0.50
<1.00
<0,50
<0.50
<0.50
<0.50
<0.50
<0.50
<0.50
<0.50
Flak Seep
05/19/97
0.063
<0.50
<0.50
<0,50
<1.00
<0,50
<0,50
<0,50
<0.50
<0.50
<0.50
<0 50
<0.50
Ford
10/16/96
<0.010
NA
NA
NA
MA
NA
NA
NA
NA
NA
NA
NA
HA
Ford Shirley
i 0/22/96
<0.010
NA
NA
NA
NA
NA
NA
NA
NA
NA
MA
NA
NA
Hageman KC
10/Q8/96
<0.010
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Kaberna
10/22/96
13
NA
NA
NA
NA
NA
NA
NA
MA
MA
MA
NA
NA
10/29/96
10
<0.20
<0.20
<0.20
<0.20
<0 50
<0,50
<0.20
<0,20
<0.®
<0.20
<0,20
<0.20
03/25/97
1.4
<0.50
<0.50
<0,50
<1.00
*0.50
<0.50
<0.50
<0.50
<0.50
<0.50
<0.50
<0.50
05/19/97
12
<0.50
<0.50
<0.50
<1,00
<0.50
<0,50
<0 50
<0.50
<0.50
<0.50
<0.50
<0,50
W»hn
10/08/96
0.17
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
10/16/86
0.13
<0.20
<0,20
<0,20
<0.40
<0.50
<0.50
<0.20
<0.20
<0.20
*0.20
<0,20
<0.20
07/01/97
0.046
<0.50
<0.50
<0,50
<1.00
<0.50
0.62
<0.50
<0.50
<0,50
<0.50
<0,50
<0.50
Len^tey
10/16/96
<0.010
<0.20
<0.20
<0,20
<0.40
<0,50
<0,50
<0.20
<0.20
<0.20
<0.20
0,69
<0,20
03/31/97
<0 020
<0.50
<0.50
<0,50
*1.00
<0.50
<0.50 .
<0.50
<0.50
<0.50
<0 50
<0,50
<0,50
Martin
10/22/96
<0.010
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
Federal Drinking Water MCL
o.os
5
1.000
700
10,000
NA
NA
NA
5,0
NA
NA
NA
NA
RBC
0 00075
0.36
750
1300
1400
1500
NA
1500
1.6
0.17
2.4
0.15
NA
NOTES:
NA - Not Analyzed or Not Applicable tr - trace; delected below the quantification limit *1 ugM is approximately equal to 1 ppb
'TS - iNF/Splelss - Treatment System Influent IS - EFF/8plilss~ Treatment System Effluent
MCI - Maximum Contaminant Level R8C - Rtslc Bated Concentration* from EPA Region III Table, Concentrations assume residential exposure by tap water Ingestion.
-------
Table .2
(continued)
(ug/l*)
Sampling Location
Date of
EDB
Benzene
Toluene
Ethyl-
Total
Naphtha-
1.2,3-
Isopropyl-
"Trichloro-
iromo-
Bromo-
Chloro-
Dibromo-
Laboratory
benzene
Xylenes
lene
Trichloro-
benzene
ethene
dichlora-
form
form
chloro-
Submittal
benzene
(Cumene)
methane
methane
Post Office/Fire Oept
10/08/96
0.062
MA
m
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
10/16/96
0.046
<0.20
<0,20
<0.20
<0,40
<0.50
<0.50
<0.20
0.27
<0,20
<0.20
<0.20
<0.20
10/29/96
0.063
<0.20
<0.20
<0.20
<0.20
<0,50
<0,50
<0.20
0.22
<0,20
<0,20
<0.20
<0,20
OS/27/9?
0.023
<0.50
<0.50
<0,50
<1.00
<0.50
<0.50
<0.50
<0.50
<0,50
<0 50
<0,50
<0.50
School
10/08/96
1.12
NA
MA
NA
HA
NA
NA
NA
NA
NA
NA
NA
NA
10/16/96
0.82
<0,20
<0,20
<0.20
<0.40
<0.50
<0.50
<0.20
<0.20
<0,20
<0,20
<0.20
<0.20
06/25/97
1,1
<0.50
<0.50
<0.50
<1.00
<0.50
<0.50
<0,50
<0.50
<0.50
<0.50
<0.50
<0.50
Smith
07/01/97
<0.020
<0,50
<0.®
<0.50
<1.00
<0.50
¦ 0
<0,50
<0 50
<0.50
<0.50
<0.50
<0.50
Spleiss House
10/08/96
0.47
NA
m
NA
" nT~1
NA
NA
NA
MA
NA
NA
NA
NA
10/16/97
1.0
<0.20
<0.20
<0.20
<0.40
<0.50
<0.50
<0.20
<0,20
0.28
2,8
0.86
MB
10/22/96
1.0
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
TS-INF/Spleiss
05/22/97
3.6
<0.50
<0.50
<0.50
<1,00
<0,50
<0.50
1,20
<0.50
<0,50
<0.50
<0,50
<0.50
TS-EFF/Spleisa
OS/22/97
<0 020
<0.50
<0.50
<0.50
<1,00
<0,50
<0.50
<0,50
<050
<0.50
<0.50
<0.50
<050
Troxell / Keough
10/08/96
4,7-4.4
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
10/16/96
3,1
<0.20
<0.20
<0.20
<0.40
<0.50
<0 50
<0.20
<0.®
<0.20
<0.20
<0.20
<0.®
05/27/97
8.4
<0.50
<0.50
¦<0,50
<1.00
<0.50
<0.50
<0.50
<0,50
<0,50
<0.50
<0.50
<0.50
Troxell Lilian
10/22/96
<0.010
MA
NA
NA
NA
NA
NA
NA
MA
NA
NA
NA
NA
Troxell Buck
10/29/98
<0.010
m
NA
NA
NA
MA
MA
NA
NA
NA
NA
NA
NA
Tungland
10/22/96
<0.010
m
MA
HA
NA
NA
NA
¦¦¦ NA
NA
NA
NA
NA
NA
Weston
10/22/96
2,2
m
NA
NA
NA
MA
NA
NA
NA
NA
NA
NA
NA
10/29/96
1.7
<0.20
<0.20
<0.20
<0.20
<0.50
<0.50
<0.50
<0.20
<0,20
<0.20
<0.20
<0.20
05/19/97
0.28
<050
<0.50
<0,50
<1.00
<0.50
<0.50
<0,50
<0.50
<0,50
<0.50
<0.50
<0.50
Witcap
10/22/96
<0.010
NA
NA
NA
NA
MA
NA
NA
NA
NA
NA
NA
NA
Zopp Donna
10/22/96
<0.010
m
NA
NA
NA
MA
NA
NA
NA
NA
NA
NA
NA
Creek E * W of
10/08/96
<0.010
MA
NA
HA
NA
NA
MA
NA
m
NA
NA
NA
NA
Nemo
4 TOW
03/19/97
§.063
<0.50
<0.50
<0.50
<1.00
<0.50
<0 50
<0.50
<0.50
<0.50
<0.50
<0.50
<0,50
Mine
03/19/97
<0.020
<0.50
<0,50
<0.50
<1.00
<0,50
<0.60
<0.50
<0.50
<0.50
<0.50
<0.50
<0.50
Unknown well south
03/19/97
<0.02
<0.50
<0.50
<0,50
<1.00
<0.50
<0,50
<0.50
<0,50
<0 50
<0.50
<0 50
<0.50
of Hooper
Federal Drinking Water MCL
005
5
1,000
700
10,0)0
NA
NA
NA
5.0
NA
NA
NA
NA
fin?.
0.00075
0.36
750
1300
1400
1500
NA
1500
1.6
0.17
2,4
0,15
NA
NOTES;
NA - Not Analyzed or Not Applicable If - trace; detected below the quantification limit *1 ugfl Is approximately equal to 1 ppb
TS - INF/Spieiss - Treatment System Influent TS - EFF/Spleiss - Treatment System Effluent
' MCL - Maximum Contaminant Level RBC - Risk Based Concentrations from EPA Region 111 Table, Concentrations tuume residential exposure by tap water Ingestion.
-------
-------
1 MONITORING WELL (IMPACTED IN RED,
NON-IMPACTED IN BLUE)
« Sihoo! IMPACTED DOMESTIC WELL
EBB CONTAMINANT PLUME
(DASHED WEftE APPROXIMATED)
FAULT
LITHOLQGIC CONTACT
l
i
A
0 SOS FEET
PO En viroSvarc h
1 I T £ 1 1 i T 1 1 1 A l
FIGURE 2
DISTRIBUTION OF EDS IN GROUNDWATER
NEMO, SOUTH DAKOTA
APPROXIMATE SCALE
6/12/97
P# 1752
(11VR12A)
-------
-"W-IC MONITORING WELL (IMPACTED IN RED,
NON-IMPACTED IN BLUE)
4810 GROUNDWATER ELEVATION IN FEET
ichoo'; IMPACTED DOMESTIC WELL (IMPACTED IN RED,
NON-IMPACTED IN BLACK)
EOUIPOTENTIAL LINE IN FEET
~ (DASHED WHERE INFERRED)
FLOW LINE
0 ^ 800 FEET
APPROXIMATE SCALE
Fnviro Search
I I 1 ( I I t ! I I I 1 :
FIGURE 3
PIEZOMETRIC SURFACE CONTOUR AND
GROUNDWATER FLOW DIRECTION MAP
_NEMO, SOUtH DAKOTA
8/1 2/97_[p# 1 752_ _L( 1 1VCC12)
-------
-------
EPA Region 8 pane!.
I am a resident of the Hot Springs area in Fail River county. I am very concerned about the
proposed draft permits to Powertech/Azarga for the Dewey-Burdock Uranium line art Deep
Disposal Weils. The area for the permits is in itself a very sensitive area. It is in proximity and
downstream from major recharge areas for all three aquifers, the Madison, Minnelusa and hyan
Kara. The Black His, in general, are also geologically unstable as there is already on going
seismic activity. This is important as waste water deep injection wells have been linked to
increased earthquake activity in Oklahoma.
Injection wells putting hazardous waste into the Minnelusa and Inyan Kara could have otter far
reaching and serious effects. Many ranchers and other residents of Custer and Fall River
counties use the Minnelusa water for drinking, watering livestock and irrigation. The Inyan Kara
water is also used extensively for livestock and irrigation in many areas. This was reported in a
US Dept. of Interior, US Geological Survey study "Hydrology of the Black Hlls Area, South
Dakota" by Daniel G. Driscoll, Janet M. Carter, Joyce E. Williamson and Larry D. Putnum,
Water-Resources Investigations Report 02-4094. This information is in contrast to what
Powertech/Azarga reports.
The USGS report states the extent of the aquifers describing the vast area of distribution of the
water and the varying water qualities. In most areas the water is usable and meets quality
standards for most uses. The Powertech excuse that ttiese aquifers are already contaminated
to not a valid reason to dump wastewater into them. The report also describes that the amount
of transmission between the aquifers can vary from undetermined to significant One can make
the assumption that heavy contamination of one aquifer could therefore contaminate other
aquifers and have a wider effect not only in damage but in cleanup efforts.
The geology of the strata formations Include numerous breccia pipes, fractures and caverns (ex.
Jewel Cave and Wind Cave formations) which no one knows of their extent. These are the
pipelines of water transmission by these aquifers and the extent to which they communicate with
each ottier Is unknown. One should also include the 7650 abandoned boreholes that leak and
transfer water.
The artesian springs from these three aquifers are important water supplies for recreation,
livestock use, wildlife and irrigation. They add water to all the streams and rivers in the
surrounding area. The whole region relies on this supply of clean water. It is a major factor in
our economies. If the clean water supplies fail then the economies that depend upon them fail.
Our tourism, ranch, retail, and hospitality businesses and livelihoods would ail be affected.
I live here. This is my community. I depend upon a rural well water source. What happens if
that water source gets contaminated and is condemned? Where do I turn to? Will a
government agency be available to help out? Will they supply us with clean water and at what
cost? This is the gamble; allowing permits to inject hazardous wastewater into the Minnelusa
-------
and Inyan Kara and risk the possibility of massive contamination or refusing Powertech/Azarga
tie permits to do this. I would not take that risk. I lived in Milwaukee, Wlasa child when lake
Michigan was so contaminated with industrial waste all recreation, fishing and use were
restricted. I know what can happen. I hope we don't follow the path that caused fiat pollution
because that mistake will not be as easy if not impossible to remediate. It will affect generations.
Encl: Title page of the USGS report with the abstract and introduction.
-------
lit Dfilwliftililiiiiii
U.S. Geological Swif
Hydrology of the Black Hills Area,
South Dakota
By Daniel G, Driscoll, Janet M. Carter, Joyce E. Williamson, and tany D. Putnam
Water-Resources Investigations Report 02-4094
Prepared in cooperation with the
South Dakota Department of Environment and Natural Resources
and the West Dakota Water Development District
-------
U.S. Department of the Interior
GALE A. NORTON, Secretary
U.S. Geological Survey
Charles G. Groat, Director ' v
The use of firm, trade, and brand names in this report is for identification purposes only and
does not constitute endorsement by the U.S. Government
Rapid City, South Dakota: 2002
For sMWaml informatio n write to:
District Chief
U,S. Geological Survey
1608 Mi View load
Rapid City, SO 57702
Caputs of this report can be purchased from:
U.S. Geological Survey
Information Services
Building 810
Box 2S2M, Federal Center
Denver. CO 80225-G28S
-------
Hydrology of the Black Hills Area, South Dakota
fly Daniel G, Driscoll, Janet M. Carter, Joyce E, Williamson, and Larry D. Putnam
ABSTRACT
He Black Hills Hydrology Study was initi-
ated in 1990 to assess the quantity, quality, and
distribution of surface water and ground water in
the Black Hills area of South Dakota. This report
summarizes the hydrology of the Black Hills area
and the results of this long-term study.
The Black Hills area of South Dakota and
Wyoming is an important rechaige area for several
regional, bedrock aquifer systems and various
local aquifers; thus, the study focused on describ-
ing the hydrologic significance of selected bed-
rock aquifers. The major aquifers in the Black
Hills area are the Deadwood, Madison, Minnelusa,
Minnekahta, and Inyan Kara aquifers. The highest
priority was placed on the Madison and Minnelusa
aquifers, which are used extensively and heavily
influence the surface-water resources of the area.
Within this report, the hydrogeologic frame-
work of the area, including climate, geology,
ground water, and surface water, is discussed.
Hydrologic processes and characteristics for
ground water and surface water are presented. For
ground water, water-level trends and comparisons
and water-quality characteristics are presented.
For surface water, streamflow characteristics,
responses to precipitation, annual yields and yield
efficiencies, and water-quality characteristics are
presented. Hydrologic budgets are presented for
ground water, surface water, and the combined
ground-watei/surfiace-water system. A summary
of study findings regarding the complex flow
systems within the Madison and Minnelusa
aquifers also is presented.
INTRODUCTION
Tbe Black Hills area is an important resource
center that provides an economic base for western
South Dakota through tourism, agriculture, the timber
industry, and mineral resources. In addition, water orig-
inating from the area is used for municipal, industrial,
agricultural, and recreational purposes throughout
much of western South Dakota. The Black Hills area
also is an important recharge area for aquifers in the
northern Great Plains.
Population growth, resource development, and
periodic droughts have the potential to affect the quan-
tity, quality, and availability of water within the Black
Hills area. Because of this concern, the Black Hills
Hydrology Study was initiated in 1990 to assess the
quantity, quality, and distribution of surface water and
ground water in the Black Hills area of South Dakota ^
(Driscoll, 1992). This long -term study has been a cbop-'
erative effort between the U.S. Geological Survey
(USGS), the South Dakota Department of Environment
and Natural Resources, and the West Dakota Water
Development District, which represents various local
and county cooperates.
The specific objectives of the Black Hills
Hydrology Study included:
I. Inventorying and describing precipitation amounts,
streamflow rates, ground-water levels of selected
aquifer units, and selected water-quality charac-
teristics for the Black Hills area.
«-• ¦" ¦¦ in m*t mi inn <¦
IhlfMUCDOfl 1
-------
2. Developing hydrologic budgets to define relations
among precipitation, strcamflow, and aquifer
response for selected Black Hills watersheds.
3. Describing the significance of the bedrock aquifers
in the Black Hills area hydrologic system, with an
emphasis oe the Madison and Minneiusa aquifers,
through determination of:
a. aquifer properties (depth, thickness, structure,
storage coefficient, hydraulic conductivity,
etc.);
b. the hydraulic connection between the aquifers;
c. the source aquifer(s) of springs;
d. recharge and discharge rates, and gross volu-
metric budgets; and
e. regional flow paths.
4. Developing conceptual models of the hydrogeo-
logic system fc* the Black Hills area.
Purpose and Scops
The purpose of this report is to summarize the
hydrology of the Black Hills area and present major
findings pertinent to the objectives of the Black Hills
Hydrology Study. The information summarized in this
report has been presented in more detail in previous
reports prepared as part of the study. Because the Black
Hills area of South Dakota and Wyoming is an impor-
tant recharge area for several regional, bedrock aquifers
and various local aquifers, the study concentrated on
describing the hydrogeology and hydrologic signifi-
cance of selected bedrock aquifers. The highest priority
was placed on the Madison and Minneiusa aquifers
because: (I) these aquifers are heavily used and could
be developed further; (2) these aquifers arc connected
to surface-water resources through streamflow loss
zones and large springs; and (3) hydraulic connection
between these aquifers is extremely variable. The
Deadwood and Minnckahta aquifers had a lower pri-
ority because they are used less and have less influence
on the hydrologic system. The fractured Precambrian
rocks, Inyan Kara Group, and various local aquifers,
including minor bedrock aquifers and unconsolidated
aquifers, had the lowest priorities because: (1) the Prc-
cambrian and local aquifers are not regional aquifers
with regional flowpaths; and (2) the Inyan Kara Group
is not used as extensively in the Black Hills area as the
other priority units.
Hydrologic analyses within this report generally
are by water year, which represents the period from
October 1 through September 30. Discussions of time-
frames refer to water years, rather than calendar years,
unless specifically noted otherwise.
Description of Study Are*
The study area for the Black Hills Hydrology
Study consists of the topographically defined Black
Hills and adjacent areas located in western South
Dakota (fig. 1). Outcrops of the Madison Limestone
and Minneiusa Formation, as well as the generalized
outer extent of the Inyan Kara Group, which approxi-
mates the outer extent of the Black Hills area, also are
shown in figure 1. The Black Hills are situated between
the Cheyenne and Belle Fourdbe Rivers. The Belle
Fourche River is the largest tributary to the Cheyenne
River The study area includes most of the larger com-
munities in western South Dakota and contains about
one-fifth of the State's population.
The Black Hills uplift formed as an elongated
dome about 60 to 65 million years ago during the Lara-
midc orogeny (Darton and Paige, 1925). The dome
trends north-northwest and is about 120 mi long and
60 mi wide Land-surface altitudes range from 7,242 ft
above sea level at Harney Peak to about 3,000 ft in the
adjacent plains. Most of the higher altitudes are heavily
forested with ponderosa pine, which is the primary
product of an active timber industry. White spruce,
quaking aspen, paper birch, and other native trees and
shrubs are found in cooler, wetter areas (Orr, 1959).
The lower altitude areas surrounding the Black Hills
primarily are urban, suburban, and agricultural.
Numerous deciduous species such as cotton wood, ash,
elm, oak, and willow are common along streams in the
lower altitudes. Rangcland, hayland, and winter wheat
farming are the principal agricultural uses for dtyland
areas. Alfalfa, com, and vegetables me produced in
bottom lands and in irrigated areas. Various other
crops, primarily for cattle fodder, arc produced in both
dryland areas and in bottom lands.
Beginning in the 1870's, the Black Hills have
been explored and mined for many commodities
including gold, silver, tin, tungsten, mica, feldspar,
bentooite, beryl, lead, zinc, uranium, lithium, sand,
gravel, and oil (U.S. Department of Interior, 1967).
Mines within the study area have used various tech-
niques including placer mining, underground mining,
and open-pit mining.
2 Hydrology of tha Black Hlis Aiwa, Soutti Dakota
-------
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RECEIVED MAY 15 2017
I
Dear U.S. EPA,
. OTarriinn thp Black nils Please, no uranium in treaty territory. Please, no to the
I would like to submit a comment regarding the BtacK mis.
Dewey Burdock Uranium Aquifer Mining,
-------
RECEIVED JUM 11 2017
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From:
Subject: Tunnel collapses at Hanford nuclear waste site in Washington state - The Washington Post
Date: May 10. 2017 at 7:01 AM
To:
Tunnel collapses at Hanford nuclear waste site in Washington state
The dean-up operation of Stanford's nine nuclear reactors has been underway since 1989. (Gillian Brockell/The Washington Post)
a
C U vu ^ ^
Hundreds of workers at the Department of Energy's Hanford nuclear site in Washington state had to "take cover*1Tuesday morning after the collapse of 20-foot-long portion of a tunnel used t«
materials.
The Energy Department said it activated its emergency operations protocol after reports of a "cave-in" at the 200 East Area in Hanford, a sprawling complex about 200 miles from Seattle wbe
dean up radioactive materials left over from the country's nuclear weapons program.
The agency s*»H in a statement that the 20-foot section is part of a tunnel that is hundreds of feet long and is "used to store contaminated materials." The tunnel is one of two that run into the I
also known as PUREX. The section thai collapsed was "in an area where the two tunnels join together," the department said.
The P1JREX facility, once used to extract plutonium from spent nuclear fuel, has been idle for years but remains "highly contaminated,* the agency said.
Energy Department officials said there was "no indication of a release of contamination at this point" but that crews were still testing the area. Responder* also were using a robot to take videc
said that Energy Secretary Rick Perry had been briefed, adding that "everyone has been accounted for and there is no initial indication of any worker exposure or an airborne radiological relea
But Edwin Lyman, a senior scientist at the Union of Concerned Scientists, said there is still cause for concern. "It appears that this is a potentially serious event," he said. "Collapse of the earth
considerable radiological release."
An August 2015 report by Vanderbilt University's civil and environmental engineering department said the PUREX facility and the two tunnels had "the potential for significant on-site conseq
dangerous debris and equipment containing or contaminated with dangerous/mixed waste" had been placed inside the tunnels.
-------
'l
The portion of the 20-foct-lang portion of a tunnel that collapsed at the 200 East Area in Hanford, Wash. (Hanford Site)
Cleaning up radioactive materials at the Hanford site, which is a federal facility, has been one of the Energy Department's priorities for >ears. Reactors al Hanford produced plutonium for the
Plutonium production there ended in 1980, and the cleanup program began in 1989.
Former Energy Department official Robert Alvarez said that remotely controlled rail ore once carried spent fuel from a reactor to the PUREX chemical processing facility, which thai extracts
lies near the middle of the sprawling 580-squarc mile llanford ate and was "a very high-hasurd operation."
Many contaminated pieces of equipment, including the rail cars, have simply been left in the tunnels, he said. The Vandeihilt report said that there were eight rail care in the older t unnel and :
The caw-in was discovered during "routine surveillance," according to the Energy Department. Photographs showed a gaping hole, plainly evident because the tunnels are largely above groun
Workers near the PUREX facility were told to shelter in place, and access to the area was restricted, according to the Energy Department statement. Officials requested that the Federal A viatic
restriction in place, according to the FAA.
The two tunnels are covered with about eight feet of soil, according to the Energy Department, which added that "the depth of the subsidence of soil appears to be into the tunncL"
Alvarez, the former Energy Department official, cited a 1997 report that said the older tunnel was about 360 feet long, 22 feet high and 19 feet wide. Constructed decades ago, the walls of the o
up by pressure-treated Douglas fir timbers, the report said. They rest on reinforced concrete footings. The newer tunnel was built with reinforced concrete.
In an email, Alvarez added that "the tunnels now store contaminated train cars and a considerable amount of highly radioactive, igni table wastes including possible organic vapors." And while
timber, Alvarez said, "according to a 1997 DOE report, inspection of the tunnels Is not feasible because of radiation levels in excess of five roentgens per hour."" A roentgen, or rad, is a measin
is the annual limit for a U.S. nuclear worker.
Fixing the damaged tunnel could prove difficult. The Energy Department said on its Web site that officials are looking at options that would provide a barrier between the contaminated equipt
that would not cause the hole in the tunnel's roof to widen further.
^ Seattle - ^ - ^ - ^
Tacoma u
\S ~ N
ML Raining*^, - . e r
WASHINGTO
Mt. St.
Helens Mt. Adams
Yakima*
3ista,
Columbia R.
Hanford nuc
waste site
Kennewick
.to
OREGON
Sources: GoogleEarth and Landsat
>
THE WA
Although the Trump administration has vowed to slash the budgets of most Energy Department programs, the administration does not plan to skimp on the one charged with the Hanford de-
requested $6.5 billion for the agency's environmental management program for 2018.
The budget for! lanford alone is about $2.3 billion in the current fiscal year, about $1-5 billion of that going to the management and treatment of approximately 36 million gallons of radioactiv
storage tanks.
Trump has been slow to fill science-related tuitions- and he has not yet named a new assistant secretary for environmental management; a career department employee is serving in an acting
During his recent confirmation hearing. Perry was asked by Washington Sen. Maria Cantwell (D) about the Hanford site. "So are you committed to funding Hanford cleanup and what it takes
-------
-------
Hearings
lO JiKay, SSOXTT
I object to the tuwo draft permits foi? tine
proposed Dewey-Burdock uranium
utixie in Custer and X^aU Mver Counties
because of time following concerns.
Hife meed to protect our water, economy,
l*e alt la and way of life* Let's stop this bad
idea.
This is a very dry area of the country,
even of western South Dakota. We can't
lose 8,000 gallons of
for time next ten years It would not only
affect time Inyan Kara aquifer, but time
Mimielusa and Madison aquifers. These
are all used in tJbis area. 1life can't afford
to lose tlmat much nirater or lmaire them
pollute any of these aquifers. These
aquifers are known to communicate.
If these permits' are given to
Powerteehi/Arsargo, then there are lO
more companies that nsrW files for the
Hills. Also the companies that are
approaching from the plains for deep
hole disposable wells. Are we trying to
maJke South Dakota the next uranium
dumping area?
-------
This Mud of stoff would also disturb
cultural and Iil.firtox4.c3 sites, wild life and
ow ranoMug and tourisn*. economy.
Handling nranlnm in any form
produces radioactive and toacio wastes
-Chert threaten people* health and our food
dr^lNl CH Hi
-------
their water. Is tlme government going -to
send in contaminated bottled water fox*
«M»1S8p •
Go -to uranium cowboy on u-tube -to see a
lot of lnfovmatioii om this subject.
Cx>awfox>d$ Nebraska is -time only area
that now has a 1SFmmF^r rate of
pancreatic cancer in Nebraska and the
USA.
Dennis Yellow Thunder ha® filed a
petition for a review of Crow Buttas'
pex^nits.
According to lindmy McX^ain a known
bio-chemiet and ISnRO easpert witness,
there have been one and a half million
chenaiicals introduced to the body since
WW II. Also the Tennessee Valley
Authority after 10 years of looking for
uranium to mine in the X^ewrey-JBNjrdock
area left because they found too much
gypsum and cave ines, in the area.
It has already been proved that injecting
materials under high Pressures' deep
under ground causes earth quakes. This
area is already having numerous
earthquakes as the whole Black Kills is
in uplift stage. More and harder
earthquakes are apt to break. tllLCMBMEd
deadly gasses stored over there under
-------
Igl(»o. It could Mill every living thing in
the area.
These permits Tnroxild allow this
company "to pollute "'our nndex^ppound
water, whieh we aJJL rely on.
Just across our western Tborder in
Wyoming Gameco Resources has been
hit with nine apparent violations on
howr they are shipping uranium
products. liitto: / /~iiiriiiirKiir.nrc»geo"ir/al>omt-
nrc/reaiilatory/eiiforcement/enfogce'
poi.html ^Hfe also have that concern
with Araefupgo/Powertech.
https //www.gov/do€Mi/MlX>Sia4!<>gOS.
i>df httu: / /w"iiiriiir»rapo»a«yir/reguiiJM&-
r m /aclams. html
New information in yesterday. All of
the wells north of Hot Springs are in the
Mttnnelusa. According to Ken BuMer of
the South Dakota Department of
Environment and Natural Resources
Cor DE2MEO, said there are hundreds to
thousands of domestic wells using
water from the Minnelusa aquifer. 196
appropriated ^urater rights permits in
the Minnelusa which include
municipal, commercial, and industrial
*W CSSL^Pk
-------
Gmail - Infonnation on vour article
Oo^ii
-H
Page 1 of 1
r'h.i;! f!)f.
fu
f
* {
'{'if
Information on your article
Drat To: "journal com1
Tue, May 9, 2017 at 9:38 AM
Hi Seth, I spoke with you briefly before tie hearing started yesterday
Your line is today's report is riot necessarily tine "The uranium would be sold, processed and used
elsewhere to produce nuclear energy," Once the uranium leaves the US border, there is no control over
what, where, to whom it goes
Azarga is a huge international company who's purpose is to sell uranium to the highest bidder. Some
country may buy it for a nuclear power plant; some group
may buy it for bombs and even Azarga may riot know; t just is a money transaction
I also have concerns about tie process part too, As the yellow cake is obtained, processed and
stored, and then eventually shipped to the border, what security is there that some wbacko doesn't blow it
up, it would be devastating.
In addition, as trucks come in the dark of night and dump toxic waste into tie deep holes, who oversees
what is bang dumped and where did it come from? Is there going fo be a 24 hour security guard (in
pepntuity sp?) and how would he be even able to know what awful stuff is in those containers7
As one lady said yesterday, if something bad_h
enforcement to get out there.
ns at that site, it could take several hours for law
Thanks
/-ry. • 11 . • ?,<,
1 . 1 < ' ! '| "• < 1)1 • * . . V> 'I, II'1 . ,i >. »4 ' Mlt'lU !u I v.'f',,1 ' ' « . , ' I ' I '',1-' o.. « l' i 1 X >f(|> « *•'<' 1 t I .
AiJik, AmixU
2, that If the water in the Minnelusa lows east and south, contaminating those households and farms above and ultimately ends
up in ins qreat (jqsafa aquifer that sewiees the entire centra! US
i. i rial timet Burdock has two geologic anomalies that preclude use as an iSL mining site ..the proximity of igloo, with 3674)00
tons of various neive gasses stored in known unstable containers in over 200 miles of tunnels. And the 7650 open old bore holes
that other sites do not have, that mix the waters of the aouifeis already, makiria containment it «• nninina or deposition
of toxic wastes.
speeificiily address the sublet of the class 3 mining inject* You wily warf
to be specific here...and those old boreholes were never closed. or if so, dosed improper* by TVA...76S0 of them are s«l open
a«l some have tenceposts in them, which the rotting wood further contaminates the aquifers ft touches, inoculating them with
fungi and bacteria that organify the metals, making them unavailable chemically from being extracted by the ion exchange
method, including uranium, which will continue to increase in the wastewater.
We are protesting the use of the minnelusa aquifer for dumping of haz waste...and we are questioning the ability of
Poweitech/azarga to be able to detoxify the radioactive metals of vanadium, thorium, strontium, uranium, thallium and lead
(which has radioactive forms) down to the levels m purity of stormwater that is required to be injected into a class S well that sits
between and in two drinking water aquftsn. («* Minnelusa is used for good quality drinking water in the area and the Madison).
No such plan has been demonstrated by Powertecch/Azarga. And if such was even possible, that water would be worth gold in a
high dry area of the country, and used for irrigation of crops and farm animal use, and treated with conventional water softener
and 110 at the sink for household drinking water, as the minnelusa is now in t he radioactive metals that are
> ncern. if that water was get, .<,<»<> W - ,mm, then it would not have to be dispose , s - « well int h e first
place. And those 7650 open boreholes, existing »m an uplift area of numerals cracks, Isswes, fractures, breccia pips and sMchoies
fiat exist there, that are already allowing for It* mixing of aquifers. does not allow for tne containment of anything you put down
in the ground, no waller what level, This includes trie class 3 =t.««§ wells,
2&tk •fH&searchs-aralls&msg-- 15k... S/WWll
-------
-------
Declaration of the World Nuclear Victims Forum in Hiroshima
{Draft Elements of a Charter of World Nuclear Victims' Rights)
November 23, 2015
1. We, participants in the World Nuclear Victims forum, gathered in Hiroshima from November 21 to 23 in
2015, 70 years after the atomic bombings by the US government,
2. We define the nuclear victims in the narrow sense of riot distinguishing between victims of military and
industrial nuclear use, including victims of the atomic bombings in Hiroshima and Nagasaki and of
nuclear testing, as well as victims of exposure to radiation and radioactive contamination created by
the entire process including uranium mining and milling, and nuclear development, use and waste. In
the broad sense, we confirm that until we end the nuclear age, any person anywhere could at any time
become a victim=a potential Hibakusha, and that nuclear weapons, nuclear power and humanity
cannot coexist,
3. We recall that the radiation, heat and blast of the atomic bombings of Hiroshima and Nagasaki
sacrificed not only Japanese but also Koreans, Chinese, Taiwanese and people from other countries
there as a result of Japan's colonization and invasion, and Allied prisoners of war. Those who survived
"tasted the tortures of hell," We pay tribute to the fact that the Hibakusha question the responsibility
of the Japanese government which conducted a war of aggression; call for recognition of the right to
health and a decent livelihood; have achieved some legal redress and continue to call for state redress
to be clearly incorporated within the Atom Bomb Victims Relief Law; struggle to guarantee the rights of
those who experienced the atomic bombings yet are not recognized as Hibakusha; and call not only for
nuclear weapons abolition but also oppose nuclear power restarts and exports, and demand adequate
assistance for nuclear power plant disaster victims,
4. We noted that through the international conferences on the humanitarian impact of nuclear weapons
held in Oslo in 2013 and in Nayarit and Vienna in 2.014, the understanding is widely shared
internationally that the detonation of nuclear weapons would cause catastrophic harm to the
environment, human health, welfare and society; would jeopardize the survival of the human family;
and adequate response is impossible. We warmly welcome the Humanitarian Pledge endorsed by 121
states, pledging to fill the legal gap for the prohibition and elimination of nuclear weapons. We support
the adoption in early November 2015 at the UN General Assembly First Committee, by an
overwhelming majority of 135 in favor with only 12 opposed, of a resolution convening an open-ended
working group "to substantively address concrete effective legal measures... and norms that will need
to be concluded to attain and maintain a world without nuclear weapons,"
i
-------
5. We acknowledge that the mining and refining of uranium, nuclear testing, arid the disposal of nuclear
waste are being carried out based on ongoing colonization, discriminatory oppression, and
infringement of indigenous peoples* rights, including their rights to relationships with their ancestral
land. These activities impose involuntary exposure to radiation and contaminate the local environment.
Thus, the local populations are continually and increasingly deprived of the basic necessities for human
life with ever more of them becoming nuclear victims,
6. We also reconfirmed that every stage of the nuclear chain contaminates the environment and damages
the ecosystem, causing a wide array of radiation-related disorders in people and other living beings.
Through the experience of the nuclear disasters at Chernobyl and Fukushima, we see that nuclear
accidents inevitably expose entire populations living near the power plants and the workers assigned to
cope with the accident to harmful levels of radiation, and that adequate response to such a disaster is
impossible. We further see that radioactive contamination is inevitably a global phenomenon. We know
that "military" and "industrial" nuclear power are intimately connected within a unified nuclear
industry, and that every stage of the nuclear chain, including the use of depleted uranium weapons,
y creates large numbers of new nuclear victims.
7. Complete prevention of nuclear chain related disasters is impossible. No safe method exists for
disposing of ever-increasing volumes of nuclear waste. Nuclear contamination is forever, making it
utterly Impossible to return the environment to Its original state. Thus, we stress that the human family
must abandon its use of nuclear energy.
8. We acknowledge that the Atomic Bomb Trial against the State of Japan (the Shimoda Case; December
1963) found that the US military violated international law in dropping the atomic bombs, and that the
advisory opinion issued by the International Court of Justice stated that "there exists an obligation to
pursue in good faith and bring to a conclusion negotiations leading to nuclear disarmament in all its
aspects under strict and effective international control" (July 1996). We support the Marshall Islands,
whose people have suffered the effects of intensive nuclear testing, In bringing this issue back to the
Court in April 2014 through filing cases against nine nuclear armed states.
Furthermore, we recall the World Conference of Nuclear Victims which pursued criminal liability on the
part of the nuclear weapon states and the nuclear industry {New York Resolution, 1987), and that the
military industrial complex was found to have the responsibility of providing damages compensation
(Berlin Resolution, 1992). In addition, we confirm that the International People's Tribunal on the
Dropping of Atomic Bombs on Hiroshima and Nagasaki found all 15 defendants guilty, including
President Truman (July 2007).
9. We emphasize that all states that promote nuclear energy, the operators that cause radioactive
contamination, and the manufacturers of nuclear facilities including nuclear power plants must bear
2
-------
liability for damages clone, as do their shareholders and creditors. We are gravely concerned that the
export of nuclear power plants is extremely likely to result in severe human rights abuses and
environmental damage.
10, We accuse the International Atomic Energy Agency (IAEA) and the International Commission on
Radiological Protection (ICRP) of underestimating the harm done by radiation exposure and hiding the
true effects of nuclear power accidents. We demand the abolition of the IAEA's mandate to "promote
the peaceful use of nuclear power".
11. We have identified that the military-industrial-government-academic complex and states that support it
have, through the use of nuclear energy, degraded the foundations of human life, and violated the right
to life of all living beings. We assert that the acts of members of this complex violate fundamental
principles of international humanitarian, environmental and human rights law.
12. We condemn the Japanese government for failing to learn from the Fukushima disaster, without
j carrying out adequate investigations into the facts and impacts/hiding and trivializing the damage, and
I cutting off assistance to the victims, while investing in the restart and export of nuclear power plants.
We oppose the building, operating or exporting of nuclear power plants or any industrial nuclear facility
in Japan or any other country.
^*•^113. We call for the termination of uranium mining, milling, nuclear fuel production, nuclear power
generation and reprocessing, and for the abolition of the entire nuclear chain.
14. We call for the urgent conclusion of a legally binding international instrument which prohibits and
provides for the elimination of nuclear weapons.
15. We call for the prohibition of manufacture, possession and use of depleted uranium weapons.
16. With the momentum of this World Nuclear Victims Forum, we confirm our desire to continue to
cooperate in solidarity and share information regarding nuclear victims, and disseminate our message
through various methods including art and media.
17. Thus, as a result of this World Nuclear Victims Forum and in order to convey to the world the draft
elements of a World Charter of the Rights of Nuclear Victims, we adopt this Hiroshima Declaration.
3
-------
Draft Elements of a World Charter of the Rights of Nuclear Victims
[I] The Basis of Rights of Nuclear Victims
1. The natural world is the foundation of all life, and each human being is an integral member of the
human family innately endowed with the right to partake in human civilization with equal rights to life,
physical and emotional wellbeing, and a decent livelihood.
2. All peoples have the right to be free from fear and want, and to live in an environment of peace, health
and security.
3. Each generation has the right to enjoy a sustainable society and the responsibility of effective
stewardship for the benefit of the future generations of all living beings.
4. There exists the inherent dignity of the human person and the right of all peoples to self-determination
as enshrined in the Charter of the United Nations, the rights to life, health and survival as stipulated in
international positive law including the Universal Declaration of Human Rights, International Covenants
on Human Rights, and the Declaration of the Rights of Indigenous Peoples, as well as exists the principle
of international customary law which helps to shape the emerging "law of humanity".
[II] Rights
(1) To alleviate current and prevent future nuclear catastrophes, all persons living in the nuclear age have the
right to demand the following:
1. Not to be exposed to ionizing radiation other than that which occurs in nature or is for medical
purposes,
2. Prohibition of coerced labor involving potential exposure to ionizing radiation, and when labor involving
such potential exposure cannot be avoided, for exposure to be minimized,
3. Minimization of medical exposure to ionizing radiation, and
4. Full, accurate information regarding the dangers of ionizing radiation exposure through school and
community education; this information to include the facts that no level of radiation exposure is
without risk and that children, women and girls are especially sensitive to radiation.
(2) Additionally, nuclear victims have the right to demand the following:
5. Nuclear victims have rights under domestic law derived from human rights and basic freedoms,
including personal rights and the right to health.
6. To receive free of charge the best possible medical care and regular examinations for effects related to
past, present and future exposure; this right to extend to the 2nd, 3rd and future generations.
4
-------
7. An apology and compensation from the offending party for all damage to life, health, finance, suffering,
arid culture related to the use of nuclear energy,
8. The remediation of radiation contaminated land and domicile, and the renewal of community and local
culture,
9. Thorough scientific investigation of the victim's exposure by competent scientists independent of the
offending party, with all findings and information completely open to the public, and the victims
themselves involved in the investigation and control of information.
10. To not be forced to return to radiation contaminated land, and for the freedom to choose whether to
evacuate from or remain in a radiation affected area. And, no matter this choice, to receive support to
minimize exposure to radiation, protect health, arid maintain and rebuild a way of life,
11. To refuse to work in an environment where radioactive contamination could constitute a health threat,
said refusal having no negative ramifications for the victim.
-------
Tunnel with nuclear waste collapses in Washington state
Page 1 of 5
.VATCH LIVE: Sean Spicer takes questions on Yates testimony, Afghanistan troops at White House
Press
2 hrs ago
FBI to clarify Comey's GOP town halls go Jimmy Carter reveals Tunnel with nuclear New dino
testimony on Clinton... viral he didn't vote for,.. waste collapses in... identified
Tunnel with nuclear waste collapses in Washington
state
<"
/23
http://www.msn.com/en-us/news/us/tunnel-with-nuclear-waste-collapses-in-washington-state/ar-BBAWFTA?li=... 5/9/2017
-------
Tunnel with nuclear waste collapses in Washington state
Page 2 of 5
© Ted S. Warre An emergency has been declared at the Hartford Nuclear Reservation after a portion of a
tunnel that contained rail cars full of nuclear waste collapsed.
SPOKANE, Wash. (AP) — A portion of a storage tunnel that contains rail cars full of
radioactive waste collapsed Tuesday morning, forcing an emergency declaration at the
^ssMate^riss"" Reservatlon 'n southeastern Washington state,
2 hrs ago
Officials detected no release of radiation and no workers were injured, said Randy Bradbury,
a Sptrtasman for thefVasttagton stat
Hanford for decades made plutonium for nuclear weapons and is now the largest
depository of radioactive defense waste that must be cleaned.
It contains about 56 million gallons of radioactive waste, most of it in 177 underground
tanks.
Bradbury said the collapse occurred at one of two rail tunnels under the PUREX site.
In the past, rail cars full of radioactive waste were driven into the tunnels and then buried
there, he said.
Hanford has more than 9,000 employees.
The site was built during World War II and made the plutonium for most of the U.S. nuclear
arsenal, including the bomb dropped on Nagasaki, Japan, at the end of the war.
http://www.msn.oom/en-us/news/us/tunneI-with-nuclear-waste-collapses-in-washingtofl-state/ar-BBA^WFTA?li=.. 5/9/201?
-------
US a
»§ § i
¦2"gu*
•£ Jl w* p
2 JS> &• o>
a« c6 3
r s g g
Nebraska utility head recommends
closing small nuclear power plant
•um %**. %&*.%, J*-***?
sday thaMtjJoesaJt
; econqfSIirUanse to
ASSOCIATED P«tSS
OMAHA, Nek - The
head of a Nebraska utility
recommended shutting
down the nation's small-
est nuclear power plant by
the end of the year, saying
Thursday that
make
keep it open.
Tim Burke, the president
and CEO of the Omaha
Public Power District, told
the utility's board that Fort
Calhoun Nuclear Station
isn't financially sustainable.
Shuttering the plant
would represent a major
shift for the utility, which
serves more than 310,000
customers in 13 counties
in southeastern Nebraska.
Utility officials previously
maintained that Fort Cal-
houn would be a valuable
part of its plans because of
its ability to generate power
without adding to carbon
dioxide emissions.
The board is expected to
vote on the recommenda-
tions at its fune 16 meeting.
The district spends about
$650 million a year on gen-
erating power, which in-
cludes about $250 million
on Fort Calhoun, Burke said
closing the nuclear plant
will help keep the, utility's
rates low compared to the
average power cost in the
region.
The utility also lias to
make sure its mix of power
plants can comply with en-
vironmental rules and re-
strictions on carbon dioxide
emissions. The district typ -
ically gets about 34 percent
of its power from the Fort
Calhoun plant, but utility
officials said Thursday that
other carbon-free options,
such as wind power, now
make better financial sense.
The economics of the
utility business have
changed significantly in
recent years because of
new environmental regu-
lations and cheaper natural
gas prices due to hydraulic
fracturing. Fort Calhoun's
small size and single reac-
tor contributed to the rec-
ommendation to close it.
"It's fust not viable. It's
just not economically vi-
able," boafd member John
Green said.
Smaller nuclear plants,
like Fort Calhoun, have the
most difficult time compet -
ing on the price of power,
especially if they have had
serious safety problems,
said Mark Cooper, a senior
fellow for economic analy-
sis with the Institute for En-
ergy and the Environment
at Vermont Law School.
"The older, smaller reac-
tors are really uneconomic,"
Cooper said.
That description fits sev-
eral reactors that closed in
recent years, such as the
Vermont Yankee in Vermont
plant that was shut down
in 2014 or the Kewaunee
Power Station in Wiscon-
sin that shut down in 2013.
New Orleans-based En-
tergy Corp. has announced
plans to close two more of
its smaller, older plants by
the end of the decade -
Fitzpatrick nuclear plant
near Syracuse, N.Y., and
Pilgrim nuclear plant near
Boston. Entergy also owns
Vermont Yankee.
It's relatively rare forutil-
ities to close a nuclear power
plant unless there are major
mechanical problems, but
all nuclear plants face eco-
nomic pressure because of
the cheap natural gas and
affordable power that can
be purchased wholesale
from other utilities.
"The industry is having
trouble competing with
costs," said David Loch-
baum, director of the Nu-
clear Safety Project for the
nonprofit group Union of
Concerned Scientists,
Adding to Fort Calhoun's
problems is a series of set-
backs it has had in recent
years. The utility spent
more than $140 million on
repairs after flooding and a
small fire damaged the plant
in2011.
Among the violations
cited by regulators was the
failure of A key electrical
part during a 2010 test, a
small electricfd fire in June
2011, several security issues
and deficiencies in flood
planning that were discov-
ered a year before the river
spilled its banks.
It resumed operations in
December 2013 after the
utility hired Chicago-based
Exelon, the largest U. S. op -
erator of nuclear power
plants, to run Fort C alhoun.
OPPD estimates that it
will cost $884 million to de-
commission Fort Calhoun
over at least a decade.
-------
rapid City journal
Prairie erouse hunting Man arrested in shooting
Kraine grouse IIUIILIIIg Spearfish man, 32, charged in Belle Fourche
More birds than past years oitooms.pamb, incident loc«.mw5,moe«
MOSTLY CLOUDY 63 • 51 FORECAST, Cl I THURSDAY, SEPTEMBER 22,2016 | rapidcityjournal.com
Study raises uranium concerns
Environmentalists:
Angostura has
elevated levels
JOURNAL STAFF
Members of three activ-
ist groups say recent research
shows that abandoned uranium
mines are contributing to ele-
"VatecTuranTmn leveEin Angos-
tura Reservoirin the souther
Bjac^Hills
The research was recently
published in the journal Envi-
ronmental Earth Sciences by
authors that included two South
Dakota School of Mines & Tech-
nology scientists, Rohit Sharma
and fames Stone. The article is
titled "Stream sediment geo-
chemistry of the upper Chey-
enne River watershed within the
abandoned uranium mining re-
gion of the southern Black Hills."
According to the Clean Water
Alliance, Dakota Rural Action
and It's All About the Water, the
research shows that elevated
uranium levels at Angostura are
partly caused by human activ-
ity, including abandoned ura-
nium mines and a former mill
at Edgemont. Elevated uranium
levels at Angostura Reservoir
are comparable to the elevated
uranium levels upstream in the
Cheyenne River watershed at
abandoned mines, the groups
said.
"This impacts people through -
out western South Dakota," Gena
Parkhurst, president of the Black
Hills Chapter of Dakota Rural
Action, said in a news release.
"The Cheyenne River runs along
or through two reservations and
five counties. It impacts agri-
culture and tourism. We need to
clean it up."
The groups cited U.S. Envi-
ronmental Protection Agency
reports that list 169 old ura-
nium mines and prospects in the
southern Black Hills, which was
mined for uranium from 1951 to
1972. Few of the old mines have
been cleaned up. Additionally,
the groups said there was a 1962
dam break that released uranium
mill wastes into the Cheyenne
River, and some of the wastes
reached Angostura, a popular
recreation spot.
The groups are using the re-
search to call upon state and
federal regulators to clean up old
mine sites. The EPA studied sev-
eral abandoned mine sites north
Please see URANIUM, Page A2
JOURNAL FILE
Three activists groups say abandoned uranium mines, like this one near
Edgemont, are contributing to elevated uranium levels in Angostura Reservoir.
-------
Uranium
FremAi
of Edgemont lafct year and de-
termined that although the sites
contained pollutants, there had
not been a release of the material
that was sizable enough to neces-
sitate a cleanup.
Lilias larding, of the
Clean Water Alliance, said
the recent research by the
Mines scientists shows
otherwise.
"These radioactive mines
have been sitting open for
as much as 65 years," find-
ing said in the news release.
"These test results make it
clear there is a problem that
threatens public health and
demands immediate ac-
tion."
Aside from the concerns
about abandoned histori-
cal mines in the Edgemont
area, a proposal to conduct
a new kind of uranium
mining in the same area
is pending from Azarga
Uranium Corp. Instead of
digging tunnels and open
pits as past mining oper-
ations did, Azarga wants
to conduct in situ mining,
which involves injecting a
solution of water, oxygen
and carbon dioxide to leach
uranium from underground
ore before pumping it to the
surface.
Uranium is a naturally
occurring radioactive ele-
ment that was mined his-
torically for use in nuclear
weaponry and is now mined
for nuclear power genera-
tion. Naturally occurring
uranium in rock foim is
not typically hazardous,
because the skin blocks
uranium's alpha-particle
radiation.
But if uranium particles
are ingested in high con-
centrations via air or water,
they can cause cancer.
CITY JOURNAL
Uranium
areeftoTix
AJHOCUTID PROS
CHEYENNE, Wyo.
nlum
• A lira-
compaisy~-has
agi^eJWcorTeTGTOftteffSTifes
afterjwo spills j&f-radioac -
ti.Yf» sTudge"fthe most recent
"on March. 29 when some of
the material from a Wyoming
mine leaked from a truck
onto a highway, the Nuclear
Regulatory Commission said
Wednesday.
The low-level radioactive
sludge leaked onto U.S. 191
outside a radioactive waste
disposal facility in Utah, the
NRC said in a letter Tuesday
to Brent Berg, the president of
mine owner Cameco.
The company isn't aware of
any danger to the environment
or people, Cameco spokesman
Kenneth Vaughn said Wednes-
day.
Besides failing to prevent
the spill, Saskatchewan-based
Cameco failed to accurately
determine the amount of
radioactive material in the
sludge and adequately doc-
ument the material in ship-
ping papers, according to the
NRC.
Cameco said it has agreed to
halt shipping barium sulfate
sludge without NRC approval,
identify specifically what
caused the two spills, report
on all sludge shipments to the
disposal facility in Blanding,
Utah, over the past three years
and develop a plan to correct
the problem.
A similar leak happened last
summer. The white, paste-
like sludge is a normal by-
product of in-situ uranium
mining, a process that in-
volves pumping water mixed
with oxygen and baking soda
into uranium-bearing sand-
stone deposits underground
and pumping a solution
containing uranium to the
surface.
The solution is processed"
into yellowcake, which can be
processed further into nuclear
fuel.
Cameco has suspended
sludge Shipments from its
mine while investigating
how to prevent another leak,
Vaughn said.
The company ships the ma-
terial by truck for disposal ev-
ery six months. Last year's leak
happened at the bottom of the
15.5-foot-long shipment con-
tainer and this year's happened
at a lid at the top, Vaughn said.
"We are investigating all
ways we can ensure this does
not happen again," Vaughn
said.
Ryan Johnson with the Utah
Department of Environmental
Quality said where along the
truck's route through Wyo-
ming, Colorado and Utah the
leak began is unknown.
Testing with radiation
monitors at places where
the truck likely stopped or
turned showed no sign of
leakage less than a week af-
ter this year's spill, Vaughn
said.
Workers washed the white,
paste-like material that spilled
onto U.S. 191 off the pavement
and removed S yards to 6 yards
of potentially contaminated
soil, according to a report by
Colorado-based Energy Fuels
Resources, owner of the White
Mesa Mill.
Wyoming is home to four
of the nation's six operational
in-situ uranium mines and is
the top uranium-producing
state. Smith Ranch-Highland,
capable of producing up to 5.5
million pounds of uranium
hexafluoride annually, is the
biggest in-situ uranium mine
» by production volume in the
¦ U.S.
-------
Ripples from nuclea
closings overwhelm^
ASSOCIATED PRMS
OAK HARBOR, Ohio -
Living in the shadows of the
Davis-Besse nuclear power
plant's cooling tower, which
soars above Lake Erie in Ohio
like an oversized lighthouse,
brings with it some give-
and-take.
On the plus side, it gen-
erates tax money that once
paid for a high school swim -
ming pool and auditorium.
Thin there are the stockpiles
of radiation pills and emer-
gency drills for students in
case of a disaster.
For the small, mostly ru-
ral towns that are home to
61 U.S. nuclear plants that
produce one-fifth of the
nation's electricity, each
one has been like the golden
goose supplying high-pay-
ing jobs and money for
roads, police and libraries.
But those same places and
their residents are bracing
for what may come next
due to the soaring costs of
running aging reactors that
have speeded up the closings
of a handful of sites and are
threatening at least a.dozen
more. That's because once
the power stops flowing, so
does the money.
Towns that already have
seen nuclear plants shut-
tered are now dealing with
higher property taxes, cuts
in services and less school
funding — a new reality that
may linger for decades.
In Wisconsin, the tiny
town of Carlton saw the
source of rouglily 70 per-
cent of its yearly budget dis - s
appear when the Kewaunee •
nuclear power plant closed
four years ago. That resulted
in the first town Ux in its
history.
"Financially, we bene-
fited, tat now we're going to
pay the price for the next. 40
years," said David Hardtke,
the town chairman.
When operations ceased
at the Crystal River Nuclear
Plant along Florida's Gulf
Coast, "it was like some-
thing going through and
wiping out a third of voui
county," said Citrus County
Administ rator Randy Oliver.
To make up the difference,
property tax rates went up by
31 percent and 100 county
workers were let go — so
many that Oliver worries j
there won't be enough to |
evacuate residents and clear
roads if a major tropical
storm bits.
While the nation's fleet of
nuclear power plants wasn't
designed to last forever, do -
sures are happening earlier
than expected because re-
pair costs are astronomical
and it's harder to compete
with cheaper natural gas-
fired plants and renewable
energy sources.
The former head of the
nuclear industry's trade
group said last year that eco-
nomic pressures have put 15
to 20 plants at risk of a pre-
mature shutdown.
FirstEnergy Corp. will de -
cide by next year whether to
close or sell its plant in Penn -
sylvania and two in Ohio,
including Davis-Besse, un-
less the states change regu-
lations to make them more
competitive.
The uncertainty around
Davis-Besse and a plan to
lower its value caused the
w local school board to shelve
i plansto build a new elemen-
tary building for the district,
which stands to lose $8 mil-
lion a year without the plant.
New Orleans-based En-
tergy Corp., owner of the
Palisades nuclear plant in
Michigan, announced plans
Me last year to close in 2018
even though it has a license
to keep operating another 14
years.
How much the losses will
add up to isn't clear yet, said
Dennis Palgen, a township
supervisor where the plant
has operated since 1971.
"We're just in a state
limbo right now," he sail
adding that plans to buy
new fire truck are on hold.
Hie plant and its 60'
workers have been goo<
neighbors, he said, buytoj
backpacks for school chil-
dren and emergency gener-
ators for the township. "The
list goes on and on," Palgen
said.
In some cases, utilities
are paying communities and
schools during the first few
years to help ease the sudden
loss of theitlargest employer
and taxpayer. .
But what makes recov-
ering tough is that almost
all nuclear plants are in
out - of-the - way places that
have become heavily reliant
on them. And they employ
specialized workers who are
quick to leave for still-oper-
ating locations. '
To make matters worse,
many closed sites can't be
redeveloped for new uses
because they're still storing
radioactive waste.
Some hope the Trump
administration's new bud-
get proposal to revive the
mothballed disposal site at
Nevada's Yucca Mountain
will eventually allow for new
development at the former
"We have become a de
facto midpar'wasfe dump.
It just sits "there,-mid sits
tMfe'fcifever,'' said A1 Hill,
ffieiriayor in Zion, 111., where
spent nuclear fuel remains
stored on prime property
along Lake Michigan even
ithough the plant shut down
20 yeais ago.
On-top of that. the closing
took away half of the city's
tax base and pushed prop-
erty taxes to the highest in
the state, making it difficult
to lure new businesses, Hill
said.
Left behind are empty
storefronts and little foot
traffic, said Chris Daisy,
who runs a downtown bicy-
cle shop.
"It's had a devastating ef-
fect on this town," he said.
-------
The recycled water -would be "returned to a quality as close to pre-mining conditions as can practically be
achieved,according to Powertech.
Hollenbeck said uranium is only released in an oxygen-rich environment, such as during in-situ mining. He said
uranium that isn't extracted would remain trapped below ground by surrounding bedrock, which is oxygen
deficient.
Other toxic metals, like radium, and other by-products would be removed and shipped offsite for proper
disposal, according to Powertech. The company also said leaching chemicals wouldn't be used in the mining
process; only water, oxygen and carbon dioxide.
As for the economy, Hollenbeck said there would only be a positive impact.
"Projects that produce $40 million worth of economic development in western South Dakota don't come along
every day," he said "Most of that would be funneled through Rapid City."
He said Powertech has already invested heavily in Rapid City on contractors and equipment, and that the
mine's piping would come from the city's WL Plastics when it opens.
Hollenbeck pointed to regional in-situ mining operation in the light ofsuccess.
"This isn't a new technology." he said. 'This isn't a new idea. This has been going on for an extended amount of
I know this is a lot of information. Thank you for taking the time. In closing, here are some violations in a
neighboring ISL mine:
• Mar. 14,2U13: fcvaporation Fond 1 liner leak
• Jan. 18,2013: Well fails mechanical integrity test
• Oct. 24,2012: Well fails 20-year mechanical integrity test
• Aug. 20,2012: Well fails 5-year mechanical integrity test
• June 4,2012: Well fails 5-year mechanical integrity test
• May 25,2012: Monitor well fails 15-year mechanical integrity test
• • Oct. 7, 2011: Monitor well excursion
• Aug. 9,2011: Exceedance of Well Head Manifold Pressure Limitations
• July 18,2011: two wells fail 5-year mechanical integrity test
• June 1,2011: Evaporation Pond 1 liner leak
• May 27,2011: two Monitor well excursions
• May 24,2011: Monitor well excursion
• Mar. 16,2011: Monitor we'll excursion
• Jan. 13,2011: Monitor well excursion
• July 8,2010: Monitor well excursion
• July 6,2010: Well fails 5-year mechanical integrity test
• June 22, 2010: Excursions at two monitor wells "due to increased groundwater levels"
• June 22,2010: Monitor well excursion
• June 16,2010: Excursions at three monitor wells "due to increased groundwater levels"
time."
2
-------
• June 11,2010; Evaporation Pond 3 liner leak detected
• May 10,2010: Well fails 5-year mechanical integrity test
• Apr. 13,2010; Excareion at monitor well due to "natural conditions"
• Dec. 31,2009; Evaporation Pond 4 Liner Leak
• Nov. 19,2009: Well fails 15-year mechanical integrity test
• Oct. 15,2009; Mechanical integrity test missed for two wells
• June 18,2009: Evaporation Pond 4 liner leak detected
• June 11,2009: Monitor well excursion
• June 5,2009: Evaporation Pond 1 liner leak detected
• April 27,2009: Monitor well placed on excursion status
• April 17,2009: Production well fails 5-year mechanical integrity test
• June 4,2008: Exceedance of Well Head Manifold Pressure Limitations
• May 31,2008: Monitor well placed on excursion status
• May 23, 2008: | 50.000 penalty imposed for violations ~
• May 19,2008: Monitor well placed on excursion status
• April 29,2008: Five-year mechanical integrity test missed for 42 wells
• September 26,2006: Monitor well placed on excursion status
• May 5,2006: leak detected at Pond 4
• January 19,2006: Monitor well placed on excursion status
• October 27,2005: Injection well leak detected
• August 4,2005: Monitor well placed on excursion status
• June 28,2005: Monitor well placed on excursion status
• June 17,2005: Monitor well placed on excursion status
• May 2,2005: Monitor well placed on excursion status
• May 14,2004: leak detected at Pond 1
• December 23,2003: Monitor well placed on excursion status
• December 26,2002: Monitor well placed on excursion status
• September 10,2002: Monitor well placed on excursion status
• April 4,2002: Monitor well placed on excursion status
• December 4,2001: Monitor well placed on excursion status
• March 2,2001: Monitor well placed on excursion status
• September 10,2000: Monitor well placed on excursion status
• May 26,2000: Monitor well placed on excursion status
• April 27,2000: Monitor well placed on excursion status
• March 6,2000: Monitor well placed on excursion status 7~
» July 2,1999: Monitor well placed on excursion status —'
• August 7,1998: Spill of 10,260 gallons of injection fluid
• March 21,1998: Monitor well placed on excursion status
• August 12,1997: Discovery of Pinhole Leaks in Upper Liner of Process Water Evaporation Pond
Source: http://www.wise-uranium.Org/umoPUSi.html#CRQWB
Remember, if the permits are granted, due to state legislation removed in 2011, the DENR will no longer
have the authority to do anything regarding ISL sibling - no bonds, oversight, or penalties for license
violations.
Be well,
1
3
-------
• Poisoning the Well: How the Feds Let Industry Pollute the Nation's Underground Water Supply - ProPublica Page I of 4
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Federal officials law given emer©- and mining companies perm ission to pollute aquifers in more than 1,500 places across the oountiy,
releasing tcacic material into underground reservoirs that help supply more than half of the nation's drinking water,
¦ ^ In many cues, the Environmental Protection Agency has granted these so-called aquifer exemptions in Western states now stricken by
drought and increasingly desperate for water.
EPA records show that portions of at least 100 drinking water aquifers have been written off because exemptions haw allowed them to be
used as dumping grounds.
Ton are sacrificing these aquifers," said Mark Williams, a hydrologist at the University of Colorado and a member of a National Science
Foundation team studying the effects of energy development on the environment. "By definition, you are putting pollution into them.... If
you are looking 50 to 100 years down the road, this is not a good way to go."
As part of an investigation into the threat to water supplies from underground injection of waste, ProPublica set out to identify which
aquifers have been polluted.
*—-4 We found the EPA has not even kept track of exactly how many exemptions it has issued, where they are, or whom they might affect.
"\j What records the agency was able to supply under the Freedom of Information Act show that exemptions are often issued in apparent
conflict with the IPA's mandate to protect waters that may be used for drinking.
\ , Though hundreds of exemptions are for lower-quality water of questionable use, many allow grantees to contaminate water so pure it
would barely need filtration, or that is treatable using modern technology.
httns://www nrormhlica oTv/article/noisoninff-the-well-how-the-feds-let-rndastrv-nollute-the-nationvundereroun
-------
Poisoning the Well; How the Feds Let Industry Pollute the Nation's Underground Water Supply - ProPublica Page 2 of 4,
The 1PA is only supposed to issue exemptions if aquifers are too remote, too dirty, or too deep to supply affordable drinking water,
Applicants must persuade the government that the water is not being used as drinking water and that it never will be.
Sometimes, however, the agency has issued permits for portions of reservoirs that are in use, assuming contaminants will stay within the
finite area exempted.
In Wyoming, people are drawing on the same water source for drinking, irrigation and livestock that, about a mile away, is being fouled
with federal permission. In Texas, EPA officials are evaluating an exemption for a uranium mine - already approved by the state — even
though numerous homes draw water from just outside the underground boundaries outlined in the mining company's application.
The EPA declined repeated requests for interviews for this story, but sent a written response saying exemptions have been issued
responsibly, under a process that ensures contaminants remain confined.
"Aquifer Exemptions identify those waters that do not currently serve as a source of drinking water and will not km as a source of
drinking water in the future and, thus, do not need to be protected," an EPA spokesperson wrote in an email statement. "The process of
exempting aquifers includes steps that minimize the possibility that future drinking water supplies are endangered,"
Yet EPA officials say the agency has quietly assembled an unofficial internal task force to reevaluate its aquifer exemption policies. The
agency's spokesperson declined to give details on the group's work, but insiders say it is attempting to inventory exemptions and to
determine whether aquifers should go unprotected in the future, with the value of water rising along with demand for exemptions closer to
areas where people live.
Advances in geological sciences have deepened regulators' concerns about exemptions, challenging the notion that waste injected
underground will stay inside the tightly drawn boundaries of the exempted arras,
"What they don't often consider is whether that waste will flow outside that zone of influence over rime, and there is no doubt that it will,"
said Mike Wire man, a senior hydrologist with the EPA who has worked with the World Bank on global water supply issues. "Over decades,
that water could discharge into a stream. It could seep into a well. If yoa are a rancher out there and you want to put a well in, it's difficult
to find out if there is an exempted aquifer underneath your properly."
Aquifer exemptions are a little-known aspect of the government's Underground Injection Control program, which is designed to protect
water supplies from the underground disposal of waste.
The Safe Drinking Water Art explicitly prohibits injection into a source of drinking water, and requires precautions to ensure that oil and
gas and disposal wells that run through them are carefully engineered not to leak.
Areas covered by exemptions are stripped of some of these protections, however. Waste can be discarded into them freely, and wells that
run through them need not meet all standards used to prevent pollution. In many cases, no water monitoring or long-term study is
required.
The recent surge in domestic drilling and rush for uranium has brought a spike in exemption applications, as well as political pressure not
to block or delay them, EPA officials told ProPubllea.
"The energy policy in the U.S is keeping this from happening because right now nobody - nobody — wants to interfere with the
development of oil and gas or uranium," said a senior EPA employee who declined to be identified because of the sensitivity of the subject.
The political pressure is huge not to glow that down."
Many of the exemption permits, record* show, have been issued in regions where water is needed most and where intense political debates
are underway to decide how to fairly allocate limited water resources.
In drought-stricken Texas, communities are looking to treat brackish aquifers beneath the surface because they have run out of better
options and several cities, including San Antonio and El Paso, are considering whether to build new desalinization plants for as much as
$100 million apiece.
And yet environmental officials have granted more than 50 exemptions for waste disposal and uranium mining in Texas, records show.
The most recent was Issued in September.
The Texas Railroad Commission, the state agency that regulates oil and gas drilling, said it issued additional exemptions, covering large
swaths of aquifers underlying the state, when it brought its rules into compliance with the federal Safe Drinking Water Act in 1982. This
was in large part because officials viewed them as oil reservoirs and thought they were already contaminated. But it is unclear where, and
how extensive, those exemptions are.
EPA "Region VI received a road map — yes, the kind they used to give free at gas stations — with the aquifers delineated, with no detail on
depth," said Mario Salaxar, a former EPA project engineer w ho worked with the underground injection program for 25 years and oversaw
the approval ofTexas* program, in an email.
https://www.propublica.org/article/poisoning-the-well-how-the-feds-let-industry-pollute-the-natj(ms-undergroun 4/1/2016
-------
. Poisoning the Well; How the Feds Let Industry Pollute the Nation's Underground Water Supply - ProPubiica Page 3 of 4
In California, where nearly half of the nation's fruits and vegetables are grown with water from as far away as the Colorado River, the
perennially cash-strapped state's governor is proposing to spend $14 billon to divert more of the Sacramento Elver from the north to the
south. Near Bakers-field, t private project Is underway to build a water bank, essentially an artificial aquifer.
Still, more than 100 exemptions for natural aquifers have been granted in California, some to dispose of drilling and fracking waste in the
state's driest parts. Though moat date back to the 1980s, the most recent exemption was approved in 2009 in Kern County, an agricultural
heartland that is the epicenter of some of the state's most volatile rivalries over water.
The balance is even more delicate in Colorado, Growth in the Denver metro area has been stubbornly restrained not by available land, bat
by the limits of aquifers that have been drawn down by as much as 300 vertical feet. Much of Eastern Colorado's water has long been piped
underneath the Continental Divide and, until recently, the region was mulling a $3 billion plan to build a pipeline to bring water hundreds
of miles from western Wyoming,
Along with Wyoming, Montana and Utah, however, Colorado has sacrificed more of its aquifer resources than any other part of the
country.
More than 1,100 aquifer exemptions have been approved by the EPA's Rocky Mountain regional office, according to a list the agency
provided to ProPubiica. Many of them are relatively shallow and some are in the same geologic formations containing aquifers relied on by
Denver metro residents, though the boundaries are several hundred miles away. More than a dozen exemption* are in watere that might
not even need to be treated in order to drink.
"It's short-sighted," said Tom Curtis, the deputy executive director of the American Water Works Association, an international non-
governmental drinking water organization. "It's something that future generations may question."
To the resource Industries, aquifer exemptions are essential. Oil and gas drilling waste has to go somewhere and In certain par® of the
country , there are few alternatives to injecting it into porous rock that also contains water, drilling companies say, In many places, the
same layers of rock that contain oil or gas also contain water, and that water Is likely to already contain pollutants such as beniene from
the natural hydrocarbons within it.
Similarly, the uranium mining industry works by prompting chemical reactions that separate out minerals within the aquifers themselves;
the mining can't happen without the pollution.
When regulations governing waste injection were written in the 1980s to protect, underground water reserves, industry sought the
exemptions as a compromise. The intent was to acknowledge that many deep waters might not be worth protecting even though they
technically met the definition of drinking water.
"The concept of aquifer exemptions was something that we 'invented' to address comments when the regulations were first proposed,"
Salazar, the former EPA official, said. "There was never the intention to cxem pt aquifers just because they could contain, or would obviate,
the development of a resource. Water was the resource that would be protected above all."
Since then, however, approving exemptions has become the norm. In an email, the EPA said that some exemption applications had been
denied, but provided no details about how many or which ones. State regulators fa Texas and Wyoming could not recall a single
application that had been turned down and industiy representatives said they had come to expect swift approval.
^Historically they have been fairly routinely granting aquifer exemptions," said Richard Clement, the chief executive of Powertecl
Uranium, which is currently seeking permits for new mining fa South Dakota, There has never been a we that Tm aware of that it has
not been done."
*
-------
Poisoning the Well: How the Feds Let Industry Pollute the Nation's Underground Water Supply - ProPublica Page 4 of 4,
applicants to asses the quality of reservoirs and to do some basic modeling to show where contaminants should end up. But in most cases
there & no obligation, for example, to track what has teen put into the earth or — except in the case of the uranium mines — to monitor
where it does end up,
f The biggest problem now, experts say, is that the EPA's criteria for evaluating applications are outdated. The rales — last revised nearly
three decades ago — haven't adapted to improving water treatment technology and don't reflect the changing value and scarcity of fresh
water.
\ Aquifers once considered unusable can now be. processed for drinking water at a reasonable price.
The law define an underground source of drinking water as any water that has less than 10,000 part* per million of what are called Total
Dissolved Solids, a standard measure of water quality, but historically, water with more than 3,000 TDS has been dismissed as too poor for
drinking. It also has been taken for granted that, in most places, the deeper the aquifer — say, below about a,000 feet — the higher the TDS
and the less salvageable the water.
Yet today, Texas towns are treating water that has as high as 4,000 TDS and a Wyoming town is pumping from 8,500 feet deep, thousands
of feet below aquifers that the EPA has determined were too far underground to ever produce useable water.
"You can just about treat anything nowadays," said Jorge Arroyo, an enpneer and director of innovative water technologies at the Texas
Water Development Board, which advises the state on groundwater management. Arroyo said he was unaware that so many Texas aquifers
had been exempted, and that it would be feasible to treat many of them. Regarding the exemptions, he said, "Willi the advent of technology
to treat some of this water, I think this is a prudent time to reconsider whether we allow them."
Now, u commercial crops wilt in the dry heat and winds rip the dust loose from American prairies, questions are mounting about whether
the EPA should continue to grant exemptions going forward.
"Unless someone can build a clear case that this water cannot be used — we need to keep our groundwater clean," said Al Armendariz, a
former regional administrator for the EPA's South Central region who now works with the Sierra Club. "We shouldn't be exempting
aquifers unless we have no other choice. We should only exempt the aquifer if we are sure we are never going to use the water again."
Still, skeptics say fewer exemptions are unlikely, despite rising concern about them within the EPA, as the demand for space underground
continues to grow. Ijong-term plans to slow climate change and clean up coal by sequestering carton dioxide underground, for example,
could further endanger aquifers, causing chemical reactions that lead to water contamination.
"Everyone wants clean water and everyone wants clean energy," said Richard Heaiy, a geologist with the U J. Geological Survey whose
work is focused on the nexus of energy production and water. "Energy development can occur very quid# because there is a lot of money
involved. Environmental studies take longer."
Wet tfcte atoryfSIgn up for our dally newletter to get mora qfour beat work.
•S Com#* JOW Pubica ft*
UMwsoffwwiMnoM1 yoj mptiblmn our sum s
for free if you fo!h« mess miss.
Qowntemd Our Ms
Santf Us Hps or SmnMb Stcuwff
https://www.propublica.org/articte/poisoning-the-weU4iow-the-feds-let-industry-pollute-the-nations-undergroun 4/1/2016
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Way 22, 2014
RE; Comments to EPA on permits for in-situ uranium mining
1 attended 'two days of hearings in Rapid City on May 8 and 9th. As I listened to various people
speak, there were various grave concerns including:
1. The science of actual and potential harm to the water, land and sky. Our scientists have
proved that in-situ uranium mining is dangerous and changes the water and
environment. The proximity of the Igloo waste site depot has potential devastating
consequences. We need to let sleeping dogs laf 5'We already have too many holes that
were never closed by other companies. LEAVE OUR LAND ALONE!
2. The economics of the project (a few temporary jobs, a huge profit for a few people versus
probable environmental devastation and clean up costs). Western South Dakota has a long
history of outside companies coming in and making profits and gone before the damage is
evident. None of them put up the huge sums of money for clean up insurance.
LEAVE OUR LANDS ALONE I
3. The morality of giving permits to companies without Native American, farmers and
ranchers, and other citizens living in the area, without their consent or benefit. The white
Europeans have done their best to abuse and steal the lands in the 1868 treaty. But there is
now a coalition of people who wilt try to legally fight these permits because there are 10
other companies standing in line, licking their chops to do mining projects,
WE DO NOT WANT THEM!
4. The political reality that the EPA may become weakened and gutted by leadership who is
supporting businesses versus protection of clear air, water and lands. A report today
indicates that President Trump's March proposal would have the EPA absorb a 31% funding
cut; part of that would be less monitoring and efforts related to climate change. This is
going to make it even harder for environmentalists within the agency to stop unnecessary
projects. STAY STRONG You know how to delay unwanted projects.
5. The shadiness and uncertainties. Does Arzaga really want our uranium? Or is it our water?
Or our holes for toxic dump sites? Who controls what they do? Who pays for their
mistakes? Why are we even considering doing such an unneeded project?
HELP STOP THIS!! Thank you.
-------
for Trump budget | TheHill
Page 1 of3
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Wharf sells S136.7M
in metals from mine
srm tuppir and bob mcrces
Journal staff
PIERRE — Coeur Mining sold
$136.7 million worth of precious
metals in 2016 from its Wharf
Resources mine near Terry Peak
in the Black Hills, according to
recent reports filed by the com-
But to do so, the company used
about ISO million gallons of wa-
ter and about a million pounds of
ude along the way.
The" Wharf mine is one
five mines that Coeur, which is
based in Chicago, operates in the
Americas. The other mines are
in Nevada, Alaska, Mexico and
Bolivia. The company reported
total revenue of (665.8 million
last year.
At the Wharf mine in 2016,
gold production was 109,175
ounces and silver production
was 105,144 ounces. Both num-
bers were increases compared
with 2015, when the Wharf mine
yielded 89,496 ounces of gold
and 70,276 ounces of silver.
Matt Zietlow, environmental
manager for Wharf Resources,
spoke about the production
numbers Thursday during a pub-
lic meeting of the Sooth Dakota
Board of Minerals and Environ-
ment in Pierre.
"It was a strong year for us
A mining truck hauls ore up a steep road at the wharf Resources mine
outside Lead', near Terry Peak, last week.
overall," Zietlow said.
The company paid severance
taxes of $7.3 million to the state,
he said.
There are other gold-mining
permits and exploratory permits
in the Black Hills, but the Wharf
mine is South Dakota's only op-
erating large-scale gold mine.
The report of $136.7 million in
metal sales from the Wharf mine
is from year-end results reported
by Coeur Mining to investors.
Additional company reports say
the Wharf mine employs 214
people and covers eight square
miles. The mine is several miles
west of Lead, just north of Terry
Peak and visible from the top of
the ski area near the summit.
In a separate annual report
filed with the state of South
Dakota, Wharf reported that its
2016 mining activities included
the withdrawal of 75.63 million
gallons of groundwater and 77.47
million gallons of surface water;
the mining of 4.75 million tons
of ore and the processing of 4.27
million tons of ore; the mining of
Wharf Resources
Wharf Resources near Terry Peak
mined more than 100,000 ounces
of gold and 100,000 ounces of
silver in 2016.
(Slack hills
NMIUNAl K0BWT ¦
1 ©
Wharf Resources mine (
MPH
Cheyenne Crossing
Please see WHAKF, Page A4 m«n4n**isxom/enEI»t, Kr imerpriies graptilc
-------
minimal in 2016.
"We didn't have really
any reclamation last year
because we were mining
in areas that were, for the
most part, already dis-
turbed," Zietlow said.
In Coeur's reports to
investors, the company is
projecting lower produc-
tion from the Wharf mine
this year because of the
anticipated completion of
a high-grade deposit.
PARTLY SUNNY, A SHOWER 61*16 FORECAST, B6 I TUESDAY, MAY 23, 2017 | rapi
Black Hills gold miners
still making millions
HANNAH HUNSINGER PHOTOS. JOURNAL STAFF
Mining trucks haul ore up a steep road Tuesday afternoon at the Wharf Resources mine outside Lead. Wharf Resources mined 4.7 million tons of
ore in 2016 and generated about $137 million in precious metals sales.
Wharf
From Al
11.33 million tons of over-
burden or waste rock;
and the use of 1.2 million
pounds of cyanide as part
of the mine's heap-leach
method of extracting pre-
cious metals from ore.
Reclamation, or the re-
storing of mined land, was
HANNAH HUNSINGER, JOURNAL STAFF
In 2016, Wharf Resources used 1.2 million pounds of
cyanide and about 150 million gallons of water in its gold
and silver mining operations.
-------
Cm^rrukksM
Hello...my name is
and I live in Rapid City.
Thank you for these hearings. I am not a scientist, but I am a
mom and a grandmother. I read quite a bit, except for twitters,
and it concerns me that our current President - awl - Head of the
EPA, both seem more interested in supporting fossil fuel companies,
rather than getting serious about climate change and protection of
the environment. It makes it even harder for people within the
agency to do the right thing. We can no longer write a carte
blanche approval to qreedy, poison polluters who have done the
I have been told your agency has not denied any of these
permits....even though we ALL know of their toxic harm and ruin to
our environment. So, I guess what I am asking you to do is to
DELAY any permits until you get all of the facts. Many other
people here will be talking about the scientific research that still
needs to be done, -fYtb *£ CO A_Sul"W{ /J m
These permits do not benefit the United States. We don't need
any uranium. The US has a 200 year supply. For us, it is all about
protecting water. For Azarga, a foreign based conglomerate, it's
all about greed. These laimw disposal wells will make them a
fortune and leave us, once again, with a possible irretrievable
mess.
South Dakotans do not want to be the dumping ground for toxic
waste. No amount of assurances by anyone can guarantee the
safety of our precious water. I am incredulous that the EPA is
also proposing to exempt the portion of the Inyan Kara Aquifer
from the "Safe Drinking Water Act" which is necessary for mining
-------
to occur there. WHY? Why would you want to moke our water
unsafe to make a few guys rich?
This week, you will hear testimony that our western South
Dakota porous aquifers and caves are intertwined and leak into
each other. In-situ mining potentially contaminates a great deal of
our drinking water, as well as our top soil lands where the animals
and birds get their food and water. I urge you to require the
necessary research before giving any more permits. Check out the
cancer rates in Edgemont and Crawford, Nebraska. Require the
water testing that several organizations want to do. And
remember, we are volunteers and water testing is expensive. EPA
should help us with the funds.
We have been in this fight for a long time. In closing I want to
submit to the record, a 2013 resolution by the City Council of
Rapid City expressing GRAVE CONCERN.
Thank you again for listening. The United States does not need
this and the only way we can keep our water safer, is simply to
NOT ALLOW the permits. A ^
[Jf/tt w- -ijhu /Ur&, fc-PR-
-------
RESOLUTION NO. 2013-083
A RESOLUTION EXPRESSING GRAVE CONCERN ABOUT THE IN SITU MINING OF URANIUM BY
POWERTECH IN CUSTER AND FALL RIVER COUNTIES.
WHEREAS, Powertech Uranium Corp. has submitted applications to the South Dakota Water
Management Board for permits to use water from the Madison and Inyan Kara Aquifers to conduct in situ
mining of uranium in Custer and Fall River Counties in the Black H ills of South Dakota; and
WHEREAS, In situ mining, or in situ recovery involves pumping solutions incorporating water from the
aquifers into an ore body through wefts which will then circulate through the porous rock and recovering
the minerals from the ground by dissolving them and pumping the solution containing the ore to the
surface where the minerals can be recovered.
WHEREAS, hearings on Powertech's water permit applications will be held by the South Dakota Water
Management Board in Rapid City at the beginning of October of 2013; and
WHEREAS, the City of Rapid City obtains a majority of its drinking water from the Madison Aquifer; and
WHEREAS, the safety of the water in the Madison Aquifer is of utmost importance to the City of Rapid
City; and WHEREAS, due to the unanswered questions regarding the safety of the community's water supply,
the Common Council of the City of Rapid City believes that the proposed in situ mining of uranium in the
Black Hills poses an unacceptable risk to the primary source of Rapid City's drinking water.
NOW THEREFORE, BE FT RESOLVED, by the City of Rapid City that due to the potential risk to the
Madison Aquifer the City expresses grave concern about the proposed in situ mining of uranium in the
Black Hills.
Dated this 19th day of August, 2013.
CITY OF RAPID CITY
-------
I
In-situ mining will foul the waters
RICHARD
BELL
I have worked for uiore than
40 years in the environmental
cleanup field for industrial
companies and consulting firms
on many projects globally where
accidental discharges - leaks and
spills, etc, - have occurred and
resulted in the contamination of
groundwater systems.
During my work
on these various
clean-up projects,
pollution control
agencies have
typically insisted
that not enough
was known about
how and where the
ill-fated contam-
ination was mov-
ing in the subsurface. Well after
well needed to be installed in an
effort to try to prove the improv-
able regarding subsurface fate
and transport of contaminants.
And It is one thing to clean up an
accidental spill or other legacy
environmental problems when
laws governing the handling of
hazardous materials were not
as stringent as they are today,
but if is quite another to allow a
company to inject these materials
into the subsurface and thereby
purposely create a huge contami-
nation problem.
The Environmental Protection
Agency recently issued draft
permits to Powertech/Azarga for
a proposed in-situ leach (ISU
uranium mine to Custer and Fall
River counties. If approved, these
permits would allow the com-
pany to operate for 10 years.
ISL mining occurs in the sub-
surface, within groundwater-aqui-
fers, In this case, it would occur in
the lnyan Kara aquifer and would
include the Injection of wastewa -
ter back into the Minnelusa aqui-
fer. But people are using the water
in these aquifers for drinking wa-
ter and agricultural purposes, etc.
So this is a terrible Idea,
ISL mining involves the drilling
of thousands of wells into the ore
deposit where uranium occurs
naturally in a solid state. Leach-
ing solution is then pumped into
the aquifer where it makes con-
tact with the ore and artificially
dissolves the uranium, along with
many other heavy metals.
This solution is then theoreti-
cally captured and pumped to the
surface for further processing.
However, after naturally-occur-
ring uranium and other heavy
metals are mobilized in this fash-
ion, it is absolutely impossible to
guarantee 100 percent capture of
this solution, especially given the
heterogeneous conditions (dif-
ferent materials/layers, etc.) that
exist in this area.
The interconnections make it
impossible to predict with cer-
tainty how liquids are truly flow-
ing. And this uncertainty occurs
not only when the mining opera-
tion is active, but it is exacerbated
at the end of operations when the
mining ceases and the pumps are
turned off.
The remainder of these heavy
metals, including uranium, that
were loosened during the ISL
will then continue to flow within
the aquifer. And to make matters
worse, no such ISL operation has
ever been successfully cleaned up.
It is shocking that the F.PA is
willing to consider issuing such
permits. If the shoe was on the
other foot and the EPA was re-
sponsible for the cleanup rather
than in the position of issuing these
permits, they would be much more
discerning and demanding.
If Powertech/Azarga is allowed
to proceed, it is a near certainty
that this facility will become a
Superfund site and therefore the
company should be required to
place millions of dollars into a
reserve account to pay for an in-
evitable cleanup.
So this is a terrible idea. Why
would we risk our precious
groundwater resource for a min-
ing operation that is guaranteed
to contaminate these aquifers in
exchange for a handful of jobs
and large profits made by a for-
eign corporation?
We should keep our water pure
to support our local economy
and the sustainable growth that
is happening in the Black Hills
Common sense dictates that this
type of uranium mining should
not be allowed to proceed.
Please attend the EPA hearings
on the proposed Powertech/
Azarga ISL uranium mine to be
held from 1 to 8 p.m. on May 8
and 9, at the Best Western Ram-
kota Hotel, 2111 LaCrosse St. in
Rapid City.
Richard Bell is the president of
Sustainable Environmental Energy
Engineering, LLC in Rapid City and
chairperson of Black Hills Chapter of
Dakota Rural Action
Chance to fight
toxic waste in S.D.
The U.S. Environmental Pro-
tection Agency has issued two
draft underground injection
permits for the Dewey-Burdock
project near Edgemont. If ob-
tained, the EPA permits would
allow for injection mining
wells in the lnyan Kara group of
aquifers and disposal of treated
waste fluid into the Minnelusa
formation, below the lnyan
Kara. An "aquifer exemption"
could also be granted to exempt
the mining area from the Safe
Drinking Water Act. This is not
EPA protection; it's EPA devas-
tation.
No more toxic in-situ ura-
nium mining; nor do we want
western South Dakota to be -
come a dump site for local,
national and possible interna-
tional toxic waste.
Please visit the Black Hills
Clean Water Alliance website
for more detailed information
as well as dates and places for
upcoming public hearings. The
website also includes where you
can mail or email written com-
ments.
In Rapid City, public hearings
will be from 1 to 8 p.m. on Mon-
day, May 8, and Tuesday, May
9, at the Best Western Ramkota
Hotel. Please come. Let your
voice be heard. No more toxic
waste in South Dakota.
Mary Jo Farrington
Rapid City
-------
Mass Mail Post Card Comments
Original post card template:
Dear EPA, Region 8:
Here are my comments on the Underground Injection Control Program's Draft Permits for the Proposed
Dewey-Burdock Uranium Mine and Deep Disposal Wells:
• Old uranium mines in the Dewey-Burdock area should be fully reclaimed before new mining is
permitted.
• Adequate oversight of the quality of liquid wastes pumped into the Minnelusa Formation through the
proposed deep disposal wells will be impossible, and our groundwater is likely to be contaminated.
• A full survey of cultural and historical sites is needed before mining or deep disposal is allowed.
Cultural and historical sites must be protected.
• The proposed mine and deep disposal wells are in an area that is documented to have faults, fractures,
breccia pipes, and over 7000 old boreholes that have not been properly plugged. It will be impossible to
contain mining fluids or waste liquids, and contamination of our groundwater is very likely.
• The history of uranium mining indicates that uranium mining cannot be done without creating and
leaving contamination. This project should be stopped until it can be proved to be safe, rather than
relying on imperfect protection and clean-up processes.
Additional comments that have been added
We cannot risk ruining our water supply to provide uranium. We don't need uranium to be mined here
or anywhere else. Save out water. It's important.|
This is not good for the citizens of South Dakota!
We need out water left alone & clean. There is no need for more drilling or retrieving of uranium. Focus
on wind and solar to create jobs. I
Water is life; uranium is death.I
Why pollute indigenous lands to the sole benefit of China and France? So wrong.
Please take into close consideration Hannan LaGarry and Linsey McLean's expert scientific testimony.
Job consideration & moneys to be made for such a small populations should never be allowed to
outweigh the possibly devastating effects to millions. Thank you.l
Benefits of the project are not worth the risk to life and water. I
The probable loss of tourism and ranching would be devastating. |
Stop drilling - stop Trumpl
Uranium has no good place in our future - it is a failed industry - do not mess with it! 111
-------
The mines for uranium have been and are an environmental disaster. These will be, too.
This is our children's legacy!! It is NOT OK to mine uranium! This project should be stopped.
I am opposed to uranium mining especially to a foreign owned company. Would you approve this if it
were in your backyard?!
Dewey-Burdock is a bad deal.
We've already spent enough on clean-up and it hasn't been done.l
No new mines should be discussed until this [reclamation of abandoned uranium mines] is done!
Merely exempting these wells is not acceptable.
These [cultural and historical surveys] must be tribal approved!
This [contamination of groundwater] is a risk that is unacceptable!
[History of groundwater contamination from uranium mining] terrible track record - do not permit the
minell
I do not want any mining or dumping of uranium waste in South Dakota - period.|
No, not here, we do not want your stink. I
Save our water. This project should be stopped. |
Please do not adulterate my aquifer.
If you proceed to allow this, at least make them pay for the water they use. Thank you. I
NO! NO! NO! Absolutely NO!|
Old mines should be cleaned up. No mining or deep disposal.
I have children, grandchildren and great-grandchildren that this will - there is no "may" - affect. Please
do not do this! I am deeply concerned for our town as we depend on water, tourism, and industry.
The potential for environmental damage is too big a risk for this project to continue. |
How can we put our water at risk? This project should be stopped. |
Please pay attention to our request. I
Therefore, stop the mining. It must not be allowed.|
Save our water!! This project must be stopped.
This project must be stopped. Please stop this mining. I
To issue a permit for massive amount of water would be a huge mistake no matter to who or for what.
DENR regulates water and sewer - where is their involvement? What was Silver King all about if uranium
-------
is of no concern? We don't need another tax payer burden to clean up a foreign company's tailings.
We do not need this at all. Cancer rates go up, all because the rich get richer.I
Proof states contamination will absolutely be a problem - no guarantee of safe consumption of water
for humans, animals and farm land. Knowing the facts would you be willing to subject your water to
this? |
Who will be responsible to try to clean up the mess down the road? Taxpayers again. Why would we
want to give up our clean water? And way too much of it. You can't fix contaminated water.
My well is in the Minnelusa Formation and is good drinking water.
Water is life - no fracking. I
Water is life! Common sense. This project should be stopped.I
Groundwater will be contaminated-contamination of our groundwater will happen! Uranium in NOT
This would jeopardize the safety of our water supply. Must NOT happen. |
The prospect of this mining is insane. I
It should be illegal to mine [uranium].|
This project should be stopped.|
No uranium mining here.l
[clean up abandoned mines first] My mother taught me to clean a mess before staring another one. You
(EPA) have a bad track record of oversight. They [Native Americans] were here first and are still here.
We have no control over acts of God, but we can exercise rick management.|
Please do not permit this environmental disaster to happen. |
Not Here 11
-------
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-------
Valois Shea
U.S. EPA Region 8
Denver, Colorado
June 8, 2017
Dear Valois Shea and Others:
Greetings, I am a concerned citizen writing to convey my objections to the Dewey-
Burdock ISR and waste water injection projects proposed by Azarga Uranium in south-
western South Dakota. I am a permanent resident of the Black Hills and live near Argyle,
SD, just a few miles (about 8 miles) east of the proposed site. I am opposed to the project:
1)1 know from personal experience, and historical records, that uranium extraction and
processing has resulted in the on-site and off-site contamination of land, property, and water
—both surface waters and ground water; 2) and while the short-term profits associated with
these projects is always private, the long-term costs and liabilities are public, as cleanup
activities are difficult and expensive, and the half-lives of radioactive pollutants extend many
generations beyond those that receive any benefit from the products. Additionally, I am
philosophically opposed to foreign entities, whether private enterprises or governments,
being allowed to exploit U.S. resources, and don't understand the laws that enable them to do
so.
Given my personal experience working for Chem Nuclear Inc., on the Riverton,
Wyoming, UMTRA (Uranium Mill Tailings Remedial Action) Project, I have been converted
from an advocate of nuclear power, or the use of its by-products, to one opposed to the
mining and processing activities associated with the extraction and use of uranium, or other
radioactive elements. As a Health Physics Monitor, I was charged with detecting and
monitoring radiation in the air, soil, and on equipment at the Riverton Super Fund site: My
job involved directing excavators and surveying excavations with a scintillation probe to
insure the removal of tailings and contaminated substrates; inspecting trucks for
contamination prior to their exit from the job site, to insure safe transport for off-site
disposal; monitoring air quality, on site and off site, with sampling equipment designed to
detect air-borne radioactive contaminants; and assaying off-site properties (i.e., nearby farms,
homes, and businesses) contaminated by wind-blown sediments from tailings piles, or
tailings used as backfill around or under rural and urban building sites such as houses,
industrial buildings, and parking lots.
The Riverton UMTRA project site was one of 24 mill processing sites, and 8000
vicinity properties (off-site locations with known or putative contamination), in 9 western
states and the state of Pennsylvania, designated by the Uranium Mill Tailings Radiation
Control Act (1978, UMTRCA, Public Law 95-604) for remediation. The Department of
Energy was responsible for the remediation. The Riverton site had 35 vicinity properties that
had to be surveyed for radiological contaminants and cleaned up.
Fremont Minerals, Inc., later known as Susquehanna-Western, Inc., a private
enterprise, owned the 218-acre Riverton site where a mill was built and uranium ore was
processed from 1958 to mid-1963. Seventy-two acres of a 218-acre site had tailings 4 feet
deep, and a total of 140 acres were considered contaminated. The 1 million cubic yards of
mill tailings contaminated the air (radon and windblown tailings), soils, and both surface and
ground water—consequently, local wells were condemned and well permits were frozen, as
surveys revealed that contaminants from the mill site were present in two aquifers below the
site. The mill site, which is surrounded by the Wind River Reservation, the home of
Shoshone and Arapahoe tribes, was on private property owned by non Indians. It was
acquired by the State of Wyoming, in 1987, to facilitate remediation. Under the UMTRCA
law, the state was liable for 10% of the costs, and the Federal government 90%. Hence,
taxpayers or consumers ultimately paid for the careless behaviors of the mining and
processing entities, while it took an act of Congress and ca. 25 years to get the cleanup
started, and another 2 Vi years to complete the removal of surface contamination.
The surface cleanup was conducted between May 1988 and Sept 1990 and cost over
$50,000,000.00. The job site was active 24 hours a day, 7 days a week, in order to excavate
-------
and remove approximately 1.8 million cubic yards of materials. In other words, 1 million
cubic yards of mill tailings, with an residual concentration of uranium estimated at 15%, and
800,000 cubic yards of contaminated soils and substrates were removed and trucked to the
Gas Hills—the original mining site located 53 miles east of the mill site. In addition,
approximately 800,000 cubic yards of clean backfill had to be brought in bring the site to
grade, before re-vegetation efforts could begin. The mill was also demolished, removed, and
buried off site in the Gas Hills. And a nearby farm had its topsoil removed and replaced due
to contamination from wind-borne tailings, while other vicinity properties required soil
remediation and demolition and re-construction of affected structures.
The mill tailings site is less than a mile from the confluence of two rivers—it is 4000
feet south of the Big Wind River, and 3000 feet north of the Little Wind River. And closer
yet, there is an excavated drainage channel, a natural stream, wetlands, and an oxbow lake.
Hence, the site is located on a flood plain terrace, with alluvial deposits, and is underlain by 3
aquifers: There is a surficial aquifer, comprised of 15-20 feet of alluvial sand and gravel,
with water 3 to 6 feet below ground surface. This aquifer is contaminated with 10 to 40 times
the accepted levels of concentration for uranium and molybdenum. There is a semi-confined
aquifer of sandstone 15 to 30 feet thick, partially separated from the surficial by 5 to 10 feet
of shale, and it is also contaminated, while the confined sandstone aquifer, the largest and
deepest aquifer, has been judged to be free from contaminants, or perhaps, the contaminants
have been diluted to concentrations below detection. The nearby oxbow lake, once used by
residents of the Reservation for swimming and fishing, is contaminated, as it is recharged by
water from the surficial aquifer. In such case, it is off-limits for such uses. The plume of
contamination under the mill site is moving towards and into the Little Wind River and the
DOE estimates that it will take at least 100 years to flush the upper two aquifers. In 2001, the
DOE started issuing annual monitoring reports, and in year-2000 dollars, estimated it would
cost $100,000 a year, or more than $10 M, to monitor the ground water over this period.
Surface remediation is one thing, but the repair of damage done to aquifers is another.
Yes, contaminants from mining or processing uranium can be superficially removed from the
surface of such sites, albeit with great expense and effort, but radioactive contaminants in
surface waters or aquifers can be nearly impossible to remove fully. Once again, as in the
Riverton case, dilution becomes the solution to industrial pollution that private enterprise
initiates and profits from. And my goodness, we are considering allowing a foreign entity,
with no local interests, to actually add contaminants to our Black Hills aquifers—it is
unthinkable. Please deny the related permits and exemptions.
Sincerely,
-------
"I 'f.O'/" try i
Valois Shea
U.S. EPA Region 8
8WP-SUI
1595 Wynkoop Street
Denver, Colorado 802G2-1129
05-11-2017
My name is I live in Sioux County, I was bom and raised in the Crawford
area. Please accept these as my comments to the formal hearing record.
Deceptive language is snake oil, descriptions like uranium recovery, and the use of
simple soda pop solutions, then to top it off, hiding radioactive waste in deep injection
wells that pass through groundwater aquifers. Who will cover the costs of hazardous
training for rural emergency responders, contaminated workers and equipment? Who
will clean up license area soils that are contaminated because of the toxic waste land
applications? Who will monitor the spray discharge of the evaporation pond poisonous
waste water as it settles on the surrounding fields and prairie? Count on hazardous
delivery spills occurring on your county roads, be ready to evacuate your home when it
does. If you doubt it, come to Crawford, I'll give you a tour. The casual transport of
yellowcake is lethal to wayside communities. Boreholes and toxic flush extraction and
milling yellowcake endangers downstream communities far into the future. Ifirt"
Cawve_c_o kM wvo> rfs p© \soV\ o OS ioa s v A
KEEP IT IN THE GROUND! NO AQUIFER EXEMPTIONS!!
-------
Valois Shea
U.S. EPA Region 8
8WP-SUI
1595 Wynkoop Street
Denver, Colorado 80202-1129
04-27-2017
My name is II^BH please accept these as my comments to the formal hearing
record.
I am a Sioux County Nebraska resident, our home is located about the same distance
from the headwaters of the White River as we are from Cameco's CBR in-situ leach
uranium mining and milling operation at Crawford, NE.
In 2012 I returned to northwest Nebraska where I was born and raised after living in the
Black Hills of South Dakota for 26 years. What little I heard about the Crow Butte
yellowcake operation was mostly public relations fluff. In 2004 and 2005 I spent a lot of
time in Crawford caring for my terminally ill Mother. Mom was a resident of the Crawford
area since the early 1940s, she was diagnosed with lung cancer in 2004 and died in
Crawford nine months later. During that time period one of the many Crow Butte
Resources' documented violations was an undetected poisonous spill into an
underground source of drinking water that lasted for 2 1/2 years spanning from July 1,
2003 through March 31, 2006.
Crawford residents die early in their lives and many assume the mine is causing cancer.
Residents have tested positive for heavy metals contamination associated with ISL
operations, their recovery is dependent on their leaving the area of contamination.
Residents fish nearby ponds and the White River at Crawford, but they do not eat their
catch. It is rumored that a farmer had to down crops in their field due to contamination
from the adjacent ISL license area. My Uncle, also a long time resident of Crawford, has
stopped drinking his tap water. Workers say that one of the 8000 CBR wells has been
sealed with railroad ties, and it is rumored that one of deep disposal wells has failed.
Crawford, in Dawes County, has 2 of Nebraska's three deepest toxic waste disposal
wells.
Locally the only critical thought and formal push back against the uranium mine has
been from the Oglala Sioux Tribe and Consolidated Intervener expert witnesses.
Elected officials, economic elites and growth groups worry about real estate values and
their investments. The uranium mine and yellowcake mill is left off travel publications
and maps. It feels like a cover-up. How do you invite people to visit and/or live in a
-------
radioactive contaminated area? Informed consent is vital to ethical human population
care and development, otherwise, is it not "human trafficking" to invite uninformed
people to get sick?
Up north near the South Dakota border some people are saying they want the economic
advantages uranium mining & milling proponents boost about. The economically
advantaged up there must be talking about tax relief or school funding because
Crawford is dilapidating. The water works infrastructure is giving way and costly repairs
are undertaken to keep the city water system functioning for a high poverty arid
declining population due to health and economic evacuation. It is heartbreaking for me
when I think that short sighted land managers and property owners tied our schools to
an unlicensed nuclear waste dump and future superfund site.
Regarding the identification of traditional cultural properties at the Dewey-Burdock
Project site. Formal consultation under Section 106 of NHPA with First Nations of the
1851 and 1868 Fort Laramie Treaties must be completed. See attached documents for
listing.
My husband and I put our life savings into our sustainable build at Glen, NE, near the
headwaters of the White River. The Nuclear Regulatory Commission's ASLB hearings
made it clear to us what has been allowed on the landscapes of Nebraska's "Garden
Beyond the Sandhills". We believe we can contribute to the recovery of the Pine Ridge
White River basin but our community needs help. Decision makers need to stop the
denial and start to take action against an industry that exploited our rural environs. We
need a safe and stable water supply. High pressure injection and extraction mining of
uranium, oil and gas is happening in the Nebraska Panhandle as we speak. We in
Sioux county are at the gateway of Wyoming's movement to dump out of state waste
from these operations into Nebraska soils. Who is accountable when tectonic stability is
changed and movement occurs that allows poison production water to further
contaminate our regional groundwater? NO MORE EXEMPTIONS. MNIWICONIH
-------
RECEIVED MAY 13 2117
\tetofsShea
U.S. EPA Region 8
Mai Code:8WP-SUI
1505 Wynkoop Street
Denver, Colorado 802-112®
April 30,2017
Dear Vatos S^ea, EPA;
m 8fa writing tNa comment toiler as s common family wire resides together in Hot Springe,
SD. We we ml incSviduais with heavy aeientffle backgrounds, just concerned citizens. We are
wMrig the EPA to deny any and ait permits related to Powertech/Azarga acttvftles tor uranium
reooverv and hazardous waste dumoina. No suuertund rites should be stowed at amv time.
ULftflfc ApA MueSSlfc anil JTnl't «** WrftiiNl #1i #1 if! W I* W < 11 a i s* j> ffjrili I till ml Hi >a JW l€ll I
we mm lafTttilar Wm\ mm rtav® ftHiO mm f8S€MlfGnmi ma mpiiVI affects Of IfacpQflg, loL, UH#
a i ii im W—* dHttflhrih iMbflfeddl Oak^m. jb* ji iwanitfiiMi i iMi jwjn MLfedA. AMt MM ,¦— Iiriai iifc Mht «A m — OK ^Jk ——— -"¦¦ ¦¦"¦ —¦
mpcaon wens etc. ana to mganve effects 01 uranium on vie environment, wnavra am humane.
Hie nepive effects tew beer* watt documented wfth n^n^i mi am banned In many places
throughout the world. We should new allow a foreign country, with a tad environmental record,
that obviously has no concern far the environment, to ever be given the opportunity to
contafTirriai© our lana for money anq nn maste n not rastoreo. i nts nas oeaft a previously noted
betiavtof and the anvlronfnefit nsvar fatly able 10 to restored to ifs original state.
our area who have trade commente about
ttieir relatives usina certain lands for sacred and twyPmil activities, burials etc. that have not
been rejected and we visibly contaminated toy uranium activities. Blatant ftw«»«# of an
•^wwl * * mmm WWWt^m9 VIMS * «!^B fMftww wm w KB* wmm »• wmn&9m W w »pr® mmtm w
indigenous culture and historical abuse! No cm should be allowed to do this to any culture!
We Mil the water hero; have friends wiii wete; swim, play and heal fn the water; fish; hunt;
boating activities; grow gardens; raise animals; wash; breatft the air; raiee chitdren; hike; travel;
Nve; own land; like us. We donl
want k5 live in a ptace that could become a toxic waste area, as would anyone else. This is one
of the few pnstine water are^ in the Amencas! Poweftech should establish their business in
their country and mi on American mil No company should be allowed to recover uranium or
set up a Superfund site anywhere in fie US. Powart»eti!Azafi& permits should be denM,
pm&sm ifwifC isxui ma cniiorens lyiuf®. a pnomnt couid ©if@ci rniRions of paopta,
Please protect our environment, people, wSdHfe, archeologic£y sites, tourism and way of life in
SouVt [Mote bv suDCJortina the itanM of Powertech/Azaraa oermits. Pleas tefca no chances.
Thank you for your time and consideration,
Sincerely,
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Post card comments
No uranium mining in the black Hills! Do not allow permits for SD lands to become a solution-mining
facility. We don't need to be a nuclear waste dump either! Thanksl
No mining permits in the Dewey-Burdock, Edgemont area of the black Hills of SD—no permits should be
awarded to the uranium mining company Powertech/Azarga. ISL will not benefit the Black Hill nor
protect the groundwater.|
We demand:
1) No Permit
2) Clean up old mines
3) Tribally defined consultation
4) Full tribal approved surveys
5) Lakota translation/transcription^
No uranium mining in the Black Hills! No! Do not allow mining operations to inject mining waste into the
underground aquifers in South Dakota! Protect our land, protect our air, protect our water. That's what
the EPA does best. No Name
Uranium mining of the Black Hills is an assault on Native sovereignty and an environmental disaster in
and of itself, even if it goes as planned. Please no not allow this to happen. Please respect this important
religious, cultural and historical site. I
I'm part of the #WomensMarch movement. I'm from Colton, New York and I'm concerned about
uranium disposal in South Dakota. Here's why: It should never be acceptable to poison the earth and its
natural resources that we depend upon. Please do not approve the contamination of these precious
resources that are depended upon. They feed and nourish our children and all of us. This disposal
method can never be undone. In the first 100 days of this new administration, I hope that you
understand and take these concerns seriously.
-------
*
First, I would like to thank the EPA and the village of Hot Springs for the chance to speak to
the facts as*see them, I've been traveling to the Black Hills for over 30 years, and recently
purchased a house here in Hot Springs-flMmMpH^I've been a rock hound of sorts and a minor
geology buff for many years. After reading the Class 3 and Class 5 permit fact sheets provided
by the EPA in regards to the proposed Azarga project, it is gtfte evident to me that this project
is, at the very least, impractical, and at the very worst, extremely dangerous. Considering the
complex sub-surface geology of the area and its close proximity to known fault zones, the
choice to use injection well technology to both contain contaminated waste waters and mine
sub-surface uranium deposits, is both irresponsible and potentially catastrophic.
I would like to
just a few of the potential sticking points.
—ilBCTTTirriiiii^ I Page 23 of the Class 5 fact
sheet states the locations and conditions of fault zones in relation to the project area. And I
quote: " The Dewey structural zone consists of steeply dipping to vertical faults that are
uplifted on the north side relative to the south side of the zone a total of 500 feet. IMMfeaase
- limn n m I . II mm mi .The
Long Mountain structural zone is located approximately 7 miles south of the project area. This
fault zone consists of small NE-trending normal faults observed in outcrops of the Inyan Kara
Group and Sundance Formation within a zone measuring several miles across. The
displacement across the faults measures up to 40 feet, with folding of the strata adjacent to the
faults adding up to 60 feet additional structural relief. The faults in the Dewey Quadrangle
occur NW of the Dewey Fault in the Dewey Terrace area approx. 1.5 miles NW of the project
area. A sub-surface fault was identified by seismic methods about 5.5 miles N of the project
area boundary. It is about 1.5 miles long and 400 feet wide. 3 Faults are shown in the NE
comer of the Burdock Geologic Quadrangle. The report states that these faults have a
displacement of less than 10 feet and are located 2.5 miles or more from the eastern edge of the
project boundary." So in short, there are at least a half dozen faults of differing size located
within a mile and a half to 5 and a half miles from the project zone. Page 25 of the Class III
Draft fact sheet draws an even better picture of the Dewey Fault in particular, and 1 quote,"The
Dewey Fault, a NE to SW trending fault zone, lies approx. 1500 feet NW of the Dewey-
Burdock Area Permit Boundary."
So again, we have a steeply dipping fault line lying less than a half-mile away from the project
zone."" " * * ' ' * " *~"
sheet states, and I quote, "many other faults are probably present but not discernible because of
poor exposures." -LET ME REPEAT THAT- In response-^BHMm, it is^MW stated m
JSBlP>that "If there are any faults and fractures occurring within a well field area that cause a
breach in a confining zone, they will be detected during the well tlclcl drill and pump testing. If
found, the placement of injection and production wells can be modified from the regular pattern
to control lixiviant flow around the fractures or faults to keep it flowing through the uranium
ore bodies rather than along these paths of lower hydraulic resistance." Sty f additional
-------
fractures and faults are found in the project area, and there are already many, Power'I'ech will
simply and safely adjust the flow around these breach zones and continue to mine uranium? To
think that you can safely continue to apply injection well technologies in an area of potentially
breaching fractures and faults, I find to be both ridiculous and irresponsible.^BfcJTthe
information showing the close proximity of numerous fault zones to this injection well area is
not enough to disallow this project, we must also consider the confining layers that will be used
to contain the injected toxic fluid. The entire project area relies upon a lower and upper
containment layer of Fuson shale that underlies the whole region. However, to quote from page
22 of the Class 3 fact sheet," There may be points where the Fuson confining zone has been
compromised by improperly plugged exploration drillholes or wells that penetrate the Fuson
confining zone. Evidence that suggests at least one breach in the Fuson confining zone is
included in the reports on the pump tests.,, conducted in the Chilsen Aquifer in the Burdock
area," It is tffcp clear from pages 15 and 17 of the Class 5 |m* sheet that the porous
nature of the Minnelusa sandstone as an upper containing layer is a concern,
sheet, "Low-permeability layers in the lower part of the Minnelusa Formation
generally act as an upper confining zone to the Madison Aquifer. However, karst features
(limestone that has dissolved and is in some stage of collapse) in the top of the Madison
Limestone may contribute to reduced competency of the overlying confining zone in some
locations.I we would all like to know where those locations are, and
what the consequences of their "reduced competency" will be. I think it should also be
mentioned that, on page 25 of the Class 5 fact sheet, PowerTech's own miscalculations on the
pressure required to move fluid from containment layers to public water supplies is openly
challenged by the EPA itself"
Beyond that, we must also consider the history of PowerTeeh drill sites from the past, and the
competency of the work that was done. State regulation requires drillholes be plugged after
they are logged. Newer PowerTech drillholes were plugged and abandoned according to SO
regulations. However, historical drillhole records are not available to show how they were
plugged. £&on page 37 of the same report, "It is possible that some historical drillholes may
not have been plugged in a manner that would prevent communication between sub-surface
aquifers." Page 45 of the same report states,"With one
exception, groundwater discharging to the ground surface is limited to flowing artesian
wells...the only feature identified that was indicative of groundwater discharge from
exploration drillholes at or near surface was the alkali area in the SW corner of the Burdock
"Power lech has identified this area as a
possible location where groundwater may be discharging to the surface from the Fall River and
possibly the Chilson (aquifers) to the surface through an abandoned exploration drillhole."'
•^^B^QHHH0ii^''Pow'erTech will not be able to begin injection activity until this issue
is resolved. Resolutions of the issue may involve locating and plugging of improperly plugged
historic drillholes, locating and performing corrective action on nearby wells that create a
pathway through the Fuson confining zone, or a pumping, injection and monitoring plan that
demonstrates control of lixiviant in the areas where breaches in the Fuson confining zone have
-------
been identified." It is obvious that there already exist communication between aquifers because
of these abandoned drillholes. And it is also clear that they are fully expecting there to be
further breaches in these confining zones. To think that all of these potential breaches and
leaking drillholes can be identified and resolved is wishful thinking, at best.
In its own outlines, the USGS lists specific factors necessary for injection wells to induce
earthquakes. Those factors include the presence of
faults that are large enough to produceeartfiquakes, stresses that are large enough to produce
earthquakes, and the presence of pathways for the fluid pressure to travel from the injection
point to faults. It is obvious that-^ggggpthose same factors are in severe question in relation to
this injection project.
Finally, I think what I would like to say is that geology is an imperfect science. I'm sure the
PowerTech geologists would agree. What cannot be seen below ground, cannot be anticipated
111!" jilj w^mwtnf'rtiTiTii i inn ill HI I n In my opinion, considering the toxic nature of these
injection fluids and the obvious dangers of both questionable confining layers aid their close
proximity to known and unknown fault and fracture lines, the idea that this project can be done
safely and with no ill effects to our water supply or to local geologic integrity, is foolhardy and
defenseless. The massive public and environmental loss that could very well occur far
outweighs the private gain that is being sought. Thank you.
(^J\
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RECEIVED JUN 19 2017
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S80M7
Ci
iy before uranium miring hearings | bocat 1 rapidcityiajrnal.oQm
5/6 f f]
littp://rapidc%JourfiaI,€om/n««s/tecal/€laifns
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98/2017 Clams, counterclaim# ly before uranium mining hearings | Local | reptfci^joornal.coifl
"They want to haul in waste from other states and possibly even other countries to permanently inject it right into our water* the narratorsayS *
in the video.
The video is part of a campaign by opponents of the mining proposal to encourage attendance at federal regulatory hearings Monday and
Tuesday in Rapid City, Wednesday in Hot Springs and Thursday in Edgemont.
Gardner Gray of rural Prlngie, chairman of the Council for Responsible Mining, admitted in a journal phone interview that he has no direct
knowledge of a plan by the mining company, Powertech, to bring other companies* waste fluid to the mining site.
"I haven't heard it from them, but I have heard it" Gray said.
Gray referenced uranium prices, which were $50 to $60 per pound five years ago but are now $20 to $30 per pound. He predicted Powertech
will not mine uranium if prices stay so low but will instead seek revenue by accepting and Injecting waste fluid from other mines at the
Edgemont-area site.
Mark Hoflenbeck, an Edgemont-area rancher and project director for Powertech, spoke with the journal by phone and denied the claim by the
Council for Responsible Mining.
'That is absolutely false,' he said,
Hoflenbeck said Powertech — a U.S. division of the global Azarga Uranium Corp. — does not plan to accept waste fluid from other mines. But
even if it did, Holtenbeck said, other mines already have their own disposal permits and would have no economic incentive to haul their waste to
the Edgemont-area site,
Powertech has received two draft permits from the U.S. Environmental Protection Agency, including one that would allow the company to inject
mining waste fluid underground. According to the EPA, the permit would not restrict Powertech from bringing in waste fluid from other mines.
The waste-disposal issue and others will be aired this week as the EPA conducts 28 hours of public hearings on the draft permits before issuing a
final decision sometime after May 13. This week's hearings will be from 1 p.m. to 8 p.m. each day — Monday and Tuesday at the Best Western
Ramtata Hotel in Rapid City, Wednesday at the Mueller Center in Hot Springs, and Thursday at St. James Catholic Church in Edgemont.
During the first hour of each hearing, EPA officials will be available to meet individually with members of the public and answer questions. The
EPA officials will then make a brief technical presentation and open the hearing to public comments. Attendees who wish to speak will be asked
to sign up and speak in the order of the sign-up sheet
The first hearing was April 27 In Valentine, Neb., and drew about 50 people. The EPA located the meeting there to accommodate residents of
Native American reservations in South Dakota and Nebraska,
The proposed mine location is in a sparsely populated area 13 miles northwest of Edgemont, near the old Dewey and Burdock townsites along
the southwestern edge of the Black Hills. Instead of extracting uranium-bearing ore with traditional pit and tunnel mining, which was conducted
extensively In the Edgemont area from the 1950s to the 1970s, Powertech wants to use a method known as "in situ* — a Latin phrase meaning
"in its place.**
The company would capture underground water, mix it with oxygen and carbon dioxide, and inject the solution into underground ore bodies to
loosen deposits of uranium.
The uranium-bearing solution would then be pumped to the surface, where the uranium would be removed and dried into yellowcake for
eventual refinement and use in nuclear power plants. The water-based solution would be reused until ail the uranium at the well site is
extracted. The solution would then be treated and disposed of by injecting it into a deep underground body of water known as an aquifer.
-------
S8KD17
Claims, eountefdalrrwfly before uranium mining hearings | local | rapitfcftyjoumai.com
4 -* •
A similar system is now operating near Crawford, Neb., about 120 miles due south of Rapid City,
The Council for Responsible Mining video describes the waste fluid as toxic and radioactive, Hollenbeck, of Powertech, said regulations require
the waste fluid to be treated and made safe before it is injected underground.
"It's basically saltwater," Hollenbeck said,
Powertech acquired its Edgemom-area mining rights in 2006 and has been attempting to begin mining ever since. It already has a license from
the U.S. Nuclear Regulatory Commission. If Powertech's EPA permits are finalized, the company would still need additional permits — including
from the state of South Dakota — to begin mining.
One of the EPA permits would allow Powertech to drill as many production wells as the company desires — potentially 4,000 of them, according
to one EPA document — within 14 designated well fields. The production wells would go hundreds of feet underground into the Inyan Kara
formation of aquifers.
The other EPA permit would allow Powertech to drill up to four disposal wells, from 1.615 to 2,540 feet underground in the Minnelusa formation
of aquifers. The Council for Responsible Mining has claimed that Powertech is seeing eight disposal wefts. That was originally true, but
Powertech has since withdrawn Its request for four of the disposal wells, leaving only the remaining four wells in the draft EPA permits.
The EPA is also proposing to exempt the portion of the inyan Kara aquifer in the project area from the Safe Drinking Water Act, which is
necessary for mining to occur there.
Critics of the project say the mining solution and the injected waste fluid could migrate arid contaminate other underground water sources.
"No money is worth that," Gray said. If we don't have water, we dont exist down here."
Hollenbeck said Powertech's project is environmentally sound, and while he will attend this week's hearings, he does not plan to comment orally
and instead plans to submit written comments prior to the EPA's May 19 deadline.
Hearing schedule
This week's schedule for public EPA hearings on two permits for a proposed in situ uranium mine near Edgemont:
• Monday and Tuesday, 1 to 8 p.m. (with a bredk from 5 to 6 p.m.). Best Western Romkou Hotel, 211f N, La Crosse St., Rapid City.
• Wednesday, 1 to S p.m. (with a break from 5 to 6 p.m.!, Mueller Center, 801 S. Sixth St., Hot Springs.
• Thursday, t to 8 p.m. (With a break from S to 6 p.m.), St. James Catholic Church, 310 Third Ave., fcdgemont.
-------
Clams, counterclaim* iy Mora uranium miring hearings | Local j rapidcftyjtxjmBl.com
W201?
Written comments may be submitted by midnight May 19 to Vatots Shea by email, shea.valois#epa,gov; fax, (303) 312-6741; or mall, U.S. EPA Region 8 Mail Code ^
8WP-SUI, 1595 wynkoop St. Denver, CO, 80202-1129.
Seth Tupper
Seth Tupper is an enterprise reporter for the Rapid Cityjournal and the author of the new book "Calvin Coottdge in the Black Hills."
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LakM 683: Lakota Environment Mgmt. and Protection
*TYToyt| to
Powertech Uranium Mining in the Black Hills
i
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uJo owe
Introduction:
Powertech Uranium Mining Company proposes to mine uranium in the Black Hills of South
Dakota. This is a Canadian company known as Azarga Uranium, In actuality, this company is
comprised of shareholders and a Chinese investment fund. This Chinese investment fund is
under investigation by Chinese authorities. It doesn't state what they are under investigation /^L
for. Powertech proposes to take water out of the ground. The Madison Aquifer. The drainage
will eventually leach into the Ogallala Aquifer which reaches down to Texas, There are
thousands of wells that draw water from the Ogallala Aquifer through eight states. Nebraska
has the most abundant well water available. Should Powertech be allowed to utilized this
source of water from the Madison Aquifer, There are many repercussions. Wells are already
depleted across several states. More water is being pumped out of the aquifer then being
replenished, This hurts the famers who depend on these wells for their crops and safe drinking
water. Cattle operations are vast and many across these eight states. The United States
depends on these states to produce the food we eat and export,
states to produce the food we eat and export. I »
D /ywS
" Y.o kfpd a
). to $50.00 per pound. Acgprding to a recent article in the \U
Uranium Mining: J p~*
The going rate for uranium is $30.
Rapid City Journal. Uranium mining has become more profitable since the nuclear meltdown in
Fukushima, Japan. There is talk of Powertech using these bore holes already in the ground from
past mining near Edgemont, S.D. mining. Powertech will be utilizing current sites already bored J
into the ground. These were drilled 20,30 and even 40 years ago. Producing uranium isn't
cheap. There are many factors in job costing for these projects. Such as production costs,
uranium mining\miliing costs, financial & market costs and world production costs. All these
2
-------
factors are considered for a profit. There is money to be made in the Black Hills. There is only
one Mother Earth. When she is depleted; Powertech will have their profits and move on to
their next project. The nuclear industry has always said they are environmental sensitive. But;
that isn't the truth.
Death and Destruction;
There are many direct and indirect social ills associated with uranium mining. Wells in local
areas will have their wells drop many feet. Livestock will suffer and radon emissions will affect
the surrounding communities. Not to mention chloride, sulfate, radium and iron being present in
wastewater ponds. It is bad enough wells contain arsenic already and contribute to the cancer
rates, Cancer clusters are a reality. The cost of treating cancer is expensive and does lead to
death. Add that to the cost of dying and It becomes more expensive. The benefits to the
communities are not what they seem once the in-situ leaching starts. There are many chemicals
that will be in the well water, ground and in the air. This project is about making money for the
shareholders. The Chinese Investment Fund will get their profits and the surrounding
communities will suffer the ill effects, always said they are environmental sensitive. But; that
lsn'"he,ru'h- CA/o®ci? , XJjjaSk i
Conclusion: 7^ A-/
The economic benefits to the state of South Dakota will be minimal compared to the cost of
health care and cleaning up the environment. According to The Dakota Rural Action
organization; Azarga is requesting an exemption from the EPA Safe Drinking Water Act. They
have a good argument. Azarga expects to receive this water for free. They plan on using 12.96
million gallons of water per day. Multiply that by 20 years and at some point all water will be
(J/
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unfit for drinking in the local wells and possibly the Ogallala Aquifer, That is a lot of water being
contaminated and pumped back into the bore holes already there from past mining. And who
says Powertech won't supplement their profits margins by allowing other waste from outside
companies. It's their permit to do whatever they want, project is expected to last between
seven and twenty years. Should there be leaks and contamination to the environment. The run
off will drain into the Cheyenne River and Angostura Reservoir. Angostura is a recreational
manmade lake for boating and, swimming and fishing. It was created for irrigation to crop lands
and for watering cattle mainly. It is bad enough there is radiation in the water. Letting
Powertech\Azarga mine the Black Hills is a catastrophe waiting to happen. And I believe in
"Murphy's Law."
4
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May 8,201?
EPA D-B Hearing Board
Best Western Ramkota Inn
Dear Sirs,
Yesterday I printed off the 151 page EPA summation entitled "Draft Cumulative Effects Analysis of the
Dewey-Burdock Uranium in-situ Recovery, Underground Injection Control Area Permits" and took most
of the day to read it because I wanted to be as fair as I could be about this process. The report painted a
rather benign picture of the mining process ending with kudos for the small carbon footprint left by the
power plants that produced the electricity from the enriched uranium. Not mentioned was the
enormous amounts of electricity required to isolate U234, U235 from U238 generated by coal or gas
fired power plants but more importantly the toxic products of this process that we are creating with no
safe place to put them. The entire nuclear industry has left behind a toxic nightmare that has to be
dealt with and has been systematically ignored and made the responsibility for a future generation.
With regard to the ISR mining operation, many people might be concerned that sedimentation ponds
will leak and contaminate ground water (which they have in other ISR locations), migratory birds wil!
land in these ponds, insects will obtain water from them to become food for birds, West Nile virus will
become more prevalent because of the breeding opportunities for mosquitoes among other things.
Another concern is the in-situ mining process itself which uses a lixivient solution to release and suspend
uranium in solution but also does the same for a number of other toxic heavy metals including arsenic,
vanadium, selenium, et.al that are withdrawn with the uranium and wind up being precipitated out in
the settlement pond or sprayed onto fields or sent to a class V deep well. But another concern is that
even with numerous sweeps in the restoration phase they remain in solution and without the reducing
field formerly provided by the mined out ore body will migrate down gradient within the aquifer to find
at some point a breccia column, unplugged bore hole, fracture, mining tunnel or fissure. We are told
that TVA did a wonderful job of plugging the bore holes but alas there are some that weren't. The
radioactive remains like thorium, radium and presumably non-radioactive elements like lead, arsenic
and selenium, products of the RO process that weren't disposed of by spraying on the land or placed in a
deep disposal well are sent to White Mesa even though they are trying to detoxify that site as well.
Another issue is water consumption where the water Is poisoned beyond any future use, although
according to EPA report that might be kept to a minimum in the mining process by stripping the lixivient
by RO and reinjecting most of that water back into the Inyan Kara aquifer to repeat the cycle. The
restoration phase might be another matter though where multiple pore volumes are required to bring
concentrations of these toxic elements even close to baseline levels which has never occurred in any ISR
mining operation.
What I see is the worst part of this question though is that the mining phase is just the start of a
horrifying development that results in ever more toxic next phases of the uranium story. The UF6 leaks
In the separation phase, the electrical generation using the enriched/blended U235, the military uses
that have poisoned countless people worldwide from the fallout and bio-accumulation of radioactive
nuclides especially Csl37, Sr90,1131, Pu239 et.al. producing cancers; such as, lymphoma/leukemia,
-------
bone, pancreatic, liver, lung, brain, colon, skin and breast which has seen dramatic increases after the
1300 open air nuclear tests. Exploding nuclear power plants tike Three Mite Island, Chernobyl and now
Fukushima which is an ongoing disaster that won't be stabilized for 40 to a 100 years and continues to
gush 100's of tons of radioactive water into the Pacific every day ultimately biologically magnifying into
the fish and the humans that eat them. Cancer rates in Japan are just now becoming apparent as we
see children being affected by what is referred to as Chernobyl heart disease caused by csl37. We have
our own Fukushima potentially waiting for us at the Indian Point reactor just above NY City also subject
to the effects of an earthquake. Given the artificially extended lives of our aging nuclear power plants
are more such events going to happen? It is just a matter of time before we find out. And now we have
high level nuclear waste with no place to go. Oh, yes of course we have Yucca Mountain which will be a
disaster because it is not sealed off from water incursions, iut we would have to have dozens of Yucca
Mountains to take care of all the waste sitting around just the 104 nuclear reactors in the United States,
And then it has to be safely transported. The American build sheet metal casks that last about 30 years
but the German build cast Iron ones seem to last much longer and don't seem to crack with age for on-
site storage. And don't leave out the military uses of course. The Nagasaki/Hiroshima experiment is still
with us as are the depleted uranium (U238 without the U235) particulates being enjoyed by the Iraqi
people to the point where they are afraid to have children in some places. The high level waste from
WWII is still sitting in giant pools and with time leaking Into the Columbia River. And now "we" want to
invest a trillion dollars In making nuclear weapons over a 30 year program to make them more user
friendly. We have made a Faustian bargain with the Devil by creating problems no one will be able to
solve and in the process engaged in a collective death wish that might be granted earlier than we
thought with the present administration tiling agencies at the top with administrators who are ignorant
and hostile to their missions,
Like the people on the trains to Auschwitz we have to ask ourselves 'where are we going?" before it is
too late.
-------
5(&(t7
ffom
EPA D-i Hearing Board
Best Western Ramkota Inn
Dear Sirs,
Yesterday I printed off the 151 page EPA summation entitled "Draft Cumulative Effects Analysis of the
Dewey-Burdock Uranium fn-situ Recovery, Underground Injection Control Area Permits'* and took most
of the day to read it because I wanted to be as fair as t could be about this process. The report painted a
rather benign picture of the mining process ending with kudos for the small carbon footprint left by the
power plants that produced the electricity from the enriched uranium. Not mentioned was the
enormous amounts of electricity required to isolate U234, U23S from U238 generated by coal or gas
fired power plants but more importantly the toxic products of this process that we are creating with no
safe place to put them. The entire nuclear industry has left behind a toxic nightmare that has to be
dealt with and has been systematically ignored and made the responsibility for a future generation.
With regard to the ISR mining operation, many people might be concerned that sedimentation ponds
will leak and contaminate ground water (which they have in other ISR locations), migratory birds will
land in these ponds, insects will obtain water from them to become food for birds, West Nile virus will
become more prevalent because of the breeding opportunities for mosquitoes among other things.
Another concern is the in-situ mining process itself which uses a lixivient solution to release and suspend
uranium in solution but also does the same for a number of other toxic heavy metals including arsenic,
vanadium, selenium, et.al that are withdrawn with the uranium and wind up being precipitated out in
the settlement pond or sprayed onto fields or sent to a class V deep well. But another concern is that
even with numerous sweeps in the restoration phase they remain in solution and without the reducing
field formerly provided by the mined out ore body will migrate down gradient within the aquifer to find
at some point a breccia column, unplugged bore hole, fracture, mining tunnel or fissure. We are told
that TVA did a wonderful job of plugging the bore holes but alas there are some that weren't. The
radioactive remains like thorium, radium and presumably non-radioactive elements like lead, arsenic
and selenium, products of the RO process that weren't disposed of by spraying on the land or placed in a
deep disposal well are sent to White Mesa even though they are trying to detoxify that site as well.
Another issue is water consumption where the water is poisoned beyond any future use, although
according to EPA report that might be kept to a minimum in the mining process by stripping the lixivient
by RO and reinjecting most of that water back into the Inyan Kara aquifer to repeat the cycle. The
restoration phase might be another matter though where multiple pore volumes are required to bring
concentrations of these toxic elements even close to baseline levels which has never occurred in any ISR
mining operation.
What I see is the worst part of this question though is that the mining phase is just the start of a
horrifying development that results in ever more toxic next phases of the uranium story. The UF6 teaks
in the separation phase, the electrical generation using the enriched/blended U235, the military uses
that have poisoned countless people worldwide from the fallout and bio-accumulation of radioactive
nuclides especially Csl37, Sr90,1131, Pu239 et.al. producing cancers; such as, lymphoma/leukemla,
-------
bone, pancreatic, liver, lung, brain, colon, skin and breast which has seen dramatic increases after the
1300 open air nuclear tests. Exploding nuclear power plants like Three Mile Island, Chernobyl and now
Fukushima which is an ongoing disaster that won't be stabilized for 40 to a 100 years and continues to
gush 100's of tons of radioactive water into the Pacific every day ultimately biologically magnifying into
the fish and the humans that eat them. Cancer rates in Japan are just now becoming apparent as we
see children being affected by what is referred to as Chernobyl heart disease caused by csl37. We have
our own Fukushima potentially waiting for us at the Indian Point reactor just above NY City also subject
to the effects of an earthquake. Given the artificially extended fives of our aging nuclea r power plants
are more such events going to happen? It is just a matter of time before we find out. And now we have
high level nuclear waste with no place to go. Oh, yes of course we have Yucca Mountain which will be a
disaster because it is not sealed off from water incursions. But we would have to have dozens of Yucca
Mountains to take care of all the waste sitting around just the 104 nuclear reactors in the United States,
And then It has to be safely transported. The American build sheet metal casks that last about 30 years
but the German build cast Iron ones seem to last much longer and don't seem to crack with age for on-
site storage. And don't leave out the military uses of course. The Nagasaki/Hiroshima experiment is still
with us as are the depleted uranium (U238 without the U235) particulates being enjoyed by the Iraqi
people to the point where they are afraid to have children In some places. The high level waste from
WWII is stilt sitting In giant pools and with time leaking Into the Columbia River. And now "we" want to
Invest a trillion dollars In making nuclear weapons over a 30 year program to make them more user
friendly. We have made a Faustian bargain with the Devil by creating problems no one will be able to
solve and in the process engaged in a collective death wish that might be granted earlier than we
thought with the present administration filling agencies at the top with administrators who are ignorant
and hostile to their missions.
Like the people on the trains to Auschwitz we have to ask ourselves "where are we going?" before it is
too late.
Sincerely,
-------
Dear Ms. Shea,
This letter is concerning the Powertech proposal to use groundwater from the Madison aquifer, and to utilized deep well
injection methods to dispose of waste associated with uranium mining.
I strongly object to both of these proposals. I urge the EPA not to permit these activities in the counties of Fall River and
Custer located in the south western South Dakota.
My objections are based on the probable contamination of the Madison & Inyan Kara aquifers.
I strongly object to both of these proposals. I urge the EPA not to permit these activities in the counties of Fall River and
Custer located in the south western South Dakota. My concerns are with the health and well being of the ecology of the
area, the Cheyenne River and all waters downstream of the proposed injection well sites.
Please Do Not issue permits for these projects
Sincerelv,
-------
-------
im^io
EPA Azarga/Powertec
Public Hearings
My name is I moved to Hot springs in 2002
because of the abundant clean, pure spring water here. I moved
from Colorado after spending my childhood in Breckenridge, Co.
I moved to Golden, Co and then to Boulder, CO in the 1970's. I
became involved With the Rocky Flats Truth Force, a group of
people who wanted the truth about the Rocky Flats nuclear
weapons plant to be exposed.
I watched friends who got high paying jobs at Rocky Flats right
out high school turn yellow than green, then gray and then they
died. The whole time the information coming out of Rocky Flats
was the levels of radioactive were safe and below normal ranges.
In the 1983,1 took my 18 month old daughter to a protest on the
ground above the underground plant. A few years latter when the
plant was closed due to radioactive contamination a»d^e EPA
came in to dean up the underground plant and the plans for the
ground above was for an open space. The EPA found the levels
of radioactivity were so high the ground was not even safe for day
use and it stands empty and fenced off to this day.
I drove from Golden to Boulder when I was attending CU and
went right by Rocky Flats. I always thought as I was passing I
would just hold my breath. While attending CU I was an art major
with my focus on Pottery. In the glaze room where I formulated
glazes form mineral powders there was a large jar with a skull and
cross bones and a sign, vanadium oxide. It was a beautiful yellow
and I experimented with it. Today I know that vanadium is
radioactive and I carry that in my body today. I am in the 97.5
percentile for vanadium.
-------
In the 1970, one of the many geology classes I took in college^
was palrffttolot^, We took a field trip to an old limestone quarry
right across the highway fjotm Rocky Flats. We were digging in
the radioactive limestone for marine fosseis. People dWt
believed that this was safe. I carry uranium in my body today. I
am in the 95 percentile for uranium.
In the 1960 and 70's the public was not educated about
radioactivity and believed the propaganda mining, power and
weapons industry fed them. Today it is different and we know the
dangers of radioactivity. It's ironic, that the pickecfsigns for Rocky
Flats nuclear weapons plant I painted were "Don't kill me before
the enemy". None of the nuclear bombs made at Rocky Flats
havejbeen use against any enemy. The radioactivity released in
making all those bombs still contaminates the earth and many of
us who lived there.
I have been the organizer of a group of citizens in the Southern
Hills, working to educate the people of Fall River and Custer
County about radioactivity, uranium, and the inSitu Leach mining
process.
I am handing^ayrtoty in witfr-a copy of QpHtforfaris hydrology
testimony tor the NfciC Hearings inJjtfltyl will be suBrfiltting my
iwltenc0rf!riief#«rm waste injected into
our drinking aquifers. I ha>\ h^- Icim. \,Yov b- (i rdw\ o/U-
-------
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t ^Ve3 V" £ ( M \L\_- O—' cs
Wh ^ ^ ^ _ ^eoU^
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-------
UNITED STATES OF AMERICA
NUCLEAR REGULATORY COMMISSION
BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
In the Matter of
POWERTECH (USA) INC.,
(Dewey-Burdock In Situ Uranium Recovery
Facility)
Docket No. 40-9075-MLA
ASLBP No. 10-898-02-MLA-BD01
SUPPLEMENTAL DECLARATION OF DR. ROBERT E. MORAN
I, Dr. Robert E. Moran, do hereby swear that the following is true to the
best of my knowledge:
Professional Qualifications and Introduction
Robert E. Moran, Ph.D.
Michael-Moran Assoc., LLC
Water Quality/Hydrogeology/Geochemistry
Golden, Colorado, U.S.A.
1. I am a hydrogeologist and geochemist with more than 40 years of
domestic and international experience in conducting and managing water quality,
geochemical and hydrogeologic work for private investors, industrial clients, tribal
and citizens groups, NGO's, law firms, and governmental agencies at all levels.
Much of his technical expertise involves the quality and geochemistry of natural
and contaminated waters and sediments as related to mining, nuclear fuel cycle
sites, industrial development, geothermal resources, hazardous wastes, and
water supply development. In addition, I have significant experience in the
application of remote sensing to natural resource issues, development of
resource policy, and litigation support. I have often taught courses to technical
and general audiences, and has given expert testimony on numerous occasions.
Countries worked in include: Australia, Greece, Bulgaria, Mali, Senegal, Guinea,
Gambia, Ghana, South Africa, Iraqi Kurdistan, Oman, Pakistan, Kazakhstan,
Kyrgyzstan, Mongolia, Romania, Russia (Buryatia), Papua New Guinea,
Argentina, Bolivia, Chile, Colombia, Guatemala, Honduras, Mexico, Peru, El
Salvador, Belgium, France, Canada, Great Britain, United States.
-------
Literature Reviewed
2. In addition to my professional experience, the opinions and comments that
follow are based on review of all, or significant portions of the following
documents:
Powertech Application for NRC Uranium Recovery License, Dewey-Burdock
Project, Feb. 2009:
• Technical Report (TR)
• Environmental report (ER)
• Supplement to Application, Aug. 2009
Powertech submittals (2010,2011, 2012)
Abitz, R.J., 2003 (Mar. 3), Declaration of Dr. Abitz, Before U.S. NRC, Atomic
Safety & Licensing Board Panel, Administrative Judges, in Matter of: HYDRO
Resources, Inc., Crown Point, NM; Docket No. 4Q-8968-ML.
Abitz, R.J., 2009 (Oct. 31), Comments on Powertech's Proposed Baseline
Plan, (R Squared 2009) for the proposed Centennial Site, Colorado, 6 pg.
COGEMA, 2003, Irigaray Project (IR), Quarterly Progress Report of Monitor
Wells on Excursion Status, License SUA-1341.
Crancon, P., E. Pili, and L. Charlet, 2010, Uranium facilitated transport by water-
dispersible colloids in field and soil columns: Science of The Total Environment,
Vol. 408, No., (1 April 2010), Pg. 2118-2128.
Davis, J .A., G.P. Curtis (U.S. Geological Survey), 2007, Consideration of
Geochemical Issues in Groundwater Restoration at Uranium In-Situ Leach
Mining Facilities: U.S. NRC, NUREG / CR-6870.
Driscoll, D.G., J.M. Carter, J.E. Williamson, and L.D. Putnam, 2002, Hydrology of
the Black Hills Area, South Dakota: U.S. Geological Survey Water Resources
investigation Report 02-4094, ML12240A218.
Ecometrix Inc., Nov. 2008, A Review of Environmental Criteria for Selenium and
Molybdenum: prepared for The MEND INITIATIVE; MEND Rept. 10.1.1.
Faillace, E.R., D.J. LePoire, S.-Y. Chen, and Y. Yuan, May 1997, MILDOS-
AREA: An Update with Incorporation of In Situ Leach Uranium Recovery
Technology: Letter Report, Argonne National Laboratory, Environmental
Assessment Division, Argonne, IL.
2
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Fisher, W.L., L.F. Brown, Jr., A.J. Scot, J.H. McGowen, 1969, Delta Systems in
tie Exploration for Oil and Gas; U. of Texas Bureau of Economic Geology; A
Research Coloquium.
Freeze, R.A, and J.A. Cherry, 1979, Groundwater; Prentice-Hall, 604 pg.
Galloway, W.E., 1982, Epigenetic Zonation and Fluid Flw History of Uranium-
Bearing Fluvial Aquifer Systems, south Texas Uranium Province; Texas Bur.
Econ. Geology, Rept. of Investigations No. 119, 31 pg.
Gott, G.B., R.W. Schnabel, 1963, Geology of the Edgemont NE Quadrangle Fall
River and Custer Counties, South Dakota, USGS Bulletin 1063-E.
Gott, G.B., D.E. Wolcott, C.G. Bowles, 1974, Stratigraphy of the Inyan Kara
Group and Localization of Uranium deposits, Southern Black Hills, South Dakota
and Wyoming; U.S.G.S. Prof. Paper 763,57 pg.
Hall, Susan, 2009, Groundwater Restoration at Uranium In-Situ Recovery Mines,
South Texas Coastal Plain: U.S.G.S. Open-File Report 2009-1143,36 pgs.
Harshman, E. N„ 1972, Geology and Uranium Deposits, Shirley Basin Area,
Wyoming; U.S.G.S. Prof. Paper 745, 82 pg.
Hem, John, 1985, Study and Interpretation of the Chemical Characteristics of
Natural Waters, 3rd Edit.; U.S.G.S. Water-Supply Paper 2254, 264 pg.
Henry, C.D. and R.R. Kapadia, 1980, Trace Elements in Soils of the South Texas
Uranium District: Concentrations, Origin, and Environmental Significance; Texas
Bur. Econ. Geology, Rept. of Investigations No. 101; 52 pg.
Henry, C D., W.E. Galloway, G.E. Smith, C.L. Ho, J.P. Morton, J.K. Gluck, 1982,
Geochemistry of Ground Water in the Miocene Oakville sandstone—A Major
Aquifer and Uranium Host of the Texas Coastal Plain; Texas Bur. Eoon. Geology
Rept. of Investigations No. 118; 63 pg.
Kuipers, J.R. (2000). Hardrock Reclamation Bonding Practices in the Western
United States: National Wildlife Federation. Boulder, Colorado, U.S.A., 416 pgs.
[This document and a summary can be obtained at:
http://www.mineralpolicy.org/publications/pdf/Bonding_Report_es.pdf]
Kuipers, J.R. and A. S. Maest, et. a!., 2006, Comparison of Predicted and Actual
Water Quality at Hardrock Mines: The reliability of predictions in Environmental
Impact Statements, 228 pages. Available at: http://www.mine-aid.org/ and
http://www.ea rthworksaction.org/publications.cfm?publD=213
http://www.earthworksaction.org/pubs/ComparisonsReportFinal.pdf
3
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Longmire, Patrick, Dale Counce, Elizabeth Keating, Michael Date & Kim
Granzow, Aqueous Geochemistry of Uranium and Arsenic: Los Alamos and
Surrounding Areas, New Mexico.
www.unm.edu/~cstp/Reports/H20_Session_4/4-1__Longmire.pdf
McCarthy, J.F. and J. M. Zachata, 1989, Subsurface Transport of Contaminants:
mobile colloids in the subsurface environment may alter the transport of
contaminants. Environ. Sci. TechnoL Vol. 23. No. 5. Abstract available at:
http://pubs.acs.org/cgi- bin/abstract.cgi/esthag/1989/23/i05/f
pdf/f es00063a001 .pdf?sessid=6006!3
Moran, R.E., 1976, Geochemistry of Selenium in Groundwater near Golden,
Jefferson County, Colorado. Abstracts with Programs, Geological Society of
America. 1976 Annual Meeting. November 8-11,1976. 8(6);1018.
Moran, Robert E., 2000, Is This Number To Your Liking? Water Quality
Predictions in Mining Impact Studies, p. 185-198, in Prediction: Science,
Decision Making and the Future of Nature. D. Sarewitz, R. Pielke, Jr., and R.
Byerty, Jr., eds., Island Press, Washington, D C., 405 pg.
http://www.unc.edu/~mwdoyle/riverretreat2009/Moran 2000.pdf
Moran, Robert E., 2010 (April 4), Declaration before the Atomic Safety and
Licensing Board; in the matter of D-B; Docket No. 40-9075-MLA, 32 pages.
Mudd, Gavin, 1998, An Environmental Critique of In Situ Leach Mining :The Case
Against Uranium Solution Mining; Research report prepared for Friends of the
Earth (Fitzroy) with The Australian Conservation Foundation, 154 pg.
www. sea-us. org. au/pdfs/isl/no2isl. pdf
Otton, J.K., & S. Hall, 2009, In-situ recovery uranium mining in the United Stales:
Overview of production and remediation issues.
IAEA-CN-175/87
www-pub. iaea .org/mtcd/meetings/PDFplus/2009/.. .Z08_56_Otton_USA.pdf
Parson, J.C., 2013 (JA. 10), Comments on Docket ID NRC-2012-0277; Draft
Supplemental Environmental Impact Statement, Proposed Dewey-Burdock In
Situ Leach Uranium Mine, South Dakota; to Cindy Bladey, US NRC, 22pg.
Pilkey, O. H. and Linda Pilkey-Jarvis, 2007, Useless Arithmetic: Why
Environmental Scientists Can't Predict the Future;Columbia Univ. Press, 230 pg.
Ramirez, P. & B. Rogers. 2000. Selenium in a Wyoming grassland conmmunity
receiving wastewater from an in situ uranium mine. U.S. Fish and Wildlife Service
Contaminant Report # R6/715C/00. Cheyenne, WY. Sept. 31.
4
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Ramirez, P. Jr. arid B.P, Rogers. 2002. Selenium in a Wyoming grassland
community receiving wastewater from an in situ uranium mine. Arch. Environ.
Contain. Toxicol. 42:431-436.
Ramsey J.L., R. Blaine, J. W. Gamer, J. €. Helton, J. D. Johnson, L. N. Smith
and M. Wallace, 2000, Radionuclide and colloid transport in the Culebra
Dolomite and associated complementary cumulative distribution functions in the
1996 performance assessment for the Waste Isolation Pilot Plant. Reliability
Engineering & System Safety, Vol. 69, Issues 1-3, September 2000, Pages 397-
420.
Smith, R.B., 2005, Report on the Dewey-Burdock Uranium Project, Custer and
Fall River Counties, South Dakota, prepared for Denver Uranium co., LLC, 41 pg.
Staub, W.P., N.E. Hinkle, R.E. Williams, F. Anastasi, J. Osiensky, and D.
Rogness, 1986, An Analysis of Excursions at Selected In Situ Uranium Mines in
Wyoming and Texas; NUREG / CR-3967, ORNL / TM-9956, Oak Ridge Nat'l.
Lab, TN.
So. Dakota Dept. of Environment and Natural Resources (SDDENR), 2012,
Uranium Question and Answer Fact Sheet, 6 pg. (unnumbered).
http Vdenrsd.gov/Poweftech.aspx
Tourtelot, H.A., 1962, Preliminary Investigation of the Geologic Setting and
Chemical Composition of the Pierre Shale Great Plains Region: U.S.G.S. Prof.
Paper 390;81 pg.
U.S. EPA, 2007, TENORM Uranium Occupational and Public Risks Associated
with In- Situ Leaching; Append. Ill, PG 1-11.
US EPA, 2008, Technical Report on Technologically Enhanced Naturally
Occurring Radioactive Materials from Uranium Mining, Volume 1: Mining and
Reclamation Background: Previously published on-line and printed as Vol. 1 of
EPA 402-R-05-007, January 2006, Updated June 2007 and printed April 2008 as
EPA 402-R-08-005, Pg. 3-10.
http://www.epa.qov/rpdweb00/docs/tenorm/402-r-Q8-005-voliy402-r-08-005-v1.pdf
U.S. Energy information Administration (U.S. DOE), 2005, U.S. Uranium
Production Facilities: Operating History and Remediation Cost Under Uranium
Mill Tailings Remedial Action Project as of 2000
http://www.eia.doe.gov/cneaf/nuclear/page/umtra/title1map.html http://www.eia.d
oe.qov/cneaf/nuclear/page/ymtra/backqround html
U.S. Energy Information Administration (U.S. DOE), 2005, Edgemont Mill Site,
Fall River County, South Dakota
http://www.eia.doe.gov/cneaf/nuclear/page/umtra/edgemont title1.html
5
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U.S. Fish & Wildlife Service, 2007, Comments (FWS/R6 FR-ES) on Generic
Environmental Impact Statement for Uranium Milling Facilities (GETS); prepared
for U.S. NRC, Wash., D..C.
USGSJ United States Geological Survey, variously dated, National field manual
for the collection of water-quality data: U.S. Geological Survey Techniques of
Water-Resources Investigations, book 9, chaps. A1-A9, available online
at; http://Dubs.water.usas.aov/twri9A.
U.S. NRC, 1980(Apr. 25), Regulatory Guide 4.14, Revision 1, "Radiological
Effluent and Environmental Monitoring at Uranium Mills".
httoi//nbaduim s.nr>:.itov7docs/ML0037/ML003739<>41 .odf
U.S. NRC (Lusher, J.), 2003, Standard Review Plan for In Situ Leach Uranium
Extraction License Applications, Final Report: NUREG-1569.
U.S. NRC (R.C. Linton), 2006(7), Evaluation Report, Review of COGEMA
Mining, Inc., irigaray Mine Restoration Report, Production Units 1 Through 9,
Source Materials License SUA-1341.
U.S. NRC, May 2009, Generic Environmental Impact Statement for In-Situ Leach
Uranium Milling Facilities. ML091480244, ML091480188, NUREG-1910.
Washington, IX.
U.S. NRC, Nov. 2012, DRAFT Environmental Impact Statement for the Dewy-
Burdock Project in Custer and Fall River Counties, South Dakota; 2 Vols.
Wyoming DEQ, 2008, Settlement Agreement with Power Resources / Cameco
Resources, regarding Highland and Smith Ranch Uranium projects.
http://deq.state.wy.us/out/downloads/LQ%20SA%204231-08.pdf
Summary Comments
3. These opinions focus predominantly on the water resources and related
impacts within the proposed Dewey-Burdock (D-B) area. These waters are
natural resources presently used collectively by numerous parties (ranchers,
municipalities, tribal groups, fish and wildlife, mineral and oil and gas developers,
etc.). However, the DSEIS must realistically anticipate what will be the true long-
term uses of these waters—especially when many generations must be
considered. Thus, truly conservative assumptions should be employed—which is
not the case in this DSEIS.
4. Some of these waters are already contaminated bv past uranium-,
exploration and mining, with tittle or no remediation required bv any regulatory
anwKgTwjiich suggests a^greatdeal about the future oversight. The D-B site
©SiSiffc numerous old uTanium workings (shallow open-pit and underground),
accumulations of various contaminated waste materials, 1000s of unplugged
6
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boreholes, which likely provide hydraulic connections between various water-
bearing units. To allow for a meaningful review, all available borehole
information needs to be assembled and presented in a comprehensive manner.
5. Past exploration and mining activities have exposed the mineralized rocks
to reactive surface waters and ground waters and bacteria, increasing the
concentrations of numerous contaminating chemical constituents in local waters,
soils, etc. Nevertheless, some of the water-tearing units within and around the
DB area will still contain high or relatively-uncontaminated waters, suitable for
numerous other uses. This pattern is the norm at typical metal mine locations
worldwide, including uranium sites. The proposed D-B activities will increase the
concentrations of such contaminants in some local ground waters, as a
minimum. Thus, it 8s imperative that the specific locations and characteristics of
thesecontaifiinited and unc»nteminatS^iSi^eiefined in alDSEIS avjiiibte
"for puMKTeView and COffWnent prior to publication or a htiblSncrprpjed[
approval. - ~~~ " —~ r
6. The DSEIS gives the impression that all of the D-B-area waters (surface
and ground) are already contaminated. However the DSEIS fails to supply the
detailed data necessary to support that contention. Experience at similar
sedimentary uranium sites indicates that significant quantities of uncontaminated
ground water likely exist, and could be used for other livestock, agricultural,
domestic, etc. uses. The NRC has failed to require Powerte^h p provide
statistically-adequaterreliabfe nroonftmfinnf?/ hasftiine dala-eiiher within the D-B
project araa, or in surrounding regions. Without adequate baseline data, the
presently-uncontaminated waters could Be become
T6B^"acfiyifes7but the public would tiaye no.way Qf-discov&ring thk> impook-
7. The DSEIS fails to provide basic information necessary to reliably
evaluate future, LONGTERM impacts. If the D-B-area resources had been
evaluated in a truly detailed, interdisciplinary, scientific manner, the DSEIS would
have collected and summarized the most fundamental technical information
relating to water resources, such as:
• a^etailedjnwnto^of all present water users within a radius of at least 2
miles of Such an inventory would include
statistically-valid, preoperational data on welt yields, water levels, detailed
water quality. " " " "
• a*~detailed, statistically-valid summary of BASELINE data for water quality
and quantity from the relevant water-bearing units, based on pre-
operational data. These would already include evaluation of hydrogeologic
characteristics for all of the relevant water-bearing units based on actual,
long-term aquifer / pump testing data. Such baseline data would also
incorporate all relevant data collected prior to Powertech's involvement,
iraii^iii§jdati_OTltectecl during theJ950sJo the present4tad«lwiTioL
example, TVA data),
7
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• detailed data on the presence and condition of all subsurface borings
(exploration holes, oil and gas holes, etc.)
• a detailed spring and seep survey, which would haw included staisticalty-
retiable (and seasonally-meaningful) measurement of field parameters and
yields, detailed, water quality—all based on preoperational data.
• all such actual data / information could easily be summarized in the form
of maps, tables, and graphs, without resorting to thousands of pages of
disorganized text, which has been the approach taken by Powertech and
the NRC.
8. In addition, a technically-reliable study of the D-B area would have
summarized the detailed data and long-term impacts from the numerous actual,
operating and closed ISL sites (throughout the USA and other countries), to gain
insight on actual results and impacts obtained from a population of sites. It is
technically-meaningless to make deterministic predictions about such impacts at
a single site, especially a site to be operated by a company that has never
operated another ISL mine.
9. Impact evaluation (by NRC, PT and consultants) in this DSEIS fails to
follow accepted approaches used in the wider scientific community. The DSEIS
fails to use reliable scientific investigation to assess or compare known impacts
at populations of other operating and closed ISL sites. Most importantly, it is not
possible to reliably-rank future D-B impacts [SMALL, MODERATE, LARGE]
when the NRC and public lack reliable baseline data to use as a measure of
change. Such approaches would not be acceptable in most technical, scientific
(academic-research) publications.
10. The data and information described above are required for an analysis in
a DSEIS prior to FEIS or license approval. Otherwise reliable evaluations of
future impacts cannot be made. In addition, without such data, it will be largely
impossible to hold the operators responsible for future, unremediated impacts.
Specific Comments
The DSEIS has been publicly-released at a period specifically inconvenient
for public review.
11. By releasing the DSEIS over the winter holiday season, NRC has
obviously made review and commenting on these documents more difficult and
precluded the public from making a useful site visit to verify data and claims
made in the DSEIS.
8
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The DSEIS comprises thousands of pages of convoluted, poorly-organized
and inadequately-summarized material.
12. The various D-B documents submitted to the NRC encompass more than
14,512 pages, yet fail to adequately present the most basic data (see below).
For example:
-the 2009 Application was almost 6000 pages;
[Technical Report (TR)- 3103 pages; Environmental Report (ER)~ 2615
pages;
Supplement to Application- 66 pages.}
-the 2011 Powertech submittal totaled roughly 5000 pages;
-the present DEIS (Vols. 1 & 2) comprises 858 pg., which is only part of the
GEtS;
--the GEIS, to which much of the DSEIS refers comprises 3512 pages.
13. The relevant D-B information, if compiled in a direct, transparent manner
using predominantly maps, tables and graphs, could easily have been
summarized in 150 pages for the DSEIS. Instead, the DSEIS is so duplicative
and poorly-organized that it makes informed review by both the regulators and
general public unnecessarily convoluted.
The DSEIS fails to adequately respond to the weaknesses and written
criticisms of the Powertech Application.
14. The Powertech Application submittals (2009,2011) were prepared by
Powertech and its consultants, based largely on data collected by these same
parties. While the DSEIS states that it was prepared by the NRC [and the
CNWRA (Center for Nuclear Waste Regulatory Analyses)], it appears that It is
based entirety on these same Powertech data, with no new water-related data
added since the application. Clearly most of the DSEIS opinions are also based
on the technical opinions of Powertech and their consultants.
15. Also, the DSEIS fails to adequately respond or address most of my written
Opinions made regarding the D-B Application, which were submitted to the NRC
in April 2010 (Moran Declaration, April 2010).
The DSEIS is Tech nically-deficient, lacMn||Juu^^
needed to reliably evaluate likely impacts to the D-B*area-water resources
and related environment
16. The DSEIS admits that important water quality data collection and aquifer
testing will only be conducted after license issuance (e.g. DSEIS p. 2-16, 7-8, 7-
14, 7-17).
17. Such data are needed now, as part of any useful EIS and certainly prior to
issuance of an operating permit. These data include: reliable preoperational
9
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baseline data on water quality and quantity I yields of all relevant surfacejand
groumi^watefS;^p^^c'3Si*on the totalwater-votafies to be used by al P-B
operation^; detailed data" on hydrogeologic cftaraaensfe'ofWreievant geologic
units; detailed evaluations of the hydraulic Interconnections between the uranium
production zones and the other relevant water-bearing and confining units; data
on the detailed chemical compositions of barren and pregnant solutions,
evaporation pond waters, etc.; a detailed inventory of all water users within at
least a 2 mile distance of the D-B project boundaries.
Details on these categories are discussed below.
Concerns Expressed by Other Federal and Stale Agencies not Addressed
18. The DSEIS mentions on p. 1-15 and 16 that several other Federal and
State agencieshaye expressed concerns regarding impacts to Water Resources,
ete.lrwfFtheproposed 1KB project, but fails to discuss or address in any detgil
these criticisms. This omission gives the false impression that the present
comments (for the Oglala Sioux) are made in isolation from those of these other
regulatory agencies..
19. A brief review of the coordination conducted with other agencies reveals
the following points of concern with respect to these agencies:
- Coordination with BLM: South Dakota BLM field office:
provided NRC staffwftfc information on oil and gas leases in the proposed
project area. DSEIS. P1-16. Additionally, BLM staff expressed cjQDfietn§j®lated
to water quality and hydrology, land ..use, mod cumulative efftecte.
-Coordination with U.S. An^.Cog&^Engineers:
USACE documented the presence of 20 wetlands within the project area and
determined that 4 were jurisdictional waters; these are Beaver Creek, ap°
unnamed tributary to Beaver Creek, Pass Creek, amfan unnamed tributary to
fraas Creek (Powertech, 2009b, Appendix 3.5-H). ' ~ ¦*""
-Coordination with,, USPS:
it expressed concerns that construction and operational activities could impact
the nearby Black Hills National Forest and Buffalo Gap National Grasslands.
USFS staff noted a concern about the cumulative groundwater effects bfthe
project on the USFS-managed aquatic recreation areas of Cascade Springs and
Keith Parte Springs. USFS also expressed concerns about potential effects the
project could have on Craven Canyon, known to have traditional cultural
significance to Native American tribes.
-Coordination with USGS: With respect to the proposed Dewey-Burdock ISR
Project, USGS staff expressed a concern that contaminated groundwater may
travel from the project area and discharge into Beaver Creek within the proposed
10
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project area and the Cheyenne River south of the projo^,project area [via
groundwater or surface water],
-Coordination With South Dakota Department of Environment and Natural
Resources expressed concerns regarding:
ft thefadequacy of subsurface characterization, (ii) groundwater flow rates within
and in the vicinity of the project area, (iii) potential complications in hydrology
caused by past exploratory drill holes, (iv) potential hydrologic connection of
production zones and abandoned onsite surface mines, and (v) the effectiveness
of confining layers in isolating ore-bearing aquifers. NRC and SDDENR staffs
also discussed the applicant's Class III UIC permit application (Powertech, 2010)
and the water appropriation and waste management permitting processes for the
proposed project. Potential risks to wildlife from wastewater surface
impoundments associated with the proposed project were also discussed.
SDDENR would coordinate with SDGFP to mitigate the potential effects of
surface impoundments on wildlife; mitigation measures discussed included the
use of netting and fencing to protect wildlife and implementing protocols to
assess the effects of wastewater constituents on wildlife.
-Coordination with S.D. Game, Fish and Parks:
focused primarily on threatened or potentially threatened and endangered
species (e.g,»Jhe plains toprnlnnow, sage-grouse, and black-fooledjgjrjgt) and
species ofTTocafconcero (e.g., raptors). SDGFP expressed a major concern: the
potential effects on birds flying through the proposed project area and "" ~
drinking at exposed wastewater evaporation ponds SDGFP suggested two
measures to mitigate effects on bird populations: (i) testing to determine the
toxicity of constituents in the evaporation ponds and (ii) using netting and
fencing to restrict wildlife access to exposed ponds. SDGFP also noted the
need for testing and monitoring of soils at the proposed site to identify any
buildup of salts and metals that could result from proposed land application of
treated wastewater.
Water Use: The D-B Project will use and contaminate tremendous volumes
of ground water. How much water will be used throughout the life of the
proposed DB operation?
20. The D-B project area is semi-arid, having an average yearly precipitation
of about 12.4 inches, and the range of evaporation for the So. Dakota-WY-
Nebraska uranium region is between 40 and 50 inches (NRC GEIS 2009). Thus
evaporation is roughly 3 to 4 times the yearly precipitation (ER, pg. 3-176 and
177; Fig. 3.6-27). Because the project is presently expected to operate for
between 7 and 20 years, it will require the use of tremendous volumes of local
ground water, and will result in losses of significantly greater quantities of water
via evaporation.
11
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After 7 yrs - 239,148,000 gallons, or 239.15 Million gallons.
After 17 yrs ¦ 580,788,000 gals or 580,8 Million gallons.
320 gpm = 168.2 Million gpy (gals. I yr).
After 7 yrs = 1,177,344,000 = 12 Billion gallons
After 17 years * 2,859,264,000 gallons = 2,86 Billion gallons.
29. Clearly, this range of estimates indicates that vast quantities of ground
water will be extracted from these aquifers over the long-term. At a minimum,
Powertech should be required to construct a credible project water balance and
to more seriously investigate the potential that such large-volume water use
might impact local i regional ground water lewis and well yields.
30. At present, I see no evidence that the Application contains a reliable
compilation of baseline water level and pumping-rate data for the surrounding
domestic and stock wells (see discussion below). Without such reliable,
summarized data, there will be no viable method to demonstrate that ground
water levels (and related pumping costs) have not been impacted by project-
related activities.
31. The public must assume that Powertech will pay no cost for the actual
water (the commodity) used during operations—while numerous other users do.
The specifics of this issue should be addressed by Powertech in writing.
32. Despite the central role of water in the operation of the project, water use,
availability, depletion, and consumption are not seriously analyzed through a
water balance investigation, or other similar technique. This analysis is critical to
understanding the anticipated impacts during project review and for monitoring
actual water impacts should this project actually begin using and consuming
groundwater.
Hydrogeologic Performance of the Water-bearing and Other Geologic
Units.
33. The DSEIS fails to provide detailed, site-specific information / data on the
hydrogeologic characteristics of the relevant D-B water-bearing and other
bounding geologic unite, including the mineralized zones. Such data must be
obtained by performing and interpreting long-term, aquifer test data. The DSEIS
admits that such long-term, detailed testing will not be performed until after the
NRC license is issued (e.g. DSEIS at 2-17,7-11).
34. The hydrogeologic data presented in the DSEIS are inadequate to
reliably portray and predict the following:
-the baseline, detailed directions of ground water flow in the relevant water-
bearing units;
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-the extent of long-term hydraulic, connections between the various geologic
unite, both within the project area and outside;
-the horizontal / regional extent of water level declines (and impacts on pumping
rates) outside the project boundaries;
-the degree to which ground water withdrawals may impact local surface waters;
-the operator's ability to contain the migration of contaminants;
-the operator's ability to restore aquifer water quality to baseline / acceptable
conditions.
35. Such inadequate hydrogeologic data also mean that any ground water
flow simulations based on these data are likely to provide highly imprecise and
unreliable predictions (e.g. SEIS, P.2-16, L 30-37).
36. In addition, such inadequate hydrogeologic data, coupled with the lack of
reliable baseline water quality data (see below), render the NRC staff predictions
about impacts (both incremental and Cumulative) to water resources largely
meaningless (e.g. the Executive Summary and Section 5.0). For example,
despite failing to define the extent (areal, vertical) and specific, detailed chemical
compositions of past contamination, the NRC staff predicts that Cumulative
Impacts to Surface Waters and Wetlands will be MODERATE TO LARGE (p.5-
17), but that the D-B project will have a SMALL incremental impact on surface
waters and wetlands when added to all other past and present impacts (p. 5-30).
Given the lack of detailed baseline data (hydrogeologic and water quality) such
conclusions sound more like public relations statements than science.
Impacts from Long-term Pumping of Ground Waters.
Radius of Impacts I Influence, (modified from Moran Declaration, 2010)
37. The DSEIS presents no specific hydrogeologic information on the
anticipated declines in water levels at domestic and stock wells outside the D-B
project. Despite lacking adequate, long-term aquifer test data, the Powertech ER
(2009) presented predictions of water level declines after 8 years of continuous
pumping:
- 9.9 to 42.8 feet at the nearest domestic well in the Fall River Aquifer, located
15,075 feet [about 2.9 ml.J from the approximate center of pumping (ER pg 4-
23);
- 4.9 to 12.6 feet at the nearest domestic well in the Lakota Aquifer, located
10,915 feet [about 2.07 mi.] from the approximate center of pumping.
38. With such uncertainty, it is quite possible that some neighboring wells will
be negatively impacted (water level declines I reduced pumping rates). These
data interpretations indicate that domestic and stock, etc. wells should be
inventoried and monitored out to at least 2 miles from the D-B boundary.
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The D-B water-bearing unite are hydrogeologically interconnected.
39. The DSEIS avoids discussing definitively the likely hydraulic
interconnections between the various D-B water-bearing units. The 2009
Powertech Application does discuss these issues, but presents overly-optimistic
conclusions about the isolation of the ore- bearing zones, aquifers, and the lack
of fluid excursions that will occur, both vertically and horizontally. Powertech's
description and evaluation of possible water-related impacts [2009 Application,
ER pg. 8-2 (Table 8.1-1)] are unreasonably optimistic. It is unlikely that the
process waters can be contained within the project boundaries given the
following pathways that connect the project area with surrounding aquifers: 1)
sedimentary formations; 2) geologic fractures, 3) exploration boreholes, 4) mine
workings, 5), other anthropogenic fractures and borings.
40. The D-B uranium deposits occur in subsurface, fluvial channel, sandstone
deposits in the Lakota and Fall River formations (Smith, 2005). These
sandstones inter-finger with finer-grained silts and shales, often associated with
lignites and coals, which form the typical lithologic sequences often seen in
classic sedimentary uranium deposits (Abitz, 2005; Gott, 1974; Henry, 1982;
Galloway, 1982; Henry, 1980; Harshman, 1972).
41. Hydraulically, such sedimentary packages typically allow ground waters to
flow between the inter-fingering facies, both vertically and horizontally, when the
coarser- grained sediments are stressed by long-term pumping. The hydraulic
inter-connections are verified by conducting long-term aquifer tests integrated
with sequential water quality sampling and in-sltu measurement of field
parameters (Henry, 1982; Galloway, 1982; Moran, R E.—hydrogeochemical
research activities, U.S.G.S., Water Resources Div., 1973—1978). The hydraulic
interconnections of such inter-fingering facies has been well known for decades
within the petroleum industry research groups (e.g. Fisher, el at., 1969).
42. Thus, ore-bearing sandstones in typical sedimentary packages associated
with roll- front uranium deposits do not routinely behave as hydraulicalty-isolated
bodies. Numerous specific lines of evidence from the 2009 D-B Application
documents indicate that the project sediments possess various pathways for the
migration of water and contaminants from the ore zones into neighboring
sediments, both vertically and laterally. For example, thousands of exploration
boreholes have been drilled since the 1950's at the D-B site (Smith, 2005; TR,
ER), many of which were not correctly plugged and abandoned (TR, Pg. 2-157;
Append. 2.7-B, sub-Appendix D, pg. 1484; TR, Append. 2.6- A, pg. 972-1111). In
addition, several sources (Smith, 2005, pg. 9; ER, pg. 3-106) report that the area
contains historic shallow mine workings, both open pits and short tunnels that
would provide additional flow pathways.
43. There are numerous old and existing water wells and old oil test wells in
the D-B area, many with rusty and leaky casings, often unplugged or partially-
plugged, drilled through several formations which act as potential pathways for
15
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flow between water- bearing units (ER, pg.3-40; TR, Append. 2.2-A, pg, 740-779;
2.2-B, especially pg. 864- 902).
44. The 2009 Application, TR, pg. 2-153-154, states that hydraulic
connections between local D-B aquifers often result because confining units are
thin or are absent in many areas (ER, pg.3-56-57). In addition, Gott (1974) and
others have mentioned the presence of breccia I evaporite pipes (collapse
structures), which create vertical permeability pathways between aquifers. Gott
(1974, pg. 27-29) and others discuss the common presence of faults and joints
throughout the region, which could easily act as flow pathways. The DSEIS
states that detailed geologic mapping conducted by Powertech found no
indication of such breccia pipes (p. 3-32), but the document fails to state that a
detailed examination of all the subsurface data was searched for the presence of
such breccia pipes.
45. Vertical and lateral hydraulic connectivity between the ore zones and the
neighboring fades / formations are also indicated by the aquifer test results
conducted in both 1979 and 2008 (ER, pg.3-56-57; TR, pg. 2-170 & 2-180, for
example; TR Append. 2.7-B, Knight-Piesold Pumping Test Report, pg. 1290).
46. The DSEIS fails to assess the forgoing conditions, or likely impacts
associated with these conditions in any scientifically meaningful way, nor does it
consider that geologic materials with geologic / hydraulic characteristics similar to
the D-B target formations frequently yield both water and oil and gas from
geologic fracture*. A classic example is the Florence oil field in Colorado, which
has been producing continuously from fractures in the Cretaceous Pierre
Formation since 1862, making it the second oldest producing field in the U.S.
rhttp://ahostdepot.com/rq/librarv/maoazine/fiorence%20oil.htm 1.
47. The Pierre Formation exists in the Black Hills region and lies
stratigraphically above the Inyan Kara Group, the target formations at D-B
(Tourtelot, 1962; DSEIS p.3-14). Thus, it is likely that several of the geologic
units in the D-B area can also transmit fluids via fracture pathways. This indicates
that future computer simulations of D-B ground water flow and leach field
performance should be capable of modeling fracture flow characteristics.
48. The aquifer testing already performed demonstrates leakage between the
various formations / fades bounding the ore zone. However, it seems equally
likely that longer-duration aquifer tests conducted at even higher pumping rates
would demonstrate even more clearly the leaky nature of these site sediments.
Potential hydrogeologic pathways to nearby wells have not been
adequately investigated and documented.
49. The discussion above presents ample evidence that the D-B area
sediments contain numerous possible subsurface pathways for project leach
fluids to migrate vertically between water-bearing units and outside the project
16
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boundaries. Unfortunately, as noted above, Powertech has not adequately
defined the baseline water levels or water quality conditions of neighboring wells
within a 2-mile radius of the D-B project. In addition, the 2009 Application, TR pg.
2-180, states that no pubic date are available on the use of aquifers in Fall River
or Custer counties. Such data should have been compiled by Powertech as part
of the DSEIS and Application, and should be required before any licenses are
given.
Toxic and Hazardous Substances to be Used at D-B.
50. The following chemicals are proposed to be used / stored at D-B (DSEIS,
p.4-19):
The applicant proposes to store, use, and receive shipments of the following
chemicals: sodium chloride jNaCl), sodium carbonate (NaHC03), sodium
hydroxide (hauH),hydrochloric acid (HCI), hydrooen peroxide (H202), carbon
dioxide (C02), Qxygen (02), anhydrous ammonia (NH31. digs**! fuel, gasoline.^
'and bottled gases (Powertech", 2009b)."
51. All these chemicals are likely stored I used in concentrations that would
qualify them as toxic or hazardous substances. Releases of such chemicals can
contaminate local soils and waters. Despite the proposed use of these
chemicals, the proposed water quality (surface and ground waters) and soils
monitoring does include constituents adequate to demonstrate the presence of
several of these chemicals, especially the fuels / organic compounds (see
below).
Chemical Analyses (Detailed) of Ores, Pregnant Leach Solutions, Liquid
Wastes are not presented in the DSEIS.
52. The DSEIS fails to provide actual, detailed chemical analyses (numerous)
of representative pregnant leach solutions (ore reacted with lixiviant), both before
and after undergoing ion exchange treatment. Such data would routinely include
both in-situ measurements of fluid temperature, pH, specific conductance,
possibly D.O. (dissolved oxygen) and Eh (redox). Similar representative, detailed
data should also have been included for the detailed chemical composition of
liquid wastes to be disposed of via deep-well injection, land application and
evaporation.
53. Because most mining projects at a similar stage of advancement have
already conducted extensive laboratory testing and prepared Feasibility Studies
to present to potential investors, such detailed chemical composition data would
be available. It is not sufficient to present theoretical I expected chemical
compositions, as has been done in the 2009 Powertech ER, pg. 4-83. Smith &
Assoc. (2005), pg. 5, reports that TVA, one of the previous mineral right holders,
had a "pre-mine feasibility study" prepared, probably in the late 1970's or 1980's.
If TVA had obtained such detailed data in earlier decades, certainly Powertech
would have obtained the older Feasibility information and contracted to have an
17
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updated Feasibility Study performed. Clearly some information in Feasibility
Studies is considered proprietary, but detailed chemical composition data on the
pregnant solutions and liquids / wastes described above should be analyzed and
available to the public and included in any complete DSEIS.
Characterization of Water Resources: Inadequately Described and
Characterized.
54. The DSEIS fails to clearly distinguish site surface waters, ground waters
(including springs and seeps), wetlands, and waters flowing from boreholes. As
all of these waters are ultimately interconnected, hydraulically, this prevents a
clear understanding of future impacts to water resources. In several sections, the
DSEIS actually confusingly describes ground waters as surface waters. For
example, on p. 3-23, it discusses ground waters in abandoned mine pits as
though they are surface waters. Page 3-23 states that there are no known natural
springs within the proposed Dewey-Burdock ISR Project area, which does not
mean that a detailed attempt to locate and characterize such springs was ever
conducted. On p. 3-27-28, the DSEIS confusingly describes water flowing from
an old well as the source of a wetland, when i is obviously not a natural wetland.
55. DSEIS page 3-20 contains a section disingenuously entitled "Artificial
Penetrations', but which is strangely not included in the discussions pertaining to
either Surface oj-Qrouod Waters. It states: "According to the environmental
report, there a^4,000^xploration drill holes representing historic exploration
activities (Powertech, 2009a). The applicant has drilled approximately 115
exploration holes, including 20 monitoring wells in the project area. While the
applicant cannot confirm that all historic borings were property plugged and
abandoned, the applicant has made commitments to ensure that unplugged drill
holes will not impact human health or the environment during operations
(Powertech, 2009b, 2011). In the technical report (Powertech, 2009b), the
applicant stated that little evidence of unplugged boreholes has been observed
given infrared photography data. However, an infrared map of a portion of the
Burdock area shows an alkali pond area (Powertech, 2011). The applicant states
unplugged borings appear to explain the presence of this pond area. No other
pond areas or springs appear in infrared photography data of the Dewey-Burdock
site. There is no other evidence indicating that previously unplugged borings are
current groundwater flow pathways (Powertech, 2011)."
56. This section makes several half-explained statements as though they are
proven facts, and diverts from the likely hydraulic interconnections these
boreholes have created between the site surface and ground waters. It implies
that a careful study of the site using infra-red photography has been performed,
when it is clear that a map of only a portion of the site was available. Despite this
tortured language, there is no reason to dismiss the likelihood that many of the
old boreholes are acting as conduits between the various water-bearing units, at
least below the land surface. Strangely, the DSEIS describes the presence of
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several water-filled mine pits (p. 3-23), yet they are not mentioned as being
visible on the "infrared photography data of the Dewey-Burdock site". Clearly a
more thorough investigation using infra-red photography and satellite imagery is
called for.
Baseline Water Quality
57. The D-B project area has been historically mined and thousands of
exploration holes have been drilled within the properties. Hence, it is imperative
that high-quality baseline data be supplied to evaluate the actual extent of past
impacts to water resources, and the success of future containment or aquifer
restoration,
58. The DSEIS, like the Powertech Application, fails to define pre-operationat
baseline water quality and quantity—both in the orlrzunSs and peripheral zones,
boih venlgamrandtTuiizoiitallv. Without adequate baseline water quality data
(boliLgtojjnd water and surface water), thereis no reasonablfTnylhud furerther
the~publici3r the NRG to evaluate the success orfailure of either fluid-
containment or aquifer restoration. The DSEIS and Powertech Application
documents repeatedly attempt to convey tne impression that the D-B ground
wafeTquality is^aice^Hy Upgraded, rather than compile stattetTcally-defensible
data fromlxrth the ore zones and non-mineralized zones.
59. This approach contradicts NRC guidance, which requires that pre-mining
baseline conditions be defined before licensing (NRC, 2003, pg. 2-24). Failing to
define specific baseline conditions prior to license approval also contradicts
NEPA regulations (Parsons, 2013, p.2).
60. Failing to define and quantify preoperational baseline is also scientifically
unsupportable as it a Hows Powertech and the DSEIS to avoid discussing which
specific water sources are contaminated by past uranium mining activities and
which represent naturally-contaminated waters.
61. The DSEIS, Table 3.5-4 misleadingly presents what is entitled: Baseline
Groundwater Samples with Values Exceeding the MCLs(p. 3-38). Firstly, this
table and related discussion fail to make clear that many of these sites are
contaminated by past, un-remediated uranium mining and processing. Secondly,
the table leaves out most of the important baseline constituents a competent
evaluation would have included. Thirdly, the table leaves out any values below
the MCLs. Thus, this table does not represent baseline ground water quality.
Most importantly, the DSEIS does not contain tables of any of the detailed water
quality data, baseline or otherwise. Further, there is no data or analysis of the
hydrogeologica! mechanisms by which the previous contamination occurred,
spread, or was contained.
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62. Clearly the DSEIS / Powertech ground water baseline data should include,
as a minimum, the chemical constituents listed in Table 2.7.3.1 of the NRC's
Standard Review Plan (NRC, 2003, pg. 2-25), and Table 7.3-1 of the DSEIS. In
addition, baseline water quality monitoring (both ground and surface water)
should be expanded to include nitrate, ammonia, aluminum, antimony, strontium,
lithium, thallium, turbidity, scans for organic compounds, and / or total organic
carbon, and be integrated with in-situ field measurements (temperature, pH, S.C.
turbidity), water levels and well yields and / or flows.
63. It is only logical that the actual list of baseline constituents should be
based on analyses of pregnant solutions resulting from leach testing of the D-B
ores and lixiviants—not on theoretical assumptions about what might be the
chemical compositions. Such pregnant solution analyses should be made public
in the DSEIS prior to Application approval.
64. Frequently, uranium roll-front ores will also mobilize significant
concentrations of additional constituents, such as antimony, lithium, and
strontium (Moran, 1976). In addition, it is common to detect elevated
concentrations of aluminum, sometimes as the result of well-drilling and
completion techniques. Thus, it is recommended that these constituents be
included in routine determinations of baseline water quality. In fact, standard lab
analytical scans, such as ICP (inductively-coupled plasma spectroscopy)
routinely report all (or most) of these metals and metalloids at the same cost. It
should be noted that almost all of these constituents were included in the data in
Appendix 3.4-C of the Powertech ER.
65. I suggest that nitrate and ammonia determinations be included to allow
future analysis and determinations regarding impacts from agricultural or
industrial sources (ammonia may enter the aquifer via numerous agricultural or
industrial activities).
66. Section 2.7 of NRC (2003) is unclear whether applicants shall provide
water quality data from unflltered (Total concentrations) or 0.45-micrometer-
filtered ("dissolved") samples. Table 7.3-1 of the DSEIS states that only dissolved
constituents will be reported. Much of the D-B data in the Powertech Application
Appendices includes both dissolved and Total determinations. It is recommended
that unflltered samples be collected and analyzed, as a minimum, for baseline
ground water evaluation. These provide more conservative characterization of
the ground waters, and waters used in rural areas (human and livestock
consumption from wells; other agricultural uses; irrigation; fisheries) are not
filtered. Furthermore, contaminants carried in particulate form are ingested by
humans and other organisms when consuming unfiltered waters. These particles
/ colloids are dissolved by the extreme biochemical conditions found in the guts
of such organisms, mobilizing the contaminants into the blood and other tissues.
In addition, many trace constituents are mobile in ground waters as colloidal
20
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particles (McCarthy, 1989; Ramsey, 2000), which would be removed by filtration,
generating unreasonably-low concentrations.
67. Determination of "suspended* fractions is of little utility as there are no
regulatory criteria or standards for suspended forms, and such data are subject
to much greater error (from the combination of sampling arid analytical errors)
than are either simple filtered (Dissolved) or unfiltered (Total) determinations.
68. To ensure data quality, the D-B baseline data should include:
- statistical comparisons of the field and lab determinations of pH, and S.C.
for the same samples;
- comparisons of Dissolved versus Total determinations from the same
samples;
- ion balances, to assist in evaluating the reliability of the analytical data,
with comparisons of TDS and S.C. (Hem, 1985).
69. No coordinated, statistically-sound data set for all Baseline Water Quality
data (both surface and ground water) is presented in these documents—as is
required in NUREG-1569. The DSEIS makes clear that baseline water quality
will actually be established after operations begin (e.g. DSEIS p.7-13,14:
Projectwide GW monitoring). The DSEIS fails to include reliable baseline water
quality data for any of the categories of ground water or surface water.
70. The 2009 Powertech Application, carried forward in the DSEIS, include
what it incorrectly calls baseline. For example, on pg. 2-14 and 2-15 of the
Technical Report (TR), Sect. 2.2.3.2.2, Powertech states: "At the project site,
baseline groundwater sampling was conducted in general (sic) accordance with
NRC Regulatory Guide 4.14 (NRC, 1980).... A summary of the results and
methods for the groundwater quality monitoring program, as well as the historical
TVA data, is presented in Section 2.7." However, when the reader goes to TR
Section 2.7, there are no tables that actually statistically summarize complete
baseline field and lab water quality data for the complete data sets—both historic
and recent. Instead, for ground waters, Powertech presents statistics for field
data from individual wells or selected aquifers, but fails to statistically-summarize
the laboratory data and leaves out the historic TVA data. Powertech then states
(TR, pg. 2-203): "Complete groundwater quality data results are available in
Appendix 2.7-G." However, on TR, pg. 2-205 (Sect. 2.7.3.2.2.2, Results for
Laboratory Parameters) Powertech then states: "Summary statistics for baseline
monitoring program laboratory samples are contained in Appendices 2.7-H and
2.7-I. Appendix 2.7-H gives statistics for all groundwater constituents detected at
or above PQL by constituent." Thus, it appears that Powertech has not included
"qualified values," that is data reported as "less than" some concentration. By
deleting the "less than" values, Powertech has severely biased the data set,
rendering it useless as a reliable source for evaluating baseline conditions.
21
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71. Furthermore, Powertech states (TR, pg. 2-217-218) that they have
arbitrarily selected some analyses from the voluminous historic TVA date, but the
reviewer is never allowed to see a statistical summary of the total original data
set. This error is carried forward in the DSEIS. Portions of the relevant date are
scattered throughout the Appendices of the various documents, and
disingenuously organized to leave out all baseline data that had concentrations
reported below the detection limits (i.e. "less than" values). Obviously, this
approach biases the data. The NRC must require Powertech to statistically
summarize all historic water quality data and all recently collected data in
separate tables, including ail "less than values." Both historic and recent baseline
data should be segregated by water-bearing unit. Even should averaging of
water quality data over a portion of the aquifer be acceptable, the methodology
employed in the Application and DSEIS of discounting relevant data points is
untenable.
72. To further confuse the baseline issues, Powertech's Supplement to the
Application (August 2009) states on pg. 3-3: "A minimum of eight baseline water
quality wells will be installed in the ore zone in the planned well field area." Thus
it appears that the Applicant intends that the massive amounts of water quality
data (historic and recent) presented in both the TR and ER (Environmental
Report) will not actually be used to determine baseline. More importantly, it is
unclear whether Powertech has true baseline (pre- operational) ground water
quality data that describe the non-ore zone regions of the relevant aquifers. It
is imperative that baseline data for the non-ore zone ground waters be collected
and summarized separate from those of the ore zones - a review the DSEIS fails
to conduct.
73. Any revision of the DSEIS should incorporate the comments made in Abitz
(2009) regarding baseline characterization and data interpretation.
74. Lastly, the DSEIS should already contain a statistically-reliable database
of baseline ground water quality data from all known wells within at least 2 miles
of the DB boundary
Confusion of Baseline and Background
75. Table 7.3-1 of the DSEIS (p. 7-8 to 7-11), and the accompanying text
confusingly and incorrectly use the terms "Background" and "Baseline" as having
the same meaning. For many decades, "background" in geochemical / water
quality literature has been defined as: "The normal abundance of an element in
unmineralized earth materials is commonly referred to as background." (Rose,
Hawkes & Webb, 1979, p. 30). Baseline in environmental studies has routinely
been used to define a starting criterion, or yardstick, against which subsequent
data are to be compared. Baseline has been used in this sense for many
decades. In mining-related studies, the most common "baseline" is either pre-
mining or preoperational conditions.
22
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The DSEIS foils to clearly and adequately describe the detailed methods
employed for collecting water quality and water quantity data, for both
surface and ground waters.
76. Because the specific sampling and handling procedures can drastically
change the results obtained when collecting water quality samples {both surface
and ground water), I is imperative that the DSEIS include detailed descriptions of
the various sampling, sample handling, preservation and shipment methods
employed. Likewise, the DSEIS contains inadequate detail concerning the
specific methods employed in collecting field water quality measurements and
measurements of well yield, stream flow, etc.
77. For example, such details should provide information similar to those
contained in the U.S.G.S. methods documents cited below:
[USGS] United States Geological Survey, variously dated, National field manual
for the collection of water-quality data: U.S. Geological Survey Techniques of
Water-Resources Investigations, book 9, chaps. A1-A9, available online
at: http://pubs.water.usqs.gov/twri9A,
Surface Water Quality Baseline Data: The DSEIS fails to adequately
characterize these resources, or to include statistically- reliable summaries
of detailed surface water data.
78. Tables 3.5-1 and 3.5-2 (p.3-25-26) present totally incomplete and
inadequate summaries of surface water quality. Most hydrogeologically-important
chemical constituents are missing from these tables and they contain no
indication of whether samples were field-filtered, or if the data are Total
concentrations, (unfiltered samples).
79. The DSEIS contains no substantive discussion of the interactions between
ground and surface waters, especially when the hydrogeologic system would be
under pumping stress—as would be expected during the operating life of the D-B
project. The DSEIS contains no detailed analysis or discussion of potential
impacts to site surface waters due to ground water pumping, or potential spills
and permitted discharges to surface waters. All such operations generate short-
term impacts to surface waters, as a minimum.
80. The DSEIS no longer contains the questionable statements included in the
2009 application at ER pg. 4-16, which state: "Most ISL operations extract slightly
more groundwater than they re-inject into the uranium bearing formation. The
groundwater extracted from the formation could result in a depletion of
flow In nearby streams and springs if the ore-bearing aquifer is
hydraulically connected to such features. However, because most, if not all
ISL operations are expected to occur where the ore- bearing aquifers are
23
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confined, local depletion of streams and springs is unlikely, and potential impacts
would be anticipated to be SMALL (NUREG-1910, 2008).' However, the DSEIS
provides no detailed technical analysis to support the contention that surface
waters will not be impacted because water-bearing units having confined aquifer
conditions underlie much of the D-B site,
81. More importantly, the DSEIS and Application fail to provide a summarized,
statistically-reliable surface water quality baseline database. As such, there will
be no defensible method for verifying whether impacts to surface water quality
have or have not occurred.
A Baseline Spring and Seep Survey is not presented in the DSEIS.
82. Disingenuously the DSEIS states that: "There are no known natural
springs within the proposed Dewey-Burdock ISR Project area (Powertech,
2011). There is one area in the southwest comer of the Burdock area, known as
the "alkali flats" or the "alkali area,' where groundwater is discharging to the
ground surface from the Fall River aquifer and Chilson aquifer (Chilson Member
of the Lakota Formation) through improperly plugged exploratory boreholes
{Powertech, 2011). Two springs are present along the Dewey Fault near the
town of Dewey approximately 2 km [1.2 mi] northwest of the proposed project
boundary (DSEIS p. 3-23)."
83. The DSEIS presents no information to indicate that either the NRC or
Powertech have conducted an actual spring and seep survey. Such a survey
would have included and characterized the springs along the Dewey Fault, and
any others located within the D-B area and a reasonable perimeter, which should
be at least 2-miles from the project boundary—given the results of the short-term
pump test data in the 2009 Application.
84. The region surrounding the D-B project contains numerous springs in both
the Madison and Minnelusa formations (DEIS p.3-32; Driscoll. et al„ 2002).
Baseline surveys of springs and seeps are crucial in studies where large volumes
of ground water are to be extracted. The flows of such seeps and springs often
decline or stop after large-scale, long-term ground water extraction begins,
especially in arid or semi-arid regions, such as the D-B area. If such impacts
begin to occur, disputes will arise as to the possible rotes of the project water
extraction and overall climate change, for example. Hence, it is imperative that
such a survey be performed prior to issuance of any licenses, and such a survey
should include, as a minimum:
-locate and survey all springs and seeps within some reasonable radius of the
project boundary;
-measure and record flow I discharge quarterly for at least one year prior to
issuance of any licenses;
-during all field episodes, make field measurements of in-situ pH, water
temperature,
24
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and S.C.(specific conductance) arid collect samples for laboratory analysis.
Samples should be analyzed for the same list of constituents noted in the
Baseline water Quality comments above. Spring and seep water quality data
should be interpreted as representative of local ground water quality (Freeze and
Cherry, 1979; Hem, 1985).
The presence of high quality ground waters within the D-B Project
boundary have not been adequately defined.
85. Much of the DSEIS discussion concerning ground water quality seems
focused on showing that the site waters are already contaminated. This would
not be surprising given the presence of the uranium mineralization and the past
mining and exploration activities—all of which would have caused increased
concentrations of numerous chemical constituents above true pre-mining
baseline. However, based on statements and data presented in the DSEIS,
Powertech has not adequately defined whether zones peripheral to the D-B ore-
bearing geologic formations and bounding formations (above and below) also
contain zones of high-quality, possibly potable ground water. Such zones should
already have been defined as part of the DSEIS and Application documents.
Potential impacts to ground waters have been unrealisticaliy minimized
and inadequately characterized.
86. The DSEIS fails to provide adequate baseline data to demonstrate that
portions of the ore-bearing zones do not contain high quality ground water. In
fact, it is clear that the NRC has relied on Powertech data that clearly are biased
against revealing the extent of high quality ground waters. For example, Table
3.5-4 indudes only water quality concentrations that exceed the MCLs (maximum
contaminant levels), and discards all data having lower concentrations (p. 3-38).
The discussion on p. 3-37 also is clearly intended to convey the message that
most of the D-B area waters are already contaminated. A similar bias is
presented in the DSEIS discussions of D-B area surface water quality (p.3-23,
25, 26, 27).
87. The DSEIS continues the unbalanced discussion of contaminated
"baseline" that was presented in the 2009 Application. The ER (pg. 4-18) states
that all D-B ore zone ground water quality is degraded by natural mineralization
processes, but there are no data provided to support this allegation and in many
similar situations it is simply not true. Furthermore, many ground water- bearing
zones in mineralized areas do not contain elevated concentrations of metals,
non- metals, etc. until they have been exposed to air and bacteria—often as the
result of previous mining or exploration drilling—as has occurred here. Even
following exploration and mining activities, some portions of ore-bearing
formations continue to contain high-quality ground water.
25
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88. Hence, it is not defensible for NRG and Powertech to state, as the
company does in ER Sect. 4.6,2.2 (Potential Impacts of Production on Ore Zone
Groundwater Quality) that: "Potential environmental impacts to groundwater are
changes to water quality in well fields within the exempted aquifer. The impact, in
and of itself, is of limited significance, due to the fact fiat the groundwater quality
is very poor prior to 1SL operations; due to the presence naturally, occurring
radionuclides, heavy metals, and other constituents that exceed EPA and/or
state drinking water limits. Accordingly, the exempted aquifer is not and can-
never serve as a USDW (HRI, 1997; NMA, 2007)." The citations provided he,re
by Powertech do not pertain to the specific D-B situation and one, the NMA
citation, is simply a routine public relations statement made by the industry's
lobbying group. The DSEIS inadequately addresses these issues.
89. The public relations statements continue on ER, pg 4-18, where they
state; "Powertech (USA) has proposed to use gaseous oxygen and carbon
dioxide lixiviant. The interaction of the lixiviant with the mineral constituents of the
exempted ore zone results in a slight increase in trace elements and primary
constituents of sulfate, chloride, cations and TDS above pre production levels.
There is no introduction of non-naturally occurring constituents from the leach
fluids into the ore body."
90. To support these unsubstantiated statements, Powertech needs to supply
actual, detailed chemical analyses of the pregnant leach solutions (multiple
analyses)-so!utions resulting from the chemical interaction of the proposed
lixiviant and the ore zone rocks. It is a basic purpose of an ISL operation to
introduce these lixiviants to drastically change the local ground water chemistry,
routinely producing significantly-elevated concentrations of many major and trace
metals and metalloids, plus other constituents: i.e. arsenic, antimony,
molybdenum, selenium, vanadium, uranium, strontium, iron, manganese, lead,
lithium, nickel, chromium, sulfate, chloride, etc. It is a total "red-herring" to claim
that: There is no introduction of non- naturally occurring constituents "
91. In addition, there is ample evidence in the technical and regulatory
literature to show that the leached aquifers at most, if not all ISL operations, have
never truly been restored to their pre-operational, baseline water quality.
Ground Water Monitoring Methods are inadequate to Reliably Define Past
or Future Impacts. Domestic and Stock Wells.
92. DSEIS p.7-13 and 14 (Project-wide GW monitoring), states that all
domestic and stock wells within 2km (1.2 mi.) of the project area will be sampled
quarterly for a year to establish baseline water quality after operations begin
[based on NRC, 1980, Regulatory Guide 4.14], "All the preoperational
groundwater samples will be analyzed for the constituents listed in Table 7.3-1."
93. The stated approach presents several serious flaws:
26
#
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- if the samples are collected after operations begin, they cannot be considered
true baseline;
- the list of constituents to be monitored is inadequate;
- The NRC Guidance Document cited is inappropriate: it refers only to uranium
mills, not ISL operations, and deals only with radiological effluent,
- This Guidance Document does not define the radius to which domestic and
stock, etc. wells should be monitored, for any type of uranium operation-ISL or
mill. The authors have incorrectly applied the 2-Km distance as the Guidance
speaks only with regard to tailings impoundments at conventional mills (section
2.13; p. 4.14-4).
- sampling of these welis during operations is proposed to be done once per
year, which is totally inadequate to note changes in water quality or water level.
94. The definition of the area containing domestic and stock wells to be
monitored needs to be expanded and defined more precisely. Because the
DSEIS fails to show that Powertech has ever performed a detailed well inventory
of all wells outside the proposed DB boundary, such an inventory is needed to
evaluate present and future impacts as part of any acceptable EIS. A preliminary
inventory should investigate and summarize the characteristics of all wells within
at least 2 miles of the DB boundary. The inventory should plot the locations of all
such wells on appropriate maps and summarize their uses; date drilled;
completion characteristics, including depths; well yields; availability of water
quality data. Once such an inventory is completed, all of these wells should be
monitored for detailed water quality and water levels quarterly for a year, with all
data summarized in a revised EIS.
Baseline Water Quality Within Proposed Operation Areas.
95. The DSEIS states (p. 7-8) that selected wells completed within the
mineralized zones will be used to evaluate "baseline" water quality and they will
then be converted into injection or production wells. Clearly the water quality in
many of these zones is no longer true baseline due to all of the historical drilling /
mining in many of these areas. These activities would have altered the original
geochemical and bacteriological conditions, leading to significant changes in the
water quality. In addition, if the "baseline" welis are converted to injection or
production uses, these wells must be maintained, post-closure, to allow for long-
term monitoring to evaluate the success or failure of aquifer restoration.
Land application Is not an approved method of radioactive liquid waste
disposal.
96. The DSEIS proposes that various liquid wastes may be disposed via land
application. However, US EPA (2008) guidance states that land application is not
an approved method for disposal of such wastes. Equally importantly, the DSEIS
has failed to supply detailed chemical analyses of these proposed wastes (see
discussion below) to clarify the chemical nature of the materials being disposed.
27
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97. Such detailed chemical composition data should be included in the DSEIS
available for public comment and technical review prior to FEIS and license
approval.
98. It is ironic that the Supplement to the 2009 Application erroneously states
on pg. 4-7 that irrigation pivots have been used to dispose of non-hazardous
wastes via surface application" with no deleterious effect on the environment" at
Hobson, Mount Lucas, and Highland. In 2008, the operators of the Highland and
Smith ISL mines in Wyoming were forced into a settlement agreement with the
WY Dept. of Environ. Quality, because land application of liquid wastes
containing elevated concentrations of selenium had contaminated soils. Part of
the settlement agreement required the operators of Highland to immediately pay
$8 million to accelerate reclamation activities and to increase their financial
assurance bonds for these two sites to $80 million (WY DEQ, 2008).
Furthermore, Faillace and others (1997) report that release of such waters will
contaminate the soil at the land application areas. Radionuclides adsorbed by the
soil will become a source term for radioactive release through wind erosion
processes.
Deep Well Injection of Liquid Wastes. The DSEIS fails to provide necessary
details on the chemical composition of the wastes and water treatment
specifics.
99. At present, the public has not been told what specific measures will be
used to dispose of D-B liquid wastes. One option mentioned is to dispose of such
wastes via deep wells completed into the Minnelusa and / or Deadwood
Formations (DSEIS p. 2-22). However, the public has no idea of the detailed
chemical compositions of these liquid wastes. Detailed chemical analyses of
these liquids should have been included In the DSEIS, including, as a minimum,
all chemical constituents for which any category of environmental standard or
criterion exists. These should include determinations of S C., TDS, pH, all
commonly-reported inorganics, trace elements, radiochemicals, and a detailed
organic-constituent scan Such data should be provided in the EIS for both
treated and untreated liquid wastes.
100. While both the Minnelusa and Deadwood Formations are deep below the
land surface, it is quite short-sighted to assume that these waters, once
contaminated by the process wastes, could never generate negative impacts—
especially if one considers the cumulative impact of the other industrial wastes
that are or will be injected into these formations, long-term. Long-term scenarios
should consider timeframes of at least 100s to 1000s of years in the future, when
these deep waters may be required for other foreseeable domestic, agricultural,
or industrial uses, and the economics of water are likely to be quite different than
has been assumed in the GEIS (DSEIS p. 5-31). Thus, detailed water quality
28
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analyses should be performed on these deep aquifer waters, both pre-injection
and at various periods after injection is initiated.
The technical and regulatory literature amply documents the numerous
failures to restore aquifer water quality at other ISL sites. Thus, it is
reasonable to assume that portions of the D-B ground water surrounding
the leached zones mil have degraded water quality and may be unit for
future uses.
101. GEIS Section 2.5 described aquifer restoration activities within wellfeWs
that ensure water qualify n surrounding aquifers would not be adversely affected
by the uranium recovery operations (DSEIS p. 2-35; NRC, 2009a). However,
neither the DSEIS or the GEIS contain detailed discussions to demonstrate that
the population of other in-situ operations have been able to do so Indeed, the
historical reality from other operating or closed ISL sites demonstrates an inability
to restore to preoperational or baseline WQ conditions for all constituents.
(Otton, 2009; Hall, 2009).
The public has no detailed information concerning the specific aquifer
restoration standards I criteria that will actually be employed. The DSEIS
presents no such specific aquifer clean-up standards / criteria.
102. Because the DSEIS does not contain actual base tine data for D-B water
resources, the DSEIS does not contain any such specific aquifer restoration
standards / criteria. Instead, the DSEIS has the following convoluted,
bureaucratic language (p.2-35):
"The primary goal of aquifer restoration is to return groundwater quality within the
production zone of welifields to the preoperational water quality conditions or to
standards consistent with NRC requirements at 10 CFR Part 40, Appendix A,
Criterion 5B<5) (Powertech, 2009b, 2011)."
103. The subsequent language makes clear to the reader that the public will
not be told what the specific aquifer clean-up criteria will be until long after
aquifer restoration has begun, and that the criteria are totally flexible.
"10 CFR Part 40, Appendix A, Criterion 5B(5) requires that groundwater quality in
the exempted ore-bearing aquifer be restored to (i) a Commission-approved
background (CAB) concentration; (ii) the maximum contaminant levels (MCLs)
listed in 10 CFR Part 40, Appendix A, Table 5C, for constituents listed in Table
5C and if the background level of the constituents fall below the listed value, or
(iii) an alternate concentration limit (ACL) established by the Commission, if the
constituent background level and the values listed in Table 5C are not
reasonably achievable. The ACL development is described in SEIS Appendix B.
These groundwater quality standards would be implemented, as part of the
aquifer restoration phase, to ensure public health and safety."
29
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Target Restoration Goals and UCL Parameters and standards should all be
selected by the NRG and presented publicly in the EIS, prior to license
approval.
104. The DSEIS uses unnecessarily convoluted and inconsistent terms to
describe aquifer restoration standards I criteria. Various parts of the DSEIS use
the following terms (DSEIS p, 2-35):
Commission-approved background (CAB)
Maximum contaminant levels (MCLs)
Alternate concentration limit (ACL)
target restoration goals
lixiviant migration indicators (DSEIS p. 7-11)
105. It is impossible to discern whether or not the target restoration goals are
the same as lixiviant migration indicators.
106. DSEIS p. 7-11 states: "The constituents and parameters selected as
lixiviant migration indicators and for which UCLs will be set at the proposed
Dewey-Burdock ISR Project are chloride, conductivity, and total alkalinity
(Powertech, 2011)."
107. The 2009 Powertech Application Supplement, pg. 5-6, Sect. 5.2.7, states:
"Powertech management has always used Chlorides, Sulfate, and Uranium as
Upper Control Limit (UCL) Parameters. Sometimes Total dissolved Solids is
used." This statement fails to provide necessary clarity, as Powertech has never
operated an ISL mine.
108. The descriptions of proposed water quality monitoring (surface and ground
waters) on pages DSEIS 7-4 through 7-15 are unclear and unnecessarily
convoluted. Instead of the pages of unclear wording presented here, these
details should have been summarized using tables to show: the specific sites I
wells to be sampled; specific constituents & parameters; sampling frequency,
reporting protocol and frequency.
109. The procedures describing how UCLs will be determined are inconsistent
(p. 7-11, L 24-38). The UCLs named in the 2009 Application supplement and the
DSEIS (2012) are different. How could the procedures used in both cases
comply with NUREG-1569 (NRC 2003)? Furthermore, setting the UCLs at the
mean concentration plus 5 standard deviations is excessively lax. It would be
much more meaningful to present means plus the 95 percent confidence
intervals.
110. Apparently only water level and UCL data (chloride, conductivity, and total
alkalinity) will be reported to EPA, and only quarterly (DSEIS p. 7-11). Such
reporting is totally inadequate in both frequency and constituents. In essence it
30
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prevents the public and the EPA from understanding what is happening at the
site.
111. The NRC has considerable experience with numerous operating and
closed ISL f ISR operations. Clearly NRC, not the operator, should select the
appropriate "target restoration goals". Yet, the DSEIS p. 2-35, L 37-38, states;
The applicant would establish target restoration goals [CAB concentrations
per.......J." Selection of such target restoration goals and UCL parameters and
standards should be done by the regulatory agency in the DSEIS to avoid
possible conflicts of interest and reveal these foreseeable impacts at the earliest
possible stages of project analysis.
112. Such specific restoration goals and standards should be presented in the
DSEIS for public review and comment prior to FEIS or license approval.
The SDEIS does not clearly define the various zones that are contemplated
to contain, monitor, and control migration of lixiviant-mobiIized
groundwater and chemical constituents.
113. D-B Application Supplement, pg. 5-5 describes an aquifer exemption
boundary, which acts as an additional buffer zone outside the monitor well rings
"to provide protection to adjacent water from the excursions that occur in
the normal course of operations." Page 5-6 of the Supplement further states
that the aquifer exemption boundary is proposed to be up to 1200 ft. outside the
monitor well ring, and would be considered the point of regulatory
compliance. Apparently simply pumping to create an inward flow direction
is not adequate to control "excursions." It appears this aquifer exemption
boundary is actually an expanded ground water sacrifice zone.
Mitigation is Not Detailed In a Manner That Allows Any Meaningful Review
114. The DSEIS portrays mitigation to account for impacts, but the mitigation
consists only of proposals to make plans to restore groundwater in the future.
There is no detail as to the effectiveness of these proposed mitigation measures,
nor any analysis of whether any such plans have succeeded in the past.
115. The DSEIS provides for monitoring of restored groundwater aquifers for
only 12 months. DSEIS, P. 2-37. However, there is no assessment as to
whether 12 months is adequate. Aquifer restoration activities at numerous other
ISL sites have failed to return aquifer water quality to baseline conditions
following years of attempts at clean-up. Hence, at minimum, the NRC should
conduct these effectiveness reviews and require that post-operational monitoring
of D-B aquifer water quality continue until baseline conditions are attained.
31
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Financial Assurance
116. DSEIS, p. 2-35 states that: "The applicant would also be required to
provide financial sureties to cover the costs of both planned and delayed
restoration programs, in accordance with 10 CFR Part 40, Appendix A, Criterion
9. NRC reviews financial sureties annually." Although a final decision on surety
amounts will come at a later date, the revelation and analysis of the likely amount
of surety must be revealed and analyzed in the DSEIS.
117. The NRC and the public know several general facts about the usefulness
of most company-generated financial assurance estimates:
1-They generally are based on overly-optimistic assumptions about future water
quality, thereby under-estimating costs. Kuipers (2000) conducted a survey of
bonding practices at metal mines throughout the western U.S. and found that the
bond amounts available were hundreds of millions of dollars below that
necessary to conduct actual clean-ups. Many of the "problem" sites have been
foreign-owned entities, especially those with their corporate headquarters and
assets based in Canada.
2-Aquifer restoration at most, if not all previously-licensed and operated ISL sites
has failed to actually return ground water quality to baseline conditions [Hall
(2009); Otton and Hall (2009);
3-Predictions of future aquifer restoration success made by the project
proponents seldom use truly conservative assumptions. Calculation of financial
assurance amounts made by representatives of the party that stands to profit
from project licensing represents an extreme conflict of interest.
4-The technical literature is filled with documentation that quantitative predictions
of future water quality at specific sites cannot be done reliably [Sarewitz, et. al.
(2000); Moran (2000); Pilkey & Pilkey-Jarvis(2007); Kuipers & Maest (2006)}, and
the general failure to restore aquifers back to pre-operational baseline
concentrations supports this. This approach must be totally rejected because it
assumes one can make accurate and precise deterministic predictions.
118. For these reasons, at least preliminary financial assurance calculations
should be included in the DSEIS, preferably made by some independent party,
not paid or directed by the project proponents. These calculations should also
consider the actual reclamation and restoration costs incurred, long-term, from a
statistical sampling of the previously-licensed ISL sites. Furthermore, these
financial assurance amounts and mechanisms should be made public prior to
award of any licenses.
119. To ensure protection of the general public, such financial assurance
agreements (bonds, etc.) should be made with the parent corporation, not simply
the local operating entity.
32
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Pursuant to 10 C.R.F. § 2.304(d) and 28 U.S.C. § 1746,1 dadare under
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Signed on the 24#l day of January, 2013,
Robert E. Moran, PhD. '
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CLIENT#:
DOCTOR:
Toxic & Essential Elements; Hair
RESULT
im/n
REFERENCE
INTERVAL
PERCENTILE ^
68® §5®
Aluminum
(All
4.6
< 7.0
mmm—mm
Antimony
(Sb)
0.019
< 0.050
Arsenic
(As)
0.058
< 0.060
Barium
{Bai
2,1
< 2.0
Beryllium
(Be)
<0.01
< 0.020
Bismuth
(Bii
0.011
< 2.0
»
Cadmium
tCd)
< 0.009
< 0.050
Lead
iPb)
0.59
< 0.60
Mercurv
(Hal
0.12
« 0.80
mm
Platinum
(Ptt
< 0.003
< 0.005
Thallium
nrn
0.003
< 0.002
Thorium
(Th)
0.002
< 0.002
Uranium
cui
0.20
< 0.060
Nickel
(Nii
0.13
< 0,30
piSmm
Silver
iAa)
0.48
0.15
Tin
{Sn!
0.18
< 0.30
¦MM*
Titanium
(Ti>
0.38
< 0.70
¦MM
{Total Toxic Raorasantation
ESSENTIAL AND OTHER ELEMENTS
!
RESULT
ufl/g
REFERENCE
mnu
2.5*" 16"' | 50 1 M* IM*
Calcium
(Cal
1250
30®- 1200
^mmmm
Maqnesium
(Ma)
79
35- 120
Sodium
Ma\
26
20- 250
Potassium
(K)
11
8- 75
mtmrnm
CoDoer
(Cu)
3?
11 "»"f
•JL JL *5 /
mmmmmm
Zinc
(Zn)
1S0
140- 220
mmmmm
Manganese
(Mn)
0.30
0.08- 0.60
mm
Chromium
(Cri
ll 1*
0.40- 0.65
Vanadium
m
0.31
0.018- 0.065
Molybdenum
(Mo)
0.081
0.020- 0.050
Boron
999
1 > 800
Shampoo:
©DOCTOR'S OATA. IMC, • ADORESS: 3755 HHnolt Avwiue, St. Chartoa, (t«017«420 • CUA10 NO: 1400S46470 • LAB MR; Erto Roth, MO
-------
South Dakota Codified Laws
Page I of 1
46 A -1-8, Resolution of conflicting interests. The objectives and purposes to be
sewed by the Board of Water and Natural Resources shall 'be to resolve conflicting
special interests of federal, slate, and local agencies or entities or private interests in
proposed water projects, Including federal projects and the designation and preservation
of certain rivers or portions thereof as scenic rivers so that the public interest in such
project proposals will be protected and enhanced, optimum over-all benefits will accrue
to the people of South Dakota, and maximum consideration of all needs and desires in
such water projects will be ensured, especially in those involving multiple purposes such
as combinations of irrigation, flood control, navigation, electric power, domestic and
stock water, municipal and industrial water supplies, lake stabilization, pollution control,
water quality enhancement, fish and wildlife, recreation, groundwater recharge, erosion
control, or other beneficial purposes and uses,
S#tiree; SL 1972,ch24l, § 14; SDCL Supp, § 46-17A-13.
This page is maintained by the Legislative Research Council. It contains material authorized for
publication that is copyrighted by the state of South Dakota. Except as authorized by federal copyright
law, no person may print or distribute copyrighted material without the express authorization of the
South Dakota Code Commission.
frf \4-Wcl,
i!I"f
I
r
http://legis.state.sd. us/statutes/DisplayStatute.aspx7rype=Statute&Statute=46A-1 -I
7/15/200?
-------
A Summary of the 1851 and 1868 Treaty Issue in South Dakota
The Great Sioux Nation, which is composed of the Lakota, Dakota, and
Nakota speaking people, once resided in a vast land area in the central part of the
United States covering what is now 14 states and 3 Canadian Provinces. One of the
Lakota origin stories says that the people of the Great Sioux Nation came onto the
Earth from the mouth of Wind Cave in the-Black Hills, The Black Hills were so
sacred that they were used for ceremonial, medicinal, and funeral purposes only.
The encroachment of the European-Americans, and the subsequent
devastation of tfye buffalo, caused the people of the Great Sioux Nation to wage war
upon the United States. When the US realized that they could not win the war, they
asked the Great Sioux Nation for a treaty for peace. The Great Sioux Nation agreed
in 1851, and again in 1868, to treaties for peace at the request of the US, both times
relinquishing large tracts of land but always keeping the sacred Black Hills intact
within their care. The people of the Great Sioux Nation had resided in this area for
over 11,000 years.
On March 3rd, 1871, the US Congress passed a law which said that treaties
made prior to that date would not be abolished. It also said that no new treaties
would be made in the future with Indian nations. From that date to this, since the
Fort. Laramie Treaty of 1868 was made prior to March 3, 1871, any laws passed by
the United States are applicable only to the people of the United States, but not to
the people of the Great Sioux Nation. To try to enforce any American law that
violates the Fort Laramie Treaties of 1851 and 1868 would also be a violation of the
March 3rd Act of 1871. Furthermore, to violate any treaty would also be a violation
of the US Constitution which states that "treaties are the supreme law of the land."
The land area that is stipulated in, the Fort Laramie Treaties of 1851 and 1868
includes all of western South Dakota from the East bank of the Missouri River to
the summits of the Big Horn Mountains. This also includes all of the Black Hills and
is the actual, legal, land base of the Great Sioux Nation. A larger land area
surrounds this central base and is reserved for the exclusive use of the people of the
Great Sioux Nation. This reserved area includes portions of Nebraska, Colorado,
Wyoming, Montana, and North Dakota.
William Allen White, a newspaper publisher, once said, "Peace without
justice is tyranny." Upholding the 1868 Fort Laramie Peace Treaty would be
upholding justice as well as the Constitution of the United States.
-------
1851-1868 TREATY
last and 1SG8
Unceded land
Reserved For
Ranting
Use
1811 Treaty land
Settlement
-------
©©©~©<«©~©#©~©© @©9
©©
Good afternoon:
My name is I have lived in Edgemont for the
past 33 years. I teach high school math here in town, Prior to
doing that, I received a Mining Engineering degree from the
South Dakota School of Mines and Technology,
I am here today to publically say that I am in favor of the
proposed uranium mining project. I trust the science presented
and the experience and expertise of those individuals that
conducted the studies put before us.
Science:
• Doesn't involve emotions - it involves facts
• Doesn't take sides
• Doesn't care about the economy - one way or the other
• Can be proven - and it proves this to be a safe
proposition.
I ask you to read the facts and only the facts. When you isolate
yourself from all the false information, speculation, and rumors,
you can clearly see the facts in front of you will prove this is a
safe project for humans, plants, and animals.
I have known Mark and Suzanne Hollenbeck for over 30 years.
I know that they would never risk the health of their children,
the ranch on which they live, the ground water, or their future.
Nor would they risk any of ours. I firmly believe the science is
sound - please trust it, as I do.
Thank you
-------
Kay iO
The Proposed In-situ Uranium mining project in west
South Dakota;
Cost - Benefit Analysis:
Cost;
Thousands of gallons of water from aquifers in a drought
prone area.
Benefit;
1. Lots of money to companies, Canadian, Chinese and in
the future, likely others.
2. A few local jobs.
Result: The benefits are not worth the
extensive costs.
In the past companies have simply gone bankrupt and
disappeared...
How much are the bonds the company is paying to
guarantee the decontamination & desalination of the
waste water?
• EPA stands for Environmental Protection Agency;
• You need to do what we taxpayers pay you to do;
Protect our Water from this
contamination!! _ _
¦nfcsk
-------
U.S. EPA, Region 8
1595 Wynkoop Street
Denver, CO 80202-1129
WHAT IS AZARGA/POWERTECH?
Azarga Resources Limited, is a Canada-based, China-led company that has never mined uranium. After
owning part of Powertech since 2013, it is now merged with Powertech to form a new company named
Azarga Uranium. The new ownership controls Powertech's operations in South Dakota, as well as
uranium interests in Colorado.
Azarga's largest stockholder is Platinum Partners, a hedge fund that is based in the Cayman Islands.
Seven members of Platinum Partner's leadership team, including its founder, Mark Nordlicht, have been
charged in federal court in New York for a Si billion fraud and for running what the media has called a
"ponzi scheme." This makes the status of Azarga uncertain.
The former investment banker who heads Azarga Resources is Alexander Molyneux, who was born in
Australia. Molyneux left investment banking and entered the mining industry with the help of Robert
Friedland, a dual citizen of the United States and Canada who lives in Singapore. Friedland is known by
some as 'Toxic Bob," partly for his role in the disaster at the Summitville gold-silver mine in Colorado.
The Summitville mine was run by a subsidiary of Friedland's company, Galactic Resources. It is now a
Superfund site that discharged acid drainage and cyanide, arsenic, cadmium, copper, lead, mercury, and
other heavy metals into the Alamosa River. Friedland's bankrupt subsidiary pled guilty to 40 felony
counts. Cleanup, which is expected to cost $150 million, is ongoing.
Molyneux's mining experience began with his stint as CEO of SouthGobi Energy Resources, a coal
mining operation in Mongolia. The company was controlled by a firm founded by Friedland. Molyneux
was fired from this position after the company racked up millions of dollars in operating losses and he
apparently alienated the Mongolian government. A market observer summarized the situation: 'The
SouthGobi thing was a mess, with restated financials for two years, an abortive takeout by a China
company, Rio Tinto's giving Mr. Molyneux his walking papers, and Ontario-groomed class-action
lawsuits." (The Calandra Report)
Whether Azarga intends to actually mine uranium in the Black Hills remains to be seen. It is also
possible that the company hopes to make a profit by getting mining permits, then selling the proposed
mine site to someone else, or they might get permission to create deep disposal wells and start taking in
other mines' wastes.
In addition, Azarga/POwertech statements have faced scrutiny by the British Columbia Securities
Commission. Canadian regulators consider Azarga's preliminary assessments "too speculative
geologically." Azarga acknowledged certain "deficiencies" in its filings relating to the Dewey-Burdock
project. There should be NO deficiencies where OUR WATER is concerned. Regardless of who owns
uranium properties in the Black Hills, I oppose uranium mining in the area.
-------
(9i n
U.S. EPA, Region S
Denver, CO
According to a June 15,2015 Washington Post article, new NASA satellite data indicates that fresh
water aquifers are being depleted at alarming rates. Much of this depletion is the result of various kinds
of mining. They all use water-intensive processes.
Powertechjf proposed mining activities include lb» pumping 9,000 gallons of water per minute from
area aquifers, including the lnyan Kara, This demand on the Inyan Kara, aquifer competes with other
local uses, reducing the water level while at the same time putting it at risk of contamination.
Powertech has also requested permits for a number of extra wastewater wells in the Minnelusa aquifer.
The risk of contamination of this water source from this waste is obvious, but the danger is greater than
that. The Minnelusa communicates with neighboring water sources through naturally occurring breaks in
the structure of the rock. One of these nearby aquifers is the Madison, the major source of Rapid City's
drinking water. ^
Powertechjspeaks with scientific certainty about the\safety ofjts technology. Other mining companies
have mm the same. Then the unanticipated happens.j^Water%S^x)lIuted, gomttiflias without remediation.
There is no perfect understanding of underground geology, no mining technology that can anticipate and
prevent every possible problem, and no effective methodology for cleaning up a toxic mess deep in the
ground. So why risk the inevitable failure with our precious water?
But if the danger of poisoning our water doesn't stir you, then why allow the more obvious and certain
outcome of Powertech's project? I am speaking of allowing affcompany seeking only its own profit^to
qfateiraso much of a public good,even as that good, our precious water, is steadily dwindling away as we
meet here today? Please deny Powertech's permits for the good of our community.
May 8-9,2017
-------
New NASA data show how the world is running out of water
By Todd C. Frankel June 16, 2015 The Washington Post
More than hall of Earth's 37 largest aquifers are being depleted, according to
gravitational data from the GRACE satellite system.
The world's largest underground aquifers - a source of fresh water for hundreds of millions of people
— are being depleted at alarming rates, according to new NASA satellite data that provides the most
detailed picture yet of vital water reserves hidden under the Earth's surface.
Twenty-one of the world's 37 largest aquifers — in locations from India and China to 'the United States
and France — have passed their sustainability tipping points, meaning more water was removed than,
replaced during the decade-long study period, researchers announced Tuesday. Thirteen aquifers
declined at rates that put them into the most troubled category. The researchers said this indicated a
long-term problem that's likely to worsen as reliance on aquifers grows.
Scientists had long suspected that humans were taxing the world's underground water supply, but the
NASA data was the first detailed assessment to demonstrate that major aquifers were indeed
struggling to keep pace with demands from agriculture, growing populations, and industries such as
mining.
"The situation is quite critical," said Jay Famiglietti, senior water scientist at NASA's Jet Propulsion
Laboratory in California and principal investigator of the University of California Irvine-led studies.
Underground aquifers supply 35 percent of the water used by humans worldwide. Demand is even
greater in times of drought. Rain-starved California is currently tapping aquifers for 60 percent of its
water use as its rivers and above-ground reservoirs dry up, a steep increase from the usual 40 percent.
Some expect water from aquifers will account for virtually every drop of the state's fresh water supply
by year end.
The aquifers under the most stress are in poor, densely populated regions, such as northwest India,
Pakistan and North Africa, where alternatives are limited and water shortages could quickly lead to
instability.
The researchers used NASA's GRACE satellites to take precise measurements of the world's
groundwater aquifers. The satellites detected subtle changes in the Earth's gravitational pull, noting
where the heavier weight of water exerted a greater pull on the orbiting spacecraft. Slight changes in
aquifer water levels were charted over a decade, from 2003 to 2013.
"This has really been our first chance to see how these large reservoirs change over time," said Gordon
Grant, a research hydrologist at Oregon State University, who was not involved in the studies.
But the NASA satellites could not measure the total capacity of the aquifers. The size of these tucked-
away water supplies remains something of a mystery. Still, the satellite data indicated that some
aquifers may be much smaller than previously believed, and most estimates of aquifer reserves have
"uncertainty ranges across orders of magnitude," according to the research.
Aquifers can take thousands of years to fill up and only slowly recharge with water from snowmelt and
rains. Now, as drilling for water has taken off across the globe, the hidden water reservoirs are being
stressed.
-------
"The water table is dropping all over the world," Famiglietti said. "There's not an infinite supply of
water."
The health of the world's aquifers varied widely, mostly dependent on how they were used. In
Australia, for example, the Canning Basin in the country's western end had the third-highest rate of
depletion In the world. But the Great Artesian Basin to the east was among the healthiest.
The difference, the studies found, is likely attributable to heavy gold and iron ore mining and oil and
gas exploration near the Canning Basin. Those are water-intensive activities.
The world's most stressed aquifer — defined as suffering rapid depletion with little or no sign of
recharging — was the Arabian Aquifer, a water source used by more than 60 million people. That was
followed by the Indus Basin in India and Pakistan, then the Murzuk-Djado Basin in Libya and Niger.
California's Central Valley Aquifer was the most troubled in the United States, It is being drained to
irrigate farm fields, where drought has led to an explosion in the number of water wells being drilled.
California only last year passed its first extensive groundwater regulations. But the new law could take
two decades to take full effect.
Also running a negative balance was the Atlantic and Gulf Coastal Plains Aquifer, which stretches
across the southeast coast and Florida. But three other aquifers in the middle of the country appeared
to be in relatively good shape.
Some groundwater filters back down to aquifers, such as with field irrigation. But most of it is lost to
evaporation or ends up being deposited in oceans, making it harder to use. A 2012 study by Japanese
researchers attributed up to 40 percent of the observed sea-level rise in recent decades to
groundwater that had been pumped out, used by humans and ended up in the ocean.
Famiglietti said problems with groundwater are exacerbated by global warming, which has caused the
regions closest to the equator to get drier and more extreme latitudes to experience wetter and heavier
rains. A self-reinforcing cycle begins. People living in mid-range latitudes not only pump more water
from aquifers to contend with drier conditions, but that water — once removed from the ground —
also then evaporates and gets recirculated to areas far north and south.
The studies were published Tuesday in the Water Resources Research journal.
Famiglietti said he hoped the findings would spur discussion and further research into how much
groundwater is left.
"We need to get our heads together on how we manage groundwater," he said, "because we're running
out of it."
-------
ytV\r»
Mar«C2017
RECEIVED MAY 1 5 2017
Dear EPA, Region 8:
Please take into consideration the concerns I have about the proposed Dewey-Burdock Uranium
Mine and Deep Disposal Wells in the Black His, My concerns center on the dangers of cumulative
radiation exposure.
Those who stand to profit from the in situ mining at Dewey Burdock would like us to believe that the
mining risks are minimal and that the contaminated water would be fully contained, even though our
region is full of faults in the rock strata. We often hear the well-worn talking point about how one
glass of this water is still within "acceptable limits". Seriously, who drinks only one glass of water in
their lifetime? It is curious that with all the "expert testimony" about the supposed safety of the mining
techniques and "minimal" contamination to the water, the issue of cumulative radiation exposure
never is mentioned.
The Mayo Clinic and most other major health care organizations in the USA are taking great
measures to minimize the impact of radiation exposure to their patients. This is because they
recognize the fact that the human body accumulates radiation that it is exposed to. This radiation is
not expelled, but stays in the tissues. As the radiation accumulates in the body, so does the risk for
cancer and other diseases. The EPA studies have shown we already have some naturally-occurring
radiation in the environment. It makes no sense to add to those naturally-occurring risks with the
exposure from mining contamination that will inevitably leach into our water supplies.
Have we learned nothing from history? Historically, most mine owners and investors do not live on-
site. When things go bad, they cut and run, leaving the mess for others to suffer from and to clean
up. Few, if any of them would be willing to daily drink the water polluted by their mines. Yet they
expect others to do so, while the owners and investors pocket the profits.
Unless science can come up with a way to safely extract the uranium AND leave the water in as good
(or better) condition than it was before, why would any rational and unbiased person support in situ
uranium mining? Our society at large has little to gain from this, but much to lose. Please do not
allow this uranium mining project to proceed.
Thank you for your attention in this matter.
-------
Injection wells like the one being proposed here have caused many
problems in areas like Oklahoma over the last few years. The United
States Geological Survey data shows that between 1978 and 2008
there were no more than 3 earthquakes per year with a magnitude of
3.0 or greater in Oklahoma. With the proliferation of tracking, the
number of earthquake with a magnitude of 2.0 was 585, 887, and 639
for the years 2014-2016. The impact of these earthquakes is borne by
citizens who suffer property damage and businesses who lose revenue
while they recover.
An exemption to the Safe Drinking Water Act is being sought as part
of this project. Protection of drinking water is necessary and should be
a basic function of a government that is concerned with its citizens'
health and well-being. If the EPA abdicates itself of this responsibility
to the people of South Dakota, those people's health and livelihoods
will be put at risk. It will potentially add to the burden of the
healthcare system and could ultimately results in lawsuits costing the
EAP millions of dollars, for which the US taxpayers will ultimately be
responsible.
-------
Class V wells are for non hazardous waste disposal
What non hazardous material will be injected in these class V wells?
Are there any exploratory wells in the area involved or close by, Are these wells cased,
filled or capped? What is the possibility of these wells becoming avenues for migration
of mining fluid or waste into drinking water aquifers?
The permit requires monitoring. Who will be doing the monitoring?
The permit allows for information to be confidential. Why would there be a need for
confidinetiality at all in regards to these activities and the communal water supply?
The permit is showing that the class V waste wells will be at the 2,800 ft level which is
the same as the depth of the Edgemont drinking water wells. How could this be a good
thing?
Injection wells have created increased earthquakes along fault lines. Is this a possibility
in regards to the class V injection waste wells in the Dewey Burdock area?
My well is in the Minnelusa Aquifer, What is the potential for waste or mining
contamination to my well?
Who will pay the damage if it can be corrected at all?
-------
1 am writing regarding the application for InSitu uranium mining in the Dewy-Burdock
area of Fall River county and Custer County in South Dakota. 1 Have grave concerns
for giving an aquifer exemption for the Minnelusa to deposit waste in Class V deep
injection wells, or Class III wells for fnSitu mining of Uranium. My well is in the
Minnelusa Aquifer and waste with any radioactive or other chemical allowed in the
drinking water on purpose, or by accident would possibly contaminate my well.
While we know a lot about what happens underground we certainly do not know the
extent and variables of the geologic forms below the surface to guarantee how water
moves or will move. Compounding this is the presence of numerous exploratory wells
that have been drilled in the past. These wells have not been filled, cased, or capped.
The Class V wells according to the EPA site are for waste that has been cleaned and
will not contaminate USDW. The problem is monitoring this procedure. The mining
industry cannot be trusted to self monitor and the EPA has not done a good job in the
past. Mistakes and violations once made cannot be remedied.
It has teen discovered that pumping high pressure fluids into faults and cracks in the
rock can and do cause increased earhquake activity and strength. The area in question
is of this nature and has connection with immense cave networks such as Jewel and
Wind Cave.
This area has already suffered at the hands of the Uranium mining industry. These
foreign corporations basically exploited the area and left the clean up to the taxpayers.
The medical and physical harm is sill evident today.
I am asking that this application for Uranium mining and high pressure deep injection
waste wells be denied.
-------
We all used world wide resources that our Earth has provided for her two-legged children for centuries.
Out of her lover for use we are still here today! It is out of that love & nurture, that I pray for your spirits
that have become stagnant which has occurred overtime of ignoring our history. We should utilize our
past to stop burning ourselves in the same fire!
This representing the choices we make to destroy our Grandmother Earth, expecting different results to
make what was once created perfect for us a supposedly "better place."
For our brothers & sisters that have been led astray from their bond with Grandmother Earth by greed,
let them be made aware it is a hunger that shall never be fulfilled! The emotion your spirit yearns for is
the connection every child should have with their mother.
The biggest band wagon to self-destruction is greed! A conception that the more currency you have will
fill the emptiness that only mother earth can make whole. Let your spiritual roots grow, spiritual
connection with Grandmother Earth is true happiness & we will not allow this to happen to our
communities any longer.
Do not mistake our kindness as an Indigenous people as a weakness among a misunderstood nation I
obviously the last protectors of a wisdom that can heal our world. We will not be easily pushed aside
time after time. I stand before our today, not only for the people standing strong behind me, but for
your children you have sold out for what?
Through my humbled spirit instilled within me through my connection with the Earth, I pray persistently
for everyone among us that we may remove the veil from our spiritual consciousness & that our
Grandmother Earth forgive our naive curiosity derived from the discerning spread of greed. The ways of
our Ancestors that flourished contently without depleting our precious resources are either chosen to
be forgotten or stomped on. What is happening now here with the mine is just one of the many events
of a bigger picture that will be an inevitable expression of cause & effect. We will soon no longer exist if
we do nothing! If we fail to compromise the entity that plagues our lands, chaos will spread. Where a
hose men hiding? in their planning rooms? They send out their minions that are programmed with
paper printed with the faces of the people that have deceived all people...For that is the afflicted by any
decisions made by the Government, Mankind?
-------
JAY DAVIS LAW OFFICE
Jeremiah J. Davis, attorney at law
May 22, 201?
Valois Shea
I .S. 1 Environmental Protection Agency: Region 8
Mail Code: 8WP-SUI
1595 Wvnkoop St.
Denver, CO 80202-1129
RE: Dewey-Burdock uranium mining proposal
Dear Ms. Shea:
As a long-time resident of the Black Hills, I am writing to express strong opposition to Powertech-
Azarga's proposed permit for an in situ uranium mining operation in the Dewey-Burdock area north of
Edgemont, South Dakota.
Western South Dakota is a semi-arid region, much of which is Indian Country, whose primary
industries are agriculture (both farming and ranching) and tourism. We depend on our underground
aquifers for domestic use, livestock, wildlife and recreation. Past uranium mining operations have
compromised water quality in Angostura Reservoir, which is a resource for recreation and irrigation,
and also on distant Indian reservations whose residents depend on the Cheyenne River for drinking
water and fishing. Water is truly the life blood of our communities, and South Dakotans know that in
situ uranium mining operations in other states have degraded the water resources that they exploited.
If Powertech-Azarga obtains the uranium mining permits that they are seeking, they may well transfer
this valuable property right to a different corporation. It is a major concern that one facet of the
proposed uranium mining operation is the disposal of in situ uranium mining wastes into underground
aquifers. Radioactive wastes from elsewhere, notably Nebraska and Wyoming, could be disposed of at
the Dewey-Burdock site.
Public testimony in South Dakota has been overwhelmingly opposed to Powertech-Azarga's uranium
mining permit. There is a good reason for this: South Dakotans value their water and other natural
resources. Please respect this overwhelming testimony, from the people who will be directly affected
by this permit, and reject the proposal.
-------
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-------
Valois Shea May 8, 2017
U.S. EPA, Region 8
Mai Code:8WP-SUI
1595 Wynkoop Street
Denver, CO 80202-1129
WHAT IS AZARGA/POWERTECH?
Azarga Resources Limited, Is a Canada-based, China-ted company that has never mined uranium.
After owning part of Powertech since 2013, it is now merged with Powertech to form a new company
named Azarga Uranium. The new ownership controls Powertech "s operations in South Dakota, as well
as uranium interests in Colorado.
Azarga's largest stockholder is Platinum Partners, a hedge fund that is based In tie Cayman Islands.
Seven members of Platinum Partner's leadership team, including its founder, Mark Nordlicht, have
been charged in federal court in New York for a $1 billion fraud and for running what the media has
called a "ponzi scheme." This makes the status of Azarga uncertain.
The former investment banker who heads Azarga Resources is Alexander Molyneux, who was born in
Australia. Molyneux left investment banking and entered the mining industry with the help of Robert
Friedland, a dual citizen of the United States and Canada who lives in Singapore. Friedland is known
by some as Toxic Bob," partly for his rote in the disaster at the Summitville gold-silver mine in
Colorado. The Summitville mine was run by a subsidiary of FrlecHand's company, Galactic Resources. It
is now a Superfund site that discharged acid drainage and cyanide, arsenic, cadmium, copper, lead,
mercury, and other heavy metals into the Alamosa River. Friedland's bankrupt subsidiary pled guilty to
40 tetany counts. Cleanup, which is expected to cost $150 million, is ongoing.
Molyneux's mining experience began with his stint as CEO of SouthGobi Energy Resources, a coal
mining operation in Mongolia. The company was controlled by a firm founded by Friedland. Molyneux
was fired from this position after the company racked up millions of dollars in operating losses and he
apparently alienated the Mongolian government. A market observer summarized the situation: "The
SouthGobi thing was a mess, with restated financial for two years, an abortive takeout by a China
company, Rio Tinto's giving Mr. Molyneux his walking papers, and Ontario-groomed class-action
lawsuits." (The Calandra Report)
Whether Azarga intends to actually mine uranium in the Black Hills remains to be seen. It is also
possible that the company hopes to make a profit by getting mining permits, then selling the proposed
mine site to someone else, or they might get permission to create deep disposal wells and start taking
in wastes from other mines.
In addition, Azarga/Powertech's own statements have faced scrutiny by the British Columbia Securities
Commission. Canadian regulators consider Azarga's preliminary assessments "too speculative
geologically." Azarga acknowledged certain "deficiencies" in its filings relating to the Dewey-Burdock
project.
There should be NO deficiencies where OUR WATER is concerned. Regardless of who owns uranium
is, I oppose uranium mining in the area.
RECEIVED JUN 112017
I
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Shea, Valois
From:
Sent:
To;
Attachments:
Saturday, April 22, 2017 2:09 AM
Shea, Valois
text_1492848510940.txt
1 grew up in Gallup, NM which is surrounded by
reservation and Native American sites. My home was
on w66, west of town. We moved out there in 83 hut
my mom had lived on the property as a young child.
We are not Native but have respect and love for the
different Native cultures. 1 watched Twin Buties, year
by year become a hill of rubble. When 1 see pictures
from the 5()'s and 60s of how beautiful it was 1 am
sad. angry and frustrated. 1 implore you to do the
honorable and environmentally responsible thing and
refuse Hi allow more Native American sites, land that
we all love and need, to be destroyed for capitalism
and greed.1
3? • -Mobile-'
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Shea, Valois
From:
Sent:
To:
Subject:
Monday, March 13, 2017 10:48 PM
Shea, Valois
Opposition to the UIC Permits and Aquifer Exemption
I am writing to submit my resounding opposition to these careless acts of environmental
injustice. Dump uranium into aquifers??? How is this policy even possible with all the water
quality problems in places like Flint, Ml and Hoosick Falls, NY? How do we know if the EPA
will properly monitor the treatment of this highly contaminated water if these misguided
permits are issued when your Administrator has time and again shown that he sides with
business interests first and American Public Health last?
You must withdraw these permits for the sake of residents impacted by the injections and the
slippery slope you will create by even considering such reckless activity.
I urge this agency to reject both activities immediately.
(Denver, Colo. - March 6, 2017) EPA has issued two draft Underground Injection Control
(UIC) Area Permits to Powertech (USA) Inc., for injection activities related to a proposed
uranium recovery project in the southern Black Hills region in Custer and Fall River Counties
of South Dakota. EPA will conduct information sessions combined with public hearings on
April 27th and on May 8 through May 11 at the times and locations detailed below. EPA will
accept public comments on the draft permits and a proposed aquifer exemption associated
with the project through May 19, 2017.
The draft permits issued today include a UIC 'Class III' Area Permit for injection wells for the
in-situ recovery (ISR) of uranium in the Inyan Kara Group aquifers and a UIC 'Class V Area
Permit for deep injection wells that would be used to dispose of ISR process waste fluids into
the Minnelusa Formation below the Inyan Kara after treatment. Under the terms of the draft
permits, waste injected under the Class V permit must be treated prior to being injected and
must meet all radioactive waste and hazardous waste standards. Monitoring of the
underground sources of drinking water surrounding the Class III injection wellfields will take
place before, during and after ISR operations to ensure the underground sources of drinking
water are protected.
EPA is also proposing an aquifer exemption approval in connection with the draft UIC Class
III Area Permit. Specifically, this approval would exempt the uranium-bearing portions of the
Inyan Kara Group aquifers from protection under the Safe Drinking Water Act. Such an
exemption must be in place before ISR activities within these aquifers can occur.
Thank you,
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Shea, Valois
Sent: Thursday, May 11, 2017 8:38 AM
To: Shea, Valois
Subject: Dewey-Burdock Project
Good morning,
I want to start off by saying that I support the mining of uranium in South Dakota. I think nuclear energy
is a smart investment for the future as we begin to move away from fossil fuels. The amount of energy that can
be produced is just too great to look past and it's one of the better options for energy production for the future.
Ieer.org has a fact sheet comparing fossil fuels and nuclear power. Some of the high points include nuclear
power having no incremental climate change while fossil fuels are rated as potentially catastrophic and nuclear
power has relatively low air pollution and fossil fuels have severe tendencies to air pollution.
I also believe that uranium mining could be very good for South Dakota's economy. The mining itself
has potential to create many jobs for the area as well as bring in new people to fill our cities. The Richmond
Times-Dispatch published an article titled "New Uranium Mining Study Assesses Economic, Social Impacts."
In it they state that the uranium mine in Virginia offered 1,000 annual jobs and could bring in $135 million a
year over 35 years. One can't really look at a possible financial boom in a bad light. It can only bring in good
things for the citizens and their home state.
My major concern with the permits being issued is that Powertech is going to be responsible for their
own monitoring of the underground drinking water. This to me seems a bit outlandish. What about checks and
balances? It seems that if anything were to go south with this project this would be this instance. Who will hold
them accountable? I appreciate that the EPA is going to be holding this company to specific standards for their
waste and the surrounding source water. I think it's a good idea that they will be testing the water before,
during, and after the project. But I think a third party with no financial ties to the project or company should be
in charge of these regulations. Corruption and cover ups are too common in situations like these and the people
that pay for it are the local citizens.
I would feel much more on board with this project if some of these concerning issues were taken care of.
Projects like these are a tricky situation on all sides and everyone wants to be happy with the end results. I think
many people would feel more inclined to support this if the idea of corruption wasn't looming over their heads.
Thank you for your time,
References:
http://www.ieer.org/ensec/no-l/comffnp.html
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http://www.richmond.com/news/article c5e6f300-59f4-5566-aleb-ea56e4144556.html
2
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Shea, Valois
From:
Sent:
To:
Subject:
Friday, May 12, 2017 8:49 AM
Shea, Valois
Approve Dewey-Burdock Permits
Valois Shea (shea.valois@epa.gov)
Fax: 303-312-6741
U.S. EPA Region 8
Mail Code: 8WP-SUI
1595 Wynkoop Street
Denver, Colorado 80202-1129
May 10, 2017
RE: Dewey-Burdock Public Comment
Dear Ms. Shea:
The U.S. Environmental Protection Agency (EPA) Region 8 is requesting public comment on two Underground Injection
Control (UIC) Draft Area Permits and one associated proposed aquifer exemption decision for the Dewey-Burdock
uranium in-situ recovery (ISR) site located near Edgemont, South Dakota.
I wish to voice my support for the Dewey-Burdock Project, and it is my hope that swift approval of these permits will be
granted.
I recently attended one of the public hearings in Rapid City, and listened to the parade of detractors who spoke against
the issuance of these permits. Most were concerned that irreparable damage would occur to drinking water aquifers
and that contamination would spread throughout the land and harm wildlife. Very few speakers backed up their claims
with credible scientific evidence to support those claims. Certainly, we all want to have clean water, clear air and
healthy soil, and I believe that with proper management and oversight, both sides can achieve their respective goals.
Public comment periods and hearings provide both the opponents and the proponents a forum in which to voice
concerns, facts and opinions, and in the end, it creates a more robust permit that promotes safety and environmental
awareness.
As a former Senior Geologist at Cameco's Crow Butte Operation near Crawford, Nebraska, I am intimately familiar with
the ISR process of uranium extraction and waste disposal proposed by Powertech. For 20 years, I designed, installed,
maintained and abandoned Class III wells at an operating ISR mine. The process CAN be done safely and responsibly,
with limited environmental impacts to only the permitted areas. The impacted groundwater, wellfields and surrounding
lands are regularly monitored during and after mining to ensure public safety and regulatory compliance.
Extensive pre-mining baseline data provides data that sets the restoration standards for groundwater and land surface
clean up. EPA and the South Dakota Department of Environment and Natural Resources can ensure that proper
precautions are enacted in these permits to protect the water, lands, wildlife and people of South Dakota and the
surrounding area.
In August 2015,1 provided expert testimony for the Crow Butte License Renewal to the U.S. Nuclear Regulatory
Commission's Atomic Safety Licensing Board (ASLB) in response to contentions filed by many of the same detractors
present at the Rapid City meeting. Many of the same allegations concerning groundwater quality, uranium and heavy
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metal mobilization, contamination of drinking water, and public health impacts were presented by the intervenors
during five days of testimony before the ASLB judges.
Before the hearing concluded, after hearing the facts, even the intervenors' own geologic expert agreed that the modes
of uranium transport and contamination raised in the contentions were unlikely to occur. In the end, the ASLB judges
ruled that the intervenors' contentions concerning groundwater quality and groundwater movement were not plausible,
and ruled in favor of the Crow Butte license renewal.
Again, I support the acceptance of the Dewey-Burdock UIC Draft Area Permits, and the proposed aquifer exemption for
uranium mining. This is a sound project run by competent, responsible people that will provide jobs to a struggling
community.
Thank you for your time and consideration.
Sincerely,
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Shea, Valois
From:
Sent:
To:
Subject:
Sunday, March 12, 2017 8:48 PM
Shea, Valois
Uranium Mine Waste Disposal - No
Valois Shea
EPA asks public for permission to allow Uranium mining waste disposal in SD aquifer:
No.
Must abide by regulations, and ideally common sense.
Thank you
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Shea, Valois
Sent: Monday, May 15, 2017 9:49 AM
To: Shea, Valois
Subject: Please do not issue permits for the Dewey-Burdock uranium mine
Dear EPA decision-maker,
I'm writing to comment on the applications the Dewey-Burdock Uranium mine.
The location of this proposed mine is not suitable for this type of operation because the stata is unstable and full of
perforations. Use of the proposed techniques poses an unacceptable risk to the groundwater aquifer.
Please insist that a full study taking these risks into account be performed before considering the application for this
unusually dangerous and destructive method of uranium extraction.
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Shea, Valois
From:
Sent:
To:
Subject:
To whom this may concern, I am writing to support native Americans in there opposition to the Dewey Burdock uranium mining of the
black hills territory I
Monday, May 08, 2017 5:31 PM
Shea, Valois
No uranium mining Dewey Burdock!
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Shea, Valois
Sent: Saturday, March 11, 2017 3:03 PM
To: Shea, Valois
Subject: South Dakota Uranium Mining
I oppose the allowance of these mining permits, as they endanger the drinking water in nearby areas, as well as intrudes
on Indigenous-owned spaces.
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5-11-17
Valois Shea
US EPA Region 8
1595 Wynkoop St.
Denver, CO 80202-1129
RE: Proposed Uranium Mining Site near Dewey, SD
Dear Valois Shea:
I am writing to express my approval of the mining operation near Dewey, SD. My family has lived in
the Black Hills for 5 generations. My relatives homesteaded just east of the proposed location of the
mine. I am an environmental consultant that has worked in the Black Hills area for over 30 years
and have extensive background in mining activities in the Black Hills area, specifically in
environmental monitoring. I am also a local businessman with three businesses located in Custer,
SD that include consulting, a retail shop, and wholesale products sales.
I have conducted groundwater sampling for Powertech over this last 10 year period. I have
extensive knowledge of the mining plan and believe the plan to provide adequate protections to the
environment. The Nuclear Regulatory Commission and the South Dakota Department of
Environment and Natural Resources have approved the mining plan and I trust their/your
expertise in regulating this operation.
Personally, I feel we need to develop this resource. The United States as a whole will need more
energy because of increased demand. Nuclear energy is needed as much as any other energy
source. Solar energy, wind energy, petroleum energy, fossil fuel energy are all important sources
but nuclear energy needs to be developed right alongside these sources to provide a reliable,
carbon dioxide free energy source.
I have been reading a lot of misinformation about the operation. I think many of the negative
claims about the operation are misleading and downright false. I encourage you to review those
comments using good scientific thought.
The southern Black Hills needs the jobs created by this operation. We have witnessed a steady
decline in year round jobs in Custer, Hot Springs, and Edgemont. While this operation will not
balance the loss of jobs, it will certainly help.
-------
In short, I support the approval of Powertech's mining application.
Sincerely,
I, Environmental Scientist
Page 2
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Shea, Valois
Sent: Tuesday, March 14, 2017 11:19 AM
To: Shea, Valois
Subject: Uranium Mining in South Dakota - public comment
Dear Mx. Shea,
I am writing to express grave concerns about the plans to mine uranium in South Dakota. There seem to be clear
environmental risks at stake and I am not reassured by the EPA's assertion that it has consulted with experts or
with local Indian tribes. There is no way to guarantee that accidents won't happen and that it not a risk that I am
willing to take. As a citizen of the US and a member of the public, I am staunchly opposed to this step.
Sincerely and with all due respect,
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Shea, Valois
From:
Sent:
To:
Subject:
Tuesday, March 14, 2017 10:52 AM
Shea, Valois
Comment on UIC Area Permit to Powertech, Inc
To Whom It May Concern:
I find the use of injection wells in the Inyan Kara Group horrifying and should not be permitted. Further, this
aquifer should NOT be exempted from the Safe Drinking Water Act. It is my belief that these permits should
be rejected. It is my expectation that the EPA will ensure the safety of drinking water. Even though I do not
live in the area, I find the fact that industry is so eager to compromise the safety of America's drinking water
supplies disgusting and would not want these actions to affect the integrity of my drinking water.
Sincerely,
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Shea, Valois
From:
Sent:
To:
Subject:
Monday, June 19, 2017 9:36 PM
Shea, Valois
Dewey Burdock Uranium Aquifer Mining
Dear Ms. Shea,
I write with grave concern after reading various possible scenarios regarding uranium and the Black
Hills https://www.epa.gov/newsreleases/epa-seeks-public-comment-draft-permits-and-aquifer-exemption-
uranium-mining-proiect.
We must protect the waters and the peoples of this country. Deregulation is NOT the answer. If any one person
or company feels that these measures are just but would never perform such measures on the land in which he
or she lives then it is not a proper way.
The Black Hills are a precious land that has caused much strife for over 100 years. We need to show respect to
the land and to the peoples who reside there and say no to the corporate greed and yes to environmental safety.
Future generations will thank you for saying NO to this mining.
Best,
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Shea, Valois
From:
Sent:
To:
Subject:
Wednesday, May 10, 2017 3:16 PM
Shea, Valois
Class III, Class V, Dewey Burdock Comment
I am a landowner and rancher who lives 30 miles from the proposed uranium site. My wells use the Madison
and Minnelusa aquifers and other shallow wells to support our cattle and our own water consumption. If
Azarga is allowed to use this water supply there is no guarantee that it could sustain 10 years if in situ mining
and our wells. This is the only sustainable water we have for livestock. Livestock is the economic driver in
Western South Dakota. If you take our water, you risk a much larger industry for South Dakota in exchange for
10 years of uranium mining.
Second, and most important is. What if the chemical laden, radioactive water that is injected back down in
these wells eventually leaks.
On the EPA's website is states: "Regardless of the use of Class V wells, owners and operators are responsible
for protecting underlying ground water from contamination"—
Who will be at the site to ensure that the water injected into Class V wells meets ClassV standards? Where is
the guarantee that the chemical laden water can even be filtered to acceptable ClassV standards. Radioactive
minerals should not be allowed in Class V wells.
And if Azarga goes bankrupt and they don't cap the wells, what happens?
Will there be continued monitoring when Azarga is done with the site and the wells are capped? NO! Who
monitors these sites 20 or 30 years from now to know if the wells crack and leaking occurs? And IF these wells
leak to our water supply there is no restoring it back to a safe drinking water state which I am sure you
are well aware of. The entire western half of South Dakota relies on the Minnelusa and Madison for its water
supply. We can't haul water from anywhere else if the Madison or Minnelusa gets contaminated. Please don't
risk the tourism economy and the livestock economy and the American people's livelihoods of Western South
Dakota for a foreign company.
http://Droiects.proDublica.ore/graphics/undereround-iniection-wells. From 2008 to 2010 there have been
6,723 that have tested positive for major leaking and 60,467 wells with violations. And 859 unauthorized
injections!!!
Facts:
State-by-State: Underground Injection Wells
projects.propublica.org
The data below is from annual state regulatory summaries for underground injection wells that were
submitted to the Environmental Protection Agency between late 2007 ...
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Shea, Valois
From:
Sent:
To:
Subject:
Tuesday, March 14, 2017 1:11 PM
Shea, Valois
Aquifer exemption for uranium mining project in southwestern South Dakota
In regards to the uranium mining exemption- We must not continue to destroy our waterways and
lands by allowing big business to dump wastes and bypass the protections provided by the EPA. The
EPA's job is to Protect the environment although it appears that Mr Pruitt is unfamiliar with the
concept. What could possibly make anyone think that allowing dumping near an aquifer would be a
good idea except someone who doesn't live near by and is only concerned about making more
money.
Mr Pruitt- Step up and protect the environment or step down!
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Shea, Valois
From:
Sent:
To:
Subject:
Monday, May 29, 2017 9:29 AM
Shea, Valois
DENY PERMITS & RETURN BRIBES Re Dewey-Burdock Uranium Mine
Dear CRIMINAL EMPLOYEES @ EPA,
Commenting on the Underground Injection Control Program's Draft Permits for the Proposed Dewey-Burdock Uranium
Mine and Deep Disposal Wells.
The proposed mine and deep disposal wells are in an area that is documented to have faults, fractures, breccia pipes,
and over 7000 old boreholes that have not been properly plugged. It will be impossible to contain mining fluids or waste
liquids, and contamination of groundwater resources is very likely.
I am also concerned that adequate oversight of the quality of liquid wastes pumped into the Minnelusa Formation
through the proposed deep disposal wells will be inadequate, and groundwater WILL be contaminated.
A full survey of cultural and historical sites is needed before mining or deep disposal is allowed. Cultural and historical
sites must be protected.
The history of uranium mining indicates that uranium mining cannot be done without creating and leaving
contamination. Groundwater has never been returned to its original condition at any In-Situ leach uranium mine in the
U.S. These permits should not be issued until it can be demonstrated that groundwater resources will be protected.
DISGUSTED VOTER
1
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Shea, Valois
From:
Sent: Monday, March 13, 2017 4:44 PM
To: Shea, Valois
Subject: FW: Exemptions for Uranium Mining
Comment
—Original Message—
From:
Sent: Monday, March 13, 2017 4:38 PM
To: McClain-Vanderpool, Lisa
Subject: Exemptions for Uranium Mining
Dear Lisa,
This proposal is simply obscene. Please do everything you can do to stop it.
Sent from my iPhone
1
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Shea, Valois
From:
Sent:
To:
Subject:
Sunday, March 12, 2017 10:37 PM
Shea, Valois
SD aquifer
Dear Shea,
I am a member of the public who would like to comment on the proposed permits for injecting uranium into the
ground near a SD aquifer.
This is an extremely and astonishingly bad idea.
I understand that the uranium would be ostensibly treated to be made safe before injection. Still: no. Really,
adamantly, no.
I understand that the water would be monitored for safety throughout the process. Still: no. Completely and
emphatically no. What happens when the water in the aquifer is found to be contaminated? How long would the
remediation process take, if it's even possible?
I understand that you are an actual person showing up for work every day, just like me, and I appreciate that at
times like this, it is probably a mostly thankless job. I can only hope that opposing opinions to this idea, like
mine, are genuinely counted and can have an impact in stopping this harebrained proposal. You would indeed
be thanked for advocating for the public who is contacting you with our concerns.
All best,
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Shea, Valois
From:
Sent:
To:
Subject:
Thursday, March 16, 2017 1:48 PM
Shea, Valois
Formal comment on South Dakota UIC permits and ISR aquifer exemption
Formal comment under the authority of the Safe Drinking Water Act and UIC program regulations, regarding:
• Proposed two Underground Injection Control (UIC) Draft Area Permits
• Proposed aquifer exemption decision for the Dewey-Burdock uranium in-situ recovery (ISR) site near
Edgemont, SD
Dear Ms. Shea,
I urge the EPA to deny both of these permits. Among other hazards, radon emissions, toxic heavy metals
and other pollutants, including chloride, sulfate, sodium, radium, arsenic and iron, are in ISR wastewater
ponds. Accidents and leaks in this kind of operation are inevitable, raising concerns about runoff into the
Cheyenne River and Angostura Reservoir. As you are aware, the most serious radiation release in the US came
from a tailings pond spill at a uranium mine in New Mexico.
We can live without uranium but not without clean water and soil.
Best regards,
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Shea, Valois
Sent: Sunday, April 09, 2017 8:37 PM
To: Shea, Valois
Subject: Valois Shea , permits to mine uranium
This is unacceptable, permits to mine uranium in the southern Black Hill should be denied! Putting poison water
in to the ground should never be permitted The Black Hills, the heart of
everything that is. The 1868 Fort Laramie Treaty was ratified by Congress and was never amended. Under
international law it is Native land. "The laws of the United States, the NRG regulations, and the individuals who sit behind those
desks can honor treaty law, the life way of the Lakota, environmental laws, and demonstrate respect for Mother Earth by denying
application to mine uranium."
Sent from Mail for Windows 10
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Shea, Valois
Sent: Tuesday, March 14, 2017 12:02 PM
To: Shea, Valois
Subject: EPA seeks public comment on draft permits and aquifer exemption for uranium mining
project in southwestern South Dakota
Please, there are some things that we can't get wrong, and this is one of them.
Clean-up is near impossible and will not be an option.
Some things can't be reversed.
Between this and the proposed healthcare repeal / replace, you're going to actively kill off people.
Is that what you really want?
Please, be a responsible government for all the people, not just a few who will benefit from this.
Thank you.
News Releases
• Share
• Contact Us
News Releases from Region 08
EPA seeks public comment on
draft permits and aquifer
exemption for uranium mining
project in southwestern South
Dakota
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Public hearings will be held in Valentine, NE and in
Rapid City, Hot Springs and Edgemont, SD
03/06/2017
Contact Information:
(Denver, Colo. - March 6, 2017) EPA has issued two draft Underground Injection Control
(UIC) Area Permits to Powertech (USA) Inc., for injection activities related to a proposed
uranium recovery project in the southern Black Hills region in Custer and Fall River Counties
of South Dakota. EPA will conduct information sessions combined with public hearings on
April 27 r and on May 8 through May 11 at the times and locations detailed below. EPA will
accept public comments on the draft permits and a proposed aquifer exemption associated
with the project through May 19, 2017.
The draft permits issued today include a UIC 'Class III' Area Permit for injection wells for the
in-situ recovery (ISR) of uranium in the Inyan Kara Group aquifers and a UIC 'Class V Area
Permit for deep injection wells that would be used to dispose of ISR process waste fluids into
the Minnelusa Formation below the Inyan Kara after treatment. Under the terms of the draft
permits, waste injected under the Class V permit must be treated prior to being injected and
must meet all radioactive waste and hazardous waste standards. Monitoring of the
underground sources of drinking water surrounding the Class III injection wellfields will take
place before, during and after ISR operations to ensure the underground sources of drinking
water are protected.
EPA is also proposing an aquifer exemption approval in connection with the draft UIC Class
III Area Permit. Specifically, this approval would exempt the uranium-bearing portions of the
Inyan Kara Group aquifers from protection under the Safe Drinking Water Act. Such an
exemption must be in place before ISR activities within these aquifers can occur.
Under its obligation to comply with the National Historic Preservation Act and under EPA's
Tribal Policy on Consultation and Coordination with Indian Tribes. EPA has been consulting
and coordinating with several interested Tribes to identify the potential effects of the proposed
project on traditional cultural places, historic and sacred sites. EPA will continue to consult
and coordinate with Tribes as necessary throughout the public comment period concerning
these proposed permitting actions.
The public is encouraged to provide comment on these draft permits and the aquifer
exemption by midnight mountain time, May 19, 2017. EPA's final permit decision will be
based on an evaluation of comments received and a determination of whether underground
sources of drinking water are protected. The draft permits can be found at the EPA Region 8
UIC Program website: https://www.epa.gov/uic/uic-epa-reQiQn-8
How to Comment: Written comments must be received by email, fax or mail sent to:
Valois Shea (shea.v.iicvs^'epn.ciov): Fax: 303-312-6741
U.S. EPA Region 8 Mail Code: 8WP-SUI
1595 Wynkoop Street
Denver, CO 80202-1129
Public Information Sessions and Hearing information (The public may also provide
written and/or verbal comments during the following EPA public hearings):
Thursday, April 27, 2017 from 4:00 to 8:30 p.m. (with a break from 5:00 to 6:00 p.m.)
Niobrara Lodge
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803 US Highway 20
Valentine, Nebraska 69201
Monday-Tuesday, May 8-9, 2017,1:00 to 8:00 p.m. (with a break from 5:00 to 6:00 p.m.)
The Best Western Ramkota Hotel, 2111 N. LaCrosse Street, Rapid City, South Dakota 57701
Wednesday, May 10, 2017, from 1:00 to 8:00 pm (with a break from 5:00 to 6:00 p.m.)
The Mueller Center, 801 S 6th Street, Hot Springs, South Dakota 57747
Thursday, May 11, 2017, from 1:00 to 8:00 pm (with a break from 5:00 to 6:00 pm)
St. James Catholic Church, 310 3rd Avenue, Edgemont, South Dakota 57735
Contact Us to ask a question, provide feedback, or report a problem.
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Shea, Valois
Sent: Tuesday, March 14, 2017 3:43 PM
To: Shea, Valois
Subject: Aquifer Exemption for S D Minimg Project
I am writing to provide an opinion of the exemption rules proposed for this project.
Why in the world would injecting uranium waste products into a fresh water acquifer even be considered for approval?
Protect our drinking water, no matter where it is. An acquifer is not a garbage can for some mining company.
Sincerely
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Shea, Valois
From:
Sent:
To:
Subject:
Monday, March 13, 2017 12:35 PM
Shea, Valois
Draft permits and aquifer exemption for uranium mining project in southwestern South
Dakota
To Whom It May Concern,
I am writing to voice my strong opposition to the EPA issuing Underground Injection Control Area permits to Powertech
Inc for injection activities related to a proposed uranium recovery project in the southern Black Hills region in Custer and
Fall River Counties of South Dakota.
I am specifically horrified that the EPA would allow an exemption approval in connection with the draft UIC Class III Area
Permit. Specifically, this approval would exempt the uranium-bearing portions of the Inyan Kara Group aquifers from
protection under the Safe Drinking Water Act. Such an exemption must be in place before ISR activities within these
aquifers can occur and strongly oppose this exemption.
Thank you for considering my voice and views in this matter.
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Shea, Valois
From:
Sent:
To:
Subject:
Saturday, May 20, 2017 9:40 AM
Shea, Valois
Re: Public comment period extended through Monday, June 19 for the proposed EPA
actions at the Dewey-Burdock site
Would you please provide us with an appropriate letter template from which we can personalize to submit our
comment? That would be very helpful.
Thank you,
On May 17, 2017, at 4:15 PM, Shea, Valois wrote:
Hello,
The EPA has extended the public comment period through Monday, June 19, 2017 for the proposed
Underground Injection Control (UIC) Program actions at the Dewey-Burdock site located near Edgemont,
SD. These actions include two draft UIC permits and a proposed aquifer exemption decision. Please see
the EPA website for the official announcement and administrative record for these proposed actions:
https://www.epa.gov/uic/extension-public-comment-period-dewev-burdock-class-iii-and-class-v-
iniection-well-draft-area-O
The EPA will accept mailed written comments postmarked by June 19 and emailed and faxed comments
date stamped by midnight Mountain Time at the close of June 19. My contact information is listed at the
bottom of this email and on the website above.
Thank you for your participation in the EPA public review process for these proposed actions.
Valois Shea
U.S. EPA Region 8
Mail Code: 8WP-SUI
1595 Wynkoop Street
Denver, CO 80202-1129
Fax: (303) 312-6741
Email: sheQ.VQlois@eDQ.QOV
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Shea, Valois
From:
Sent:
To:
Subject:
Thursday, June 01, 2017 10:03 AM
Shea, Valois
Re: Dewey-Burdock templates
Hello Valois.
Here is my letter concerning Dewey-Burdock Mine Permits:
Dear EPA,
This letter is in reference to the Underground Injection Control Program's Draft Permits for the Proposed Dewey-
Burdock Uranium Mine and Deep Disposal Wells.
History tells us that uranium mining cannot be done without creating and leaving contamination. In the past,
groundwater has never been returned to its original condition at any In-Situ leach uranium mine in the U.S.
The proposed mine and deep disposal wells are in a severely compromised area. Ample documentation exists that
demonstrates that the proposed Mine and Well area has numerous faults, fractures, breccia pipes, and over 7000 old
boreholes that have not been properly plugged.
Considering these issues, it would be impossible to contain mining fluids and waste liquids. The likelihood
of contamination of groundwater is extremely high.
Additionally, liquid wastes pumped into the Minnelusa Formation through the proposed deep disposal wells is highly
likely to be insufficient; again this raises the probability of groundwater contamination.
I urge that a full survey of cultural and historical sites be conducted prior to mining or deep disposal and all efforts to
protect cultural and historical sites.
Thank you for your consideration.
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Shea, Valois
From:
Sent:
To:
Subject:
Sunday, May 14, 2017 8:13 PM
Shea, Valois
Powertech permits
I understand in March of this year the EPA issued two draft permits to Powertech, a multinational corporation
and division of Azarga Uranium Corporation of Canada. Together these permits would allow the drilling of
thousands of wells within 14 different fields. These wells would bore hundreds of feet into the ground and
pierce the Inyan Kara system of underground aquifers. The second of the two permits is to allow the disposal of
hazardous waste materials resulting from uranium mining. Both permits would needlessly expose the Lakota
Oyate to the devastation of uranium mining and continue america's war against Red Nations' peoples.
"The Inyan Kara, Minnelusa, and Madison aquifers are the principal sources of ground water in the northern
Black Hills, South Dakota and Wyoming, and Bear Lodge Mountains, Wyoming. The aquifers are exposed in
the Bear Lodge Mountains and the Black Hills and are about 3,000 to 5,000 ft below the land surface ... The
direction of groundwater movement is from the outcrop area toward central South Dakota."
Please stop this. If it were happening to you or your family you wouldn't want it either. Please show some
compassion and simple human decency.
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Shea, Valois
Sent: Tuesday, March 14, 2017 2:30 PM
To: Shea, Valois
Subject: Uranium mining/aquifer S. D.
Dear EPA:
I am writing to oppose the plan to dump wastes from uranium mining under the aquifer in S. D. This is not wise from
many standpoints. Once again our Native American tribes are threatened with a real risk to their drinking water. Once
again we run the risk of standards for treating the waste not being stringent enough and residents enduring dangerous
consequences over time. And once again, big business seeks to make tons of money off the backs of the little guy, we
common folks, who do not have the money to buy the power to stop them. When will we return to the concept of the
common good? The EPA can embrace that concept and apply it to this situation. Please oppose this project of uranium
mining. Thank you for your time.
Respectfully,
Sent from my iPhone
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Shea, Valois
From:
Sent:
To:
Subject:
Wednesday, May 17, 2017 2:55 PM
Shea, Valois
Please Leave the Black Hills In Peace
Please, we need you to participate in doing the "ethical and sane" thing. Please leave our Black Hills alone.
I know the powers that be would like to have us warring, angry, overwhelmed and distracted. We know this.
Please step up and care about this nation as a whole.
We the people deserve healing, lucidity and truth from our governing bodies. The treaties were broken, 1000
times over, the gas lighting never ceased, Indigenous nations were decimated and destroyed - turning our people
into shells, barely human.
Our government succeeded in humiliating, destroying and bringing Indigenous Nations on this continent to our
knees. That is not a governing body who unites, nurtures and expands - it is divisive.
Please work with the ethical, the humane and the joyful parts of yourself and this nation.
Please stay out of sacred sites and allow us our peace.
Honor the Treaties!
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Shea, Valois
From:
Sent:
To:
Subject:
Monday, March 13, 2017 8:40 AM
Shea, Valois
FW: Comment on Uranium extraction and aquifers in South Dakota
comment
—Original Message—
From:
Sent: Saturday, March 11, 2017 4:34 PM
Subject: Comment on Uranium extraction and aquifers in South Dakota
I am opposed to the extraction of Uranium in South Dakota. If Ivanka Trump is going to drink the test water in front of a
live audience, I might be convinced to change my mind. I would want her and her children to return weekly and drink
and bathe in the water to prove it is safe. Write that into the agreements.
Sent from my iPhone
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Shea, Valois
From:
Sent:
To:
Subject:
I can't even begin to express how vehemently I oppose allowing uranium mining waste to go into an aquifer in the black
hills. Obviously, no aquifer should be abused in this manner, but having grown up in spearfish, SD, the idea sickens me
that much more.
Please don't let this happen!
Thank you,
Sent from my iPhone
Sunday, March 12, 2017 9:38 PM
Shea, Valois
Uranium mining disposal in the black hills
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Shea, Valois
From:
Sent:
To:
Cc:
Subject:
Monday, June 19, 2017 6:17 PM
Shea, Valois
Black Hill Aquifers Comment
Hello, I am writing today as a concerned citizen of the United States of America. I live in San Diego, CA 92114. As a
concerned mother I want to place a comment here for the people and water in the area. It is an unrighteous thing to do if
you abandon this site like you have. Our people are getting sick, we can feel it in the spirit of things. Mothers are crying
up to the heavens over all the atrocities our government is bestowing on us. Azarga has no compassion for us while
contaminating our ground waters. I say "ours" and "my people" because we are one and we feel you as a government
bringing shame on yourselves for what you have done so far. We feel you as mothers who mourn for the children yet to
get sick from this. We grieve and feel the Holy Spirit grieving with us for those who are sick now and have died
unchecked in your balances. Spiritually, if you ignore this and allow these mines to go unchecked your mark will be
checked in heaven. You just cant keep grieving the Holy Spirit and think it is ok. We are the poor, the widowed, the
downtrodden and your allowing a corporate company to further damaging access against our families. We are connected
to each other. We saw how your business, your EPA was slashed and know about the things you as the EPA are
required to do by court order in Flint alone. We know there is no physical way that settlement can be honored based on
your deployment of agents, because the number of houses doubled in count testing positive for poison. You simply don't
have the man power. We want change, we want a government and the agencies associated who will not be able to
receive a profit. To push that profit over people mentality. It is deep rooted in our government as they continue to slash
employees from your EPA and throw out books that contain important regulations we need. Regulations our children
need. We see it as a blatant attack on our right to life and want to bring suit against you all based on this uranium
mess. We are expecting a righteous outcome because it is what we are praying for. Do the right thing EPA, Government
and leaders of the corporate genocide and clean this mess up ! Because if the letters don't help us stop this injustice,
some of us are prepared to go to litigation to bring charges against the multitude of evil profit people, for manslaughter, for
neglect, for emotional damages, we are strong and many. Please, do the right thing..
Sincerely,
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To whom it may concern,
1. Background
From this time until May 19th, the United States Environmental Protection Agency
(EPA) is calling for public comments regarding a hot topic issue in the state of South Dakota.
The small town of Edgemont, South Dakota is currently at the center of an environmental deal
between the US company PowerTech and the EPA that consists of permitting the company to
conduct an in situ uranium recovery project that is located roughly 13 miles northwest of the
town. This recovery site is located on the southwestern edge of the Black Hills, a wild horse
sanctuary established roughly 20 east of Edgemont. In 2015 the EPA determined that the cleanup
of these sites, the Darrow, Triangle, and Freezeout mines, was not required. While the EPA may
have sampled upstream and downstream of the site in question, they were criticised for their
ruling because testing within the actual mine sites was not conducted due to the fact that site
assessors were unable to gain private landowners permission to access the sites. While this is not
entirely the fault of the EPA, the conclusions drawn from their testing ultimately do not reflect
the real life exposure and contamination potential and therefore should not be fully accepted. In
addition, these assessments do not take into consideration large soil and mine-waste piles or
possible runoff potential from the mine pits. Due to sampling conducted downstream that did not
exceed healthy concentration levels, the epa was not able to document an occurrence of a release,
however large gaps in preliminary site testing leaves a large amount of uncertainty to be
accounted for.
2. Overview of proposed action
This action by the EPA would allow Powertech to conduct in situ recovery mining that
utilizes a series of wells to inject groundwater enriched with oxygen and baking soda into the
uranium ore area. By doing so, the mixture dissolves the uranium ore and is then drawn out by a
pump and sent to a processing plant. Once at the plant, the uranium can be removed using ion
exchange techniques, while the leftover water is refortified with oxygen and baking soda again.
By doing so, Powertech is able to create a sustainable extraction method that reuses the injected
groundwater. This process eliminates the need for mining machines, open pits, mine waste, mine
shafts, and mine workers who previously have been required to use explosives in previous
extraction methods. From their purchase and surveying of the 11,000 acres Powertech bought in
2005, the company has reported an estimated 11 million pounds of recoverable uranium that
would take over two decades to fully recover. The site itself has a few key natural characteristics
that have prevented the uranium from contaminating further including good geological
confinement and natural upward groundwater gradients that prevents dissolved uranium and
mining solutions from traveling down the water gradient. In addition, engineering controls will
be established including well field design and the implementation of monitoring wells that
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measure groundwater levels and water chemistry. Finally, the operation will implement a
technique known as bleed pressure which creates a pressure gradient in the injection process that
causes the groundwater to flow towards the production wells, ensuring as much of the treatment
water is recovered. Powertech has determined they will need roughly 190 employees for the
operation and has estimated a rough investment of $51 million dollars. Once the operation is
complete, Powertech has stated that all wells will be sealed/capped, pipelines and process
facilities will be removed, and the site will be re-vegetated. Finally, freshwater will be pumped
through the aquifer to ensure it is restored to NRC standards.
3. Personal opinion of proposed action
While taking all of the previous information into consideration, including the various
technological controls, natural site features, and established plans of process and cleanup, I
believe this operation has the potential to be a disastrous environmental catastrophe. Given the
various technological failures that have occurred over the years, such as chemical plant
explosions or the water contamination in Flint, Michigan, the most extreme consequences must
be taken into consideration. These operations are highly digitalized and rely on a variety of
different technological controls in order for the system to function properly without any
unintentional runoff or seepage to occur. These processes are so streamlined and integrated that a
single issue process could prove catastrophic to the community of Edgemont. For example, a
chemical plant in the United States had a buildup of gases in a chemical reserve tank that caused
in a backflow of chemicals into the system that resulted in a destructive explosion. This
explosion destroyed most of the plant and resulted in one of the largest death counts from an
industrial accident in recent years. These situations are thankfully not frequent occurrences,
however a proper risk assessment must take into consideration both the probability and the
impact of the consequences regardless of their assumed probability.
4. Consideration of legal and cultural impacts
In addition to the possibility of technology failure, the cultural significance to the area
must also be taken into consideration. The Black Hills have been home the The Lakota, or the
Sioux tribe, for generations. Because of this, the EPA is required to comply with the National
Historic Preservation Act under the EPA's Tribal Policy on Consultation and Coordination with
Indian Tribes. These people have been interested in the potential outcomes of the Powertech
operation, and as such have requested the EPA provide them with a concise and well researched
identification of potential effects of the proposed project. These are historic and sacred lands, and
as such the EPA continues to provide the tribe with as much information as possible, however
these potential cultural impacts must be weighed against the benefits.
5. Consideration of scientific argument
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In addition to the cultural consequences, the scientific ramifications of the project must
be taken into consideration. While research and modeling has determined that the flow rates
between the 3 Black Hills aquifers is minimal, flow between aquifers ultimately occurs. While
this flow rate has been deemed minimal a technological control failure could result in the tribe
being exposed to an extremely dangerous radioactive material that has serious health
implications associated with both short term and long term exposure. The EPA has drafted
permits for Powertech that include a UIC 'Class III' Area Permit for injection wells for the in
situ recovery of uranium in the Inyan Kara Group aquifers, as well as a UIC 'Class V' Area
Permit for deep injection wells that would be used to dispose of recovery process waste fluids
into the Minnelusa Formation below the Inyan Kara after treatment. These terms establish
treatment requirements for the waste encompassed under the 'Class V" Area Permit that must
meet all radioactive waste and hazardous waste standards. In addition, the permits establish
monitoring of the sites prior, during, and after the operation to ensure concise data records of the
process. Finally, the EPA is also considering an aquifer exemption rule for Powertech in
combination with the UIC 'Class III' Area Permit. This would exempt Powertech from
complying with the Safe Drinking Water Act in all uranium-bearing portions of the Inyan Kara
Group aquifer. While it has been determined that water flow out of and between the aquifers is
minimal, omitting a key step in the cleanup process is a counterproductive decisions of which the
consequences must be taken into consideration.
6. Conclusion
Thank you for the opportunity to provide input on the proposed aquifer exemption for
uranium mining waste issue. These environmental issues are things that many citizens of this
country must deal with in their everyday lives, and unfortunately will be present for future
generations to deal with. The long term time frame and scale of the consequences that could
from technological control failure, corporate negligence, and natural leakages must be taken into
consideration when determining whether or not to approve this project. With the information
provided, it only makes sense to discourage potentially dangerous operations such as these, and it
is my hope that I have convinced you to take into consideration a perspective you may not share.
Cordially,
7. References
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Thares, Paul. "Proposed Powertech (USA) Dewey-Burdock In Situ Recovery Uranium Mine
Project". iGrow SDSUExtension. N.p., 2017. Web. 30 Mar. 2017.
"EPA: Cleanup Not Required At Uranium Mines Near Edgemont". KELOLAND News. N.p.,
2017. Web. 30 Mar. 2017.
"Public Notice: Administrative Record For The Dewey-Burdock Class III And Class V Injection
Well Draft Area Permits | Protecting Underground Sources Of Drinking Water From
Underground Injection (UIC) | US EPA". Epa.gov. N.p., 2017. Web. 30 Mar. 2017.
Kyllonen, David, and Kathy Peter. "GEOHYDROLOGY AND WATER QUALITY OF THE
INYAN KARA, MINNELUSA, AND MADISON AQUIFERS OF THE NORTHERN BLACK
HILLS, SOUTH DAKOTA AND WYOMING, AND BEAR LODGE MOUNTAINS,
WYOMING", www.usgs.gov. N.p., 2017. Web. 30 Mar. 2017.
"EPA Seeks Public Comment On Draft Permits And Aquifer Exemption For Uranium Mining
Project In Southwestern South Dakota | U.S. EPA News Releases | US EPA". Epa.gov. N.p.,
2017. Web. 30 Mar. 2017.
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Shea, Valois
Sent: Wednesday, May 17, 2017 9:14 PM
To: Shea, Valois
Subject: U.S. EPA Region 8 Mail Code: 8WP-SUI
Val;ois Shea
U.S. EPA Region 8 Mail Code: 8WP-SUI
1595 Wynkoop Street
Denver CO 80202-1129
In regard to the permits to allow for the waste fluids to be injected, I do NOT think it should be allowed.
If there is ANY chance at all for the contamination of the aquifers, and I do not think anyone can give a 100% guarantee
that it wouldn't.
There could be earthquakes and water moves. As good as those engineers and scientists are they cannot be 100% sure
that our aquifers and water would be completely protected.
Some of my questions would be: You are using water to make money. That is the public's water.
Who is this company?
Where will the uranium be going?
Will it go to countries that are not friendly to the United States?
I do not think that injecting it back into the ground should be allowed'.
Sent from Mail for Windows 10
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Shea, Valois
Sent: Monday, March 13, 2017 6:02 AM
To: Shea, Valois
Subject: draft permits and aquifer exemption for uranium mining project in southwestern South
Dakota
This activity will poison the water supply. People cannot live without clean water. I oppose granting these
permits.
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Shea, Valois
Sent: Tuesday, March 14, 2017 12:00 AM
To: Shea, Valois
Subject: Comments on EPA permits for Uranium mining in South Dakota
The potential contamination of drinking water should be avoided at all costs. Our water is a limited resource. The
monitoring of the water will not prevent contamination and once contaminated the water will be undrinkable and taste
bad. How did uranium become more valuable than our drinking water? Stop all drilling and other activities that will or
has the potential to contaminate our water supply.
Who will be doing the monitoring of the water? The companies cannot and should not be trusted with this activity. We
all know about companies who have historically not provided accurate information to the public when water has been
contaminated. This withholding of information has resulted in serious illness or death for people who have been
exposed to contaminated water.
What happens when the injection material gets into the aquifer? Will the companies pay to clean it up or does that fall
on tax payer to clean up their mess.
No to any and all drilling, mining, pipelines with the slightest potential to contaminate water.
Sent from my iPhone
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Shea, Valois
Sent: Monday, March 13, 2017 1:12 PM
To: Shea, Valois
Subject: No!
No! No! No! Radioactive waste in the Aquafier!!! No! No! No!
Photographer
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Dewey-Burdock Class III and Class V Injection Well Draft Area Permits - Public
Comment
Department of Geography, Environment, and Society
University of Minnesota
414 Social Sciences
267 19th Ave S
Minneapolis, MN 55455
1. Introduction
In April of 2017, the US Environmental Protection Agency (EPA) released draft permits for
uranium recovery and wastewater disposal associated with the proposed Dewey-Burdock in-situ
recovery project. In accordance with EPA policy and Executive Order 12898, the EPA also
conducted an environmental justice (EJ) analysis concerning the mine's possible environmental
or health impacts on minority and low-income communities. The report finds that "the city of
Edgemont is a potentially overburdened community" based on its low-income status and
accumulation of environmental health risks, but that the Dewey-Burdock project is not expected
to meaningfully change this status. The EPA also recognizes the need for consultation with tribal
communities for whom "the Black Hills is an area of cultural importance," although it recognizes
that consultation activities are not a part of the EJ analysis. Finally, the EJ analysis mentions
several times that the EPA will conduct "enhanced public participation and outreach activities"
given that UIC wells have the "potential for significant public health or environmental impacts."
These included several public comment sessions in the Black Hills area.
We find the EJ analysis deficient in several connected ways. First, the analysis appears at odds
with broad public understandings of environmental justice, scholarly expansions on public
understandings, as well as the narrower, pragmatic definition of EJ used by the EPA. Second,
although the draft EJ analysis and the EPA's actions seem to suggest an understanding that the
project might affect Lakota and other tribal relationships with the Black Hills, the draft EJ
analysis as written does not allow the EPA to acknowledge the possible burden the proposed
project might place on the culture, religion, or health of Native peoples. Legal precedent - most
notably Lyng v. Northwest Indian Cemetery Protective Association - suggests that even in the
most extreme circumstances, the religious and cultural significance of a place will not prevent
the completion of mining and resource extraction projects, as the significance of the whole (in
our case, the Black Hills) is conceived by permit-granting institutions as separate from its part
(the Dewey-Burdock project area), and the latter is not seen by the federal government to impose
a substantial burden on the exercise of religious or cultural rights. Nonetheless, the EPA has still
undertaken enhanced outreach activities, including extensive public participation hearings closer
to the Oglala Sioux Tribe and Cheyenne River Sioux Tribe, in order to hear their concerns. To
us, this action shows the EPA has some interest in accounting for the impact this project would
have on Lakota and other Native peoples. This document thus presents an argument that the
historic environmental justice concerns of the Lakota, Dakota, and other tribes must be taken into
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account more substantially and meaningfully as a condition of this and any future EPA
permitting in the Black Hills region.
2. Defining environmental justice
The concept and practice of environmental justice emerges directly from the activism of people
of color and Native peoples directly affected by extractive industries, refineries and processing
plants, and hazardous waste repositories. In fact, much of this activism was responding to
uranium mining, processing, waste disposal, and nuclear weapons testing. In South Dakota,
Native and non-Native groups alike devoted many years in the 1970s and 80s to proving that
drinking water on the Pine Ridge and Cheyenne River reserves had been contaminated by past
mining activities, resulting in undue health burdens for their people. The organization Women of
All Red Nations (WARN) conducted many of the first drinking water tests on South Dakota
reservations and fought for environmental justice on a national and international scale (LaDuke
and Churchill 1985). The Indigenous Environmental Network (IEN) emerged to help facilitate
the extremely influential 1991 People of Color Environmental Justice Summit, which directly led
to Executive Order 12898, signed by President Clinton in 1994.
Based on EO 12898, the EPA defines environmental justice in the following way.
"Environmental justice (EJ) is the fair treatment and meaningful involvement of all
people regardless of race, color, national origin, or income with respect to the
development, implementation and enforcement of environmental laws, regulations and
policies.
Fair treatment means no group of people should bear a disproportionate share of the
negative environmental consequences resulting from industrial, governmental and
commercial operations or policies."
The EPA goes on to define the meaning of meaningful involvement:
• People have an opportunity to participate in decisions about activities that may affect
their environment and/or health
• The public's contribution can influence the regulatory agency's decision
• Community concerns will be considered in the decision making process
• Decision makers will seek out and facilitate the involvement of those potentially affected
We will return to this definition in a moment, but first it is important to contrast these principles
originally agreed upon at the 1991 Summit (which can be viewed in full at
http://www.einet.org/ei/principles.htmB. These include, most notably,
4) Environmental Justice calls for universal protection from nuclear testing, extraction,
production and disposal of toxic/hazardous wastes and poisons and nuclear testing that threaten
the fundamental right to clean air, land, water, and food.
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7) Environmental Justice demands the right to participate as equal partners at every level of
decision-making, including needs assessment, planning, implementation, enforcement and
evaluation.
11) Environmental Justice must recognize a special legal and natural relationship of Native
Peoples to the U.S. government through treaties, agreements, compacts, and covenants affirming
sovereignty and self-determination.
In contrast to the EPA's definition of environmental justice, the 1991 Summit identified the
specificity of particular activities (e.g., uranium mining) and the specificity of particular
communities and their relations with land and law (e.g., Native peoples) as fundamental to
achieving environmental justice. Here, environmental justice did not simply mean the absence of
harms or equality of distribution of risks, but also the proactive recognition of historic
relationships with specific land and environments as well as industries.
Scholars of environmental justice have focused closely on the twin problems of distribution of
environmental harms and benefits and participation in public decision-making processes
(Holifield 2001, Holifield et. al. 2010, Schlosberg 2009, Young 1996). What both social
scientists and political theorists commonly argue is that public contribution rarely has the chance
to influence the regulatory agency's decision. Nonetheless, individuals and organizations
participate wholeheartedly and without pay in public hearings like those conducted by the EPA
in South Dakota and Nebraska for the Dewey-Burdock project. In the case of the Dewey-
Burdock project, public comments were overwhelmingly against the project. Although not
always couched in this terminology, we would suggest that many of the speakers were
attempting to demonstrate to the EPA that the proposed Dewey-Burdock project does not
produce just outcomes for marginalized populations in South Dakota. Whether their public
comments meet the threshold for 'meaningful participation' depends on how willing the EPA is
to modify its approach and adhere to its own principles.
The EPA has continued to expand upon its definition of environmental justice through its EJ
2014 and 2020 Action Agendas. EJ 2014 went a long way toward strengthening the EPA's
capacity to recognize possible overburdened communities, as the Dewey-Burdock analysis via
EJ Screen and expanded use of participation and outreach meetings demonstrates. However, the
EPA has also recognized the difficulty of integrating EJ into all aspects of agency practices,
including permitting, public relations, and actual results. This includes understandings of treaty
rights, which the EPA admits has been "a major evolution in EPA's understanding of
environmental justice and tribal rights" (EPA 2016, 43). The EJ 2020 Action Agenda sets out 4
strategies for enhancing environmental justice towards Native peoples. These are:
1. Strengthen consideration of tribes' and indigenous peoples' issues, their involvement in
EPA's decision-making processes, and responsiveness to their concerns when EPA
directly implements federal environmental programs.
2. Help federally recognized tribal governments build capacity and promote tribal action on
environmental justice.
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3. Address disproportionate impacts, improve engagement, promote meaningful
involvement, and improve responsiveness to the environmental justice concerns of
indigenous peoples.
4. Promote intergovernmental coordination and collaboration to address environmental
justice concerns in Indian country and in areas of interest to tribes and indigenous peoples
throughout the United States.
Is the permitting process the EPA is conducting for the Dewey-Burdock project consistent with
these strategies and goals? Although enhanced public participation was conducted in the spring
of 2017, this outreach focused almost completely on the potential health and water quality
impacts of the project. While we find these very important, information from the draft
environmental justice report was only mentioned, but not explained or referenced in any
substantial manner by EPA officials. Although we took the time to download and comment on
this report, it is likely that many more participants would have done so if the EPA representatives
had explained their findings more substantially.
The EJ analysis is insufficient in the EPA's own standards. Yet ultimately the standards of
environmental justice today, as thirty years ago, should be responsive to debates and actions in
the public sphere, including proposals emerging from social movements. Our next section
examines in more detail perspectives on environmental justice elaborated by Native peoples.
3. Native American perspectives on environmental justice
Environmental justice scholarship and activism features various assertions of (and mobilizations
against) environmental (injustice in the US from the perspectives of Native peoples, ranging
from industrial pollution and contamination (Johnston, Dawson, and Madsen 2010; Voyles 2015)
to hydroelectric power (Howe and TallBear 2006; Lawson 2009) and oil and natural gas
development (Estes 2014; Allard 2016) to the threats which climate change poses to traditional
food sources and ecosystems (Doerfler, cited in Scheman 2012; Dittmer 2013; Whyte 2017;
Wildcat 2009). Importantly, nearly all Native-led engagements with questions of environmental
justice are grounded in claims and relationships to land, some aspects of which are legally
enshrined by treaties with the US government. Many scholars and activists, including Tsosie
(1996; 2009), Whyte (2013), and various Lakota, Dakota, and otherwise-affiliated Native
individuals who testified during the EPA public comment sessions, have noted that their
communities' complexly reciprocal relationships with the land escape capture by the narrowly
defined terms of federal treaties. Despite this important caveat, treaties remain an important
ground from which Native individuals and communities have articulated their visions for
environmental justice. This emphasis on land, water, and treaty rights extends to Lakota
articulations of environmental justice. Contemporary Lakota concerns with the impacts of
proposed uranium mining activities, including the proposed Dewey-Burdock project, are
grounded in a longer history of negative fallout from and concerted opposition against harmful
mining projects in the Black Hills region.
The Black Hills region was recognized as the land of the Dakota, Nakota, and Lakota peoples of
the 'Great Sioux Nation' in the Fort Laramie treaties signed with the US government in 1851 and
1868. After gold was discovered in the region in 1874, the Act of 1877 was orchestrated to
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provide legal cover for the seizure of the Black Hills by the US federal government, facilitating
the entry of prospecting settlers. In 1980 after years of protracted legal arguments, the US
Supreme Court affirmed that the sale of Black Hills had indeed violated these treaties and
awarded the 'Great Sioux Nation' a settlement of $106 million. Not one nation accepted the
payment, insisting that the sacred region cannot be sold. The settlement, now approaching $1
billion, continues to grow in an interest-earning account (Howe, Soldier, and Lee 2011). Today
home to the mining, logging, ranching, and tourist industries, the Black Hills remains contested,
unceded treaty territory to which Native and non-Native peoples, with very different
understandings of and relationships to the federal government, economic development, and the
land, lay claim. The politics of uranium mining in the region must be understood in this complex
context.
Uranium was discovered in the southern Black Hills region in the 1950s and quickly boomed as
prices rose dramatically with the advent of nuclear power. Much of the arid land in this region
was public land, and prospectors could lodge mineral claims and drill test boreholes with little
investment. As more uranium was found in the region, Edgemont, SD, was chosen for a uranium
processing mill, promising jobs and wealth to local residents. Little regard was given to the lives
of miners and uranium workers, or to those surrounding the operations. Tailings piles were left
uncovered and grew to heights of 50 feet or more. In addition to the daily erosion from wind and
sometimes rain and the communication of water between aquifers allowed by abandoned
boreholes and smaller mines, a number of particular events would impact the region's future
toxicity. In 1962, 200 tons of tailings broke through an earthen dam and washed into
Cottonwood Creek and subsequently the Cheyenne and Missouri Rivers, which provided
drinking water for thousands of people downstream, largely Lakota. But when the uranium boom
was growing, these events were not treated with any particular notice (Grossman 2002, Haider
2002, Jarding 2011, LaDuke and Churchill 1985, Thunder Hawk 2007, Young 1996; on
remaining effects of abandoned uranium mines on the Cheyenne River, see Sharma et. al., 2016).
It wasn't until the 1970s that the health effects of uranium mining began to be noticed by people
in the region. A South Dakota Department of Health study in 1976 already found elevated cancer
rates around Edgemont (Tupper 2015). Downstream on the Pine Ridge reservation, WARN was
conducting the first water tests, which found elevated levels of radioactive elements consistent
with toxicity from uranium mining. It would be more than 25 years before an alternative water
source was finally in place. Throughout the 1980s, WARN, the Black Hills Alliance, Defenders
of the Black Hills, and other Native and non-Native led groups sought to connect treaty rights to
environmental justice in a meaningful way based on their histories of contamination, activism,
and experience with the EPA and other federal institutions as well as private corporations.
Since the initial wave of activism in the 1980s, groups such as Owe Aku and the Black Hills
Clean Water Alliance have been working to amplify both Native and non-Native concerns
related to uranium mining into advocacy for clean water. Just as these groups' organizing and
advocacy strategies are built upon previous iterations of the environmental justice movement in
the Black Hills, so too are their concerns with potential environmental harm from the proposed
Dewey-Burdock project grounded in and made more significant by past and ongoing experiences
of contamination from historic uranium mining activities. The cumulative effects of past uranium
mining, which remain in South Dakotan waterways, bodies, communities today, have been
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6
repeatedly cited by the public as one of the most meaningful reasons that contemporary uranium
mining is seen as an environmental injustice. The lack of understanding of this history of local
and regional environmental justice movements and their connection with the fight for treaty
rights (Ostler 2011) is one of the most troubling aspects of the EPA's draft EJ analysis.
4. Meaningful involvement and consultation
Adequate attention to this history would further require the EPA revisit its existing approach to
meaningful involvement and tribal consultation with regard to the proposed Dewey-Burdock
project. While the EPA docket detailing the draft Class III and Class V permits for the project
contains a draft document detailing plans for compliance with the National Historic Preservation
Act (NHPA), including plans for tribal consultation, these plans do not feature as part of the EJ
analysis, which we strongly feel they should. In this draft NHPA compliance document, the EPA
details its plans to first conduct "inform and educate" sessions with tribes prior to beginning
government-to-government consultation. The EPA notes in this document that after meeting with
Oglala Sioux Tribal leaders, the EPA "was informed that the Tribe considered these meetings to
be "inform and educate" meetings rather than government-to-government consultation." Such a
difference in interpretation cannot characterize a legitimate consultation process, and we are left
wondering why it is that meetings which the EPA considered to be consultative were instead
considered to be informational by the Tribe.
At the public comment sessions in Rapid City on May 8-9, Lakota testifiers reminded the EPA
that those public hearings do not qualify as meaningful tribal consultation. We urge the EPA to
remember this, along with the EPA's own definitions of EJ, articulated in EO 12898 and the EJ
2020 Action Agenda, which state that people, and particularly Indigenous peoples, must
participate, be meaningfully involved in, and indeed influence the direction of decision-making
processes related to environmental justice - not simply have knowledge of those decision-making
processes. We feel that meaningful tribal consultation could result in the EPA adjusting the draft
UIC permits in question as well as the EJ analysis itself, perhaps by expanding its 20-mile buffer
zone of interest around the proposed project site or, for example, implementing a watershed
analysis approach instead.
At the hearings in May, Ms. Valois Shea reassured all those present that the EPA permits in
question would not be issued until the tribal consultation process was completed. We hope the
EPA takes this promise seriously and soon embarks upon a meaningful tribal consultation
process which stands up not just to the standards of Lakota and other Native EJ scholars and
activists, but indeed the stated standards of the EPA itself.
5. Conclusion
Outlined above is a broad understanding of the environmental justice concerns the Dewey-
Burdock raises for two scholars of environmental politics in South Dakota. Our expertise comes
from being students and scholars learning from the individuals and organizations expressing
concerns about the Dewey-Burdock project and from a commitment to do our part in amplifying
and translating these concerns into concepts recognizable to the EPA. We have attempted to
enhance the picture of what environmental justice could look like if the concerns of Lakota and
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7
other tribal communities were properly recognized as part of the permitting process. Our brief
outline is insufficient to be counted as an environmental justice analysis in its own right; we only
seek to highlight the striking absences within the EPA's draft EJ analysis.
With this in mind, we do not see how the proposed permits for the Dewey-Burdock project can
be issued and retain any valence of environmental justice. In addressing some of the problems
highlighted above, the EPA has a chance to set a precedent for working with Native communities
in a manner more consistent with the goal of creating environmental justice.
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8
Works Cited
Allard, LaDonna Bravebull. 2016. "Why the Founder of Standing Rock Sioux Camp Can't Forget the
Whitestone Massacre." Yes! Magazine, September 3, 2016. http://www.vesmagazine.org/neonle-
power/whv-the-founder-of-standing-rock-sioux-camn-cant-forget-the-whitestone-massacre-
20160903.
Dittmer, Kyle. 2013. "Changing Streamflow on Columbia Basin Tribal Lands-Climate Change and
Salmon." Climatic Change 120: 627-41.
Doerfler, Jill. 2003. "Where the food grows on water: The continuance of scientific racism and
colonization." Unpublished manuscript. Cited in Scheman, Naomi. 2012. "Toward a Sustainable
Epistemology." Social Epistemology: A Journal of Knowledge, Culture and Policy 26 (3—4):
471-89.
Environmental Protection Agency. 2016. "Environmental Justice 2020 Action Agenda."
https://www.epa.gov/sites/nroduction/files/2Q 16-
0S/documents/052 2020 strategic plan final O.ndf.
Estes, Nick. 2014. "Declaring War on KXL: Indigenous Peoples Mobilize." National Lawyer's Guild
Mass Dissent. Special Issue: "Environmental Justice and Indigenous Resistance Movements"
37(3).
Grossman, Zoltan. 2002. "Unlikely Alliances: Treaty Conflicts and Environmental Cooperation
Between Native American and Rural White Communities." Ph.D. thesis, Madison: The
University of Wisconsin.
Haider, Bornali. 2002. "Mitaku'oyasin: An Anthropological Exploration of Lakota Sioux
Environmental Activism." Ph.D., Oxford: University of Oxford.
Holifield, Ryan. 2001. "Defining Environmental Justice and Environmental Racism." Urban
Geography 22 (1): 78-90.
Holifield, Ryan, Michael Porter, and Gordon Walker, eds. 2010. Spaces of Environmental Justice.
Chichester, West Sussex, U.K.; Maiden, MA: Wiley-Blackwell.
Howe, Craig and Kim TallBear, eds. 2006. This Stretch of the River: Lakota, Dakota, and Nakota
Responses to the Lewis and Clark Expedition and Bicentennial. Sioux Falls, SD: Pine Hill Press.
Howe, Craig, Lydia Whirlwind Soldier and Lanniko L. Lee, eds. 2011 .He Sapa Woihanble: Black
Hills Dream. St. Paul, MN: Living Justice Press.
Jarding, Lilias Jones. 2011. "Uranium Activities' Impacts on Lakota Territory." Indigenous Policy
Journal 22 (2). http://articles.mdigenoiispolicv.org/mdex.php/ipi7article/view/48.
Johnston, Barbara Rose, Susan Dawson, and Gary Madsen. 2010. "Uranium Mining and Milling:
Navajo Experiences in the American Southwest." In Smith, Sherry L. and Brian Frehner. Indians
& Energy: Exploitation and Opportunity in the American Southwest. Santa Fe, NM: School for
Advanced Research Press.
LaDuke, Winona, and Ward Churchill. 1985. "Native America: The Political Economy of
Radioactive Colonialism." .Journal of Ethnic Studies 13 (3): 107-32.
Lawson, Michael. 2009. Dammed Indians, Revisited: The Continuing History of the Pick-Sloan Plan
and the Missouri River Sioux. Pierre, SD: South Dakota State Historical Society Press.
Ostler, Jeffrey. 2011. The Lakotas and the Black Hills: The Struggle for Sacred Ground. New York:
Penguin Books.
Schlosberg, David. 2009. Defining Environmental Justice: Theories, Movements, and Nature. Oxford
University Press.
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Sharma, Rohit K., Keith D. Putirka, and James J. Stone. 2016. "Stream Sediment Geochemistry of
the Upper Cheyenne River Watershed within the Abandoned Uranium Mining Region of the
Southern Black Hills, South Dakota, USA." Environmental Earth Sciences 75 (9): 823.
Thunder Hawk, Madonna. 2007. "Native Organizing before the Nonprofit Industrial Complex." In
The Revolution Will Not Be Funded: Beyond the Non-Profit Industrial Complex, edited by
INCITE! Women of Color Against Violence, 101-106.
Tsosie, Rebecca. 1996. "Tribal Environmental Policy in an Era of Self-Determination: the Role of
Ethics, Economics, and Traditional Ecological Knowledge." Vermont Law Review 21: 225-333.
Tsosie, Rebecca. 2009. "Climate Change, Sustainability, and Globalization: Charting the Future of
Indigenous Environmental Self-Determination." Environmental & Energy Law & Policy Journal
4(2): 188-255.
Tupper, Seth. 2015. "Rapid City Journal Special Project: Radioactive Legacy." Rapid City Journal,
November 1. http://rapidcitvioimal.com/app/pages/iiraiiiimi/.
Voyles, Traci Brynne. 2015. Wastelanding: Legacies of Uranium Mining in Navajo Country.
Minneapolis, MN: University of Minnesota Press.
Weaver, Jace. 1996. Defending Mother Earth: Native American Perspectives on Environmental
Justice. Maryknoll, NY: Orbis Books.
Whyte, Kyle Powys. 2013. "Justice Forward: Tribes, Climate Adaptation and Responsibility."
Climatic Change 120: 517-30.
Whyte, Kyle Powys. 2017. "Our Ancestors' Dystopia Now: Indigenous Conservation and the
Anthropocene." In Routledge Companion to the Environmental Humanities, edited by Ursula K.
Heise, Jon Christensen, and Michelle Niemann, 206-215. New York, NY: Routledge.
Wildcat, Daniel R. 2009. Red Alert! Saving the Planet with Indigenous Knowledge. Golden, CO:
Fulcrum Publishing.
Young, Iris Marion. 2011. Justice and the Politics of Difference. Princeton University Press.
Young, Phyllis. 1996. "Beyond the Water Line." In Defending Mother Earth: Native American
Perspectives on Environmental Justice, edited by Jace Weaver, 85-98. Maryknoll, NY: Orbis
Books.
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Shea, Valois
Sent: Monday, June 12, 2017 9:36 AM
To: Shea, Valois
Subject: Re: Uranium Mining in the Black Hills
Azarga Uranium should never be allowed to drill hazardous waste injection wells near Edgemont SD. We still have many
sites that have not been cleaned up from previous uranium mining! I strongly urge the EPA to decline Azarga's UIC
permits and aquifer exemption. Thank you for allowing public comments.
Sent from my iPhone
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Shea, Valois
Sent: Monday, May 15, 2017 1:38 PM
To: Shea, Valois
Subject: Black Hills
No dumping uranium on Indian Land!
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Shea, Valois
From:
Sent:
To:
Subject:
Wednesday, May 17, 2017 10:22 AM
Shea, Valois
Say No to Dewey Burdock uranium aquifer mining in the Black Hills of South Dakota
Importance:
High
Valois Shea
U.S. EPA Region 8
8WP-SUI
1595 Wynkoop Street
Denver, Colorado 80202-1129
05-17-2017
Please except my written comments into record regarding the Dewey Burdock uranium aquifer mining project
in South Dakota.
• I am asking for proof that the water gets returned to its original standard or baseline before permitting
new in situ leach uranium operations by foreign corporations. Not just "theories", but proof! It's a fact
- Water at an in situ leach uranium mine has never been returned to its original condition. Foreign
companies benefit, NOT US!
• Don't allow Powertech/Azarga from Canada to treat our homeland water as a scientific experiment for
their monetary gain. In situ leach uranium mining must be done directly in a water-bearing
aquifer. The mining solution is injected into the aquifer under pressure in order to leach the uranium
out of the ground. This is not safe. Our aquifers are not safe.
• Don't allow Cameco/Crow Butte uranium mine to dump their toxic waste into well holes in the Black
Hills punched by Powertech/Azarga. Pollutants that have been left in the water at in situ leach
uranium mines after "restoration" include toxic heavy metals and radioactive materials. This is
dangerous and life threatening to all life forms downstream or downwind.
• Just one proposed mine - the Powertech Uranium project near Edgemont - would consume over two
and a half billion gallons of water during its lifetime. This according to the company's own figures. This
water use is a bad idea for our rural communities that continually suffer from drought.
• PowerTech/Azarga must formally consult under Section 106 of NHPA with First Nations of the 1851
and 1868 Fort Laramie Treaties. The Oglala Sioux Tribe currently stands against, in opposition to
uranium mining in the Black Hills. Indigenous people know it is not worth the risk!
• Uranium mining has a sordid past and present. Current and modern in situ leach mines have spilled
and leaked hundreds of thousands of gallons of contaminated water both above ground and
underground. These leaks have entered both above ground and underground water bodies. Why
would we trust them to clean up future operations? Why would we want to poison our homelands?
Protect our aquifers! Say No to the Dewey Burdock uranium project! No uranium mining in Treaty
Territory! Keep it in the ground! People before Profits!
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Thank you for protecting our environment!
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Shea, Valois
Sent: Tuesday, May 09, 2017 5:41 AM
To: Shea, Valois
Subject: Dewey-Burdock
I, would like to say "NO" to the Dewey Burdock Uranium Aquifer Mining,
thank
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Shea, Valois
Sent: Monday, March 13, 2017 10:51 PM
To: Shea, Valois
Subject: no on exemption from safe drinking water regulations in SD
Dear Shea Valois,
In regards to the below, I am against both the uranium mining and most especially exempting the company from
regulations on safe drinking water. That sounds like a bad idea for public health. Thanks.
Sincerely,
"EPA seeks public comment on draft permits and aquifer exemption for uranium mining project in southwestern South
Dakota"
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Shea, Valois
From:
Sent:
To:
Subject:
Thursday, May 18, 2017 10:15 AM
Shea, Valois
RE: Powertech permits
I'm writing to you today to oppose the issuance of permits to Powertech allowing the drilling of thousands of wells within the 14 different
fields through the aquifer. We don't want disposal wells - - we don't want Uranium miningl There is no part of uranium mining that is life-
sustaining. Uranium mining devastates our land and water. It makes water poisonous for all living beings.
Water is a finite resource - - all the water that is on earth today is all the water that we will have for all of time.
The indigenous communities have treaties to this land. Please honor our shared resources and the sacred treaties.
Our word is our honor.
1
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Shea, Valois
From:
Sent:
To:
Subject:
Sunday, March 12, 2017 8:18 PM
Shea, Valois
Uranium in SD
I absolutely oppose allowing Uranium mining waste disposal in SD aquifer. We must protect our
environment.
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June 19, 2017
Valois Shea (shea.valois@epa.gov^
U.S. EPA Region 8
Mail Code: 8WP-SUI
1595 Wynkoop Street
Denver, Colorado 80202-1129
EPA Regional 8.
Regarding:
Deep Injection Well Area Permits
Dewey-Burdock Uranium In-Situ Recovery Project
Custer and Fall River Counties, South Dakota
Greetings Ms. Shea.
My Name is I am a resident of Rapid City, SD. I am also a enrolled
member of tn^Cneyenn^
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that of Azarga Uranium, and Azarga hold 100% ownership of the Dewey Burdock
uranium project. However, on the EPA's public notice Powertech (USA) Inc. is listed as
the operating company. If ownership has changed, shouldn't Azarga Uranium now be
the "Official Company" in which Azarga would need to go through the official permit
application process from the very beginning?
It is a known fact that several executives of Powertech previously worked with other
uranium companies that were cited for mining violations. One company went bankrupt
and left tons of radioactive mill tailings along the Colorado River in Moab, Utah. That mill
is now a superfund site whose cleanup is funded by your tax dollars. Why should we
trust them to clean up future operations? Is this why they want to send their waste water
deep underground; Out of sight, out of mind?
And what about past mining operations that took place in the Dewey Burdock back in the
1950s, which still have not been cleaned up, or from my understanding are not even part
of the Super Fund Sites. There are over 167 old mines in one area and literally
thousands of old uranium operations have been left unreclaimed in the upper Missouri
River basin. And these modern uranium companies employ people who were involved in
past uranium operations.
The U.S. Geological Survey reported that the Madison and Minnelusa aquifers are vital
water source for Rapid City and the surrounding areas and a uranium mining company
wants to dump uranium waste in the aquifers, which opens that door of nuclear waste
storage in the future, since they would already be dumping their waste fluids. And where
does this mined uranium go? I'm guessing to the highest bidder in some foreign country
like China, Russia, or somewhere unknown? So while they get the revenue, South
Dakotans get the highly toxic wastewater, this is a asinine Idea that will hold
catastrophic results.
I believe it's an outright sacrilege to pollute our water systems for the all mighty dollar.
Let's remember that future generations are counting on us to protect these precious
aquifers and the air. Let's leave a legacy that future generations will be proud of - one
that will keep them healthy - Water Is Life.
Mni Wiconi means WATER IS LIFE.
Thank you,
cirirn public comment letter to EPA Region 8
2
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Shea, Valois
Sent: Sunday, May 14, 2017 7:51 PM
To: Shea, Valois
Subject: [SPAM] Do not allow uranium waste on Lakota land
Ms. Shea,
In March of this year the EPA issued two draft permits to Powertech, a multinational corporation and division
of Azarga Uranium Corporation of Canada. Together these permits would allow the drilling of thousands of
wells within 14 different fields. These wells would bore hundreds of feet into the ground and pierce the Inyan
Kara system, of underground aquifers.
The second of the two permits is to allow the disposal of hazardous waste materials resulting from uranium
mining. Both permits would needlessly expose the Lakota Oyate to the devastation of uranium mining and
continue amcrica's war against Red Nations' peoples,
"The Inyan Kara, Minnelusa, and Madison aquifers are the principal sources of ground water in the northern
Black Hills, South Dakota and Wyoming, and Bear Lodge Mountains, Wyoming... The direction of groundwater
movement is from the outcrop area toward central South Dakota." [USGS Study,
https ://pubs .er.usgs. gov/publication/wri8641581
The proposed authorization would allow uranium waste to endanger Lakota water supplies and must not be
allowed. Please rescind both of these permits.
Thank you,
US citizen
"All perceived problems, challenges and difficulties, are symptoms of wisdom seeking emergence"
— James Priest
covotecreative. net
i
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2
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Shea, Valois
From:
Sent:
To:
Subject:
Sunday, March 12, 2017 8:19 PM
Shea, Valois; McClain-Vanderpool, Lisa
Underground Injection Control (UIC) Area Permits to Powertech (USA) Inc.
I don't know how this could possibly be a good idea. I know that Secretary Pruitt wants to protect business
interests over the environment, but that is not the role of the EPA! The agency was developed to PROTECT
THE ENVIRONMENT.
I'd like to see the science saying this is a good idea and that ground water will not be affected. And if 98% of
scientists say it's fine, I would expect Secretary Pruitt to use the same criteria he uses to evaluate scientific
evidence for climate change to rule against this invasive action!
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Shea, Valois
Sent: Wednesday, May 24, 2017 12:48 PM
To: Shea, Valois
Subject: Dewey-Burdock Uranium ISR
Dear Ms. Shea,
Please accept this communication as a formal comment regarding the proposed two Underground Injection Control (UIC)
Draft Area Permits and one associated proposed aquifer exemption decision for the Dewey-Burdock uranium in-situ recovery
(ISR) site located near Edgemont, South Dakota, under the authority of the Safe Drinking Water Act and UIC program
regulations.
I urge the EPA to deny both of these permits. Among other hazards, radon emissions, toxic heavy metals and other pollutants,
including chloride, sulfate, sodium, radium, arsenic and iron, are in ISR wastewater ponds. Accidents and leaks in this kind of
operation are inevitable, raising concerns about runoff into the Cheyenne River and Angostura Reservoir. As you are aware,
the most serious radiation release in the US came from a tailings pond spill at a uranium mine in New Mexico.
We can live without more uranium but not without clean water and soil.
1
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Shea, Valois
From:
To:
Subject:
Please do not let them contaminate our water by doing this! I am a Wyoming native and this is wrong! Please don't let this happen.
As an enrolled member of the Oglala Lakota nation, I'm asking you to please stop letting big business destroy our resources.
Regards,
Shea, Valois
Powertech and SD and WY drilling
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Shea, Valois
Sent: Sunday, March 12, 2017 8:45 PM
To: Shea, Valois
Subject: South Dakota aquifer exemption
Please do not permit Powertech an exemption to dump uranium into the aquifer system in South
Dakota. Water sources must be protected from contamination.
l
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Shea, Valois
Sent: Monday, March 13, 2017 6:50 AM
To: Shea, Valois
Subject: Aquifer exemption for uranium mining project in SW Dakota
I strenuously object to the exemption requested by the uranium mining company to permit uranium mining waste
disposal in a SD aquifer. Aquifers are pristine sources of water, and contamination cannot be reversed.. The regulations
already in place to prohibit this need to be followed. Our health takes priority over the financial interests of this
company.
Sincerely,
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Shea, Valois
Sent: Thursday, June 08, 2017 11:34 AM
To: Shea, Valois
Subject: Re: Uranium Mining in the Black Hills
Please do not allow uranium mining in our sacred Black Hills!!
-------
Shea, Valois
Sent: Friday, April 07, 2017 4:00 PM
To: Shea, Valois
Subject: Power Tech/Azarga aquifer contamination concerns
Attachments: Our Well report; Well Report, Plat Map and Aerial Map.pdf; Well Report for
Reynars.pdf; Brown Well Report.pdf
Hi Valois,
I write to you regarding my concern for our drinking water supply, which I believe may be in jeopardy if the
Dewey Burdock Uranium project is approved. I am attaching my personal well report along with just a small
sample of others that I am aware of. According to Hollenbeck, Power Tech/Azarga plans on re-injecting the
solution they use to extract uranium, back into the Minnelusa Aquifer. That is were so many of us get our
drinking water and this is unacceptable!! I feel an urgent need to provide you with the link and person who is
my 'go to pro' at the SD DENR to verify and answer any questions you have while trying to determine whether
this project should be allowed. Please do your due diligence and throughly research the aquifer use. Even the
most successful in-situ mining operations have left the water worse than it was before they started and we are
not willing to run any risks with our drinking water! Hollenbeck keeps saying we have nothing to loose, but he
is wrong! Thank you!
the link is
SD DENR Wells Completion Reports
You can contacl^^^^^^H at
SD DENR Wells Completion Reports
For all of your real estate needs!
l
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Shea, Valois
Sent: Monday, April 10, 2017 3:26 PM
To: Shea, Valois
Subject: Re: Power Tech/Azarga aquifer contamination concerns
Thanks soo much! I just spoke to the Hot Springs City Engineer, who said the city of Hot
Springs, as well as many other private wells in this area, get their drinking water from the Minnelusa Aquifer. I
would expect that if Power Tech/Azarga, before being seriously considered for this project, should be
responsible for providing and paying for a baseline water test of the wells that provide drinking water from the
Minnelusa Aquifer. Unfortunately, once the damage is done, there will be nothing that anyone can do to restore
our drinking water to its original purity except to lower the standards for safe levels for the contaminants, as has
been the case where contamination has occurred at other in-situ sites.
Please include this to my written comments regarding this project.
For all of your real estate needs!
From: "Shea, Valois"
Sent: Monday, April 10, 2017 1:36 PM
Subject: RE: Power Tech/Azarga aquifer contamination concerns
Thank you for emailing me your comments on the draft UIC Dewey-Burdock permitting actions. I have added
your email to the list of public comments received. I have also added you to my contact list to keep you
informed on future EPA actions related to the site.
Thanks also for taking the time to send me the well logs from your drinking water well and your neighbors' well
and the link the DENR water well database. This is helpful info.
Here is the link to the EPA UIC program website that contains all the information in the Administrative Record,
in case you do not already have it:
https://www.epa.aov/uic/administrative-record-dewev-burdock-class-iii-and-class-v-iniection-well-draft-area-
permits
The public comment period is in effect through May 19, 2017, in case you have any additional comments after
reviewing this information.
l
-------
Thank you!
Valois
Valois Shea
U.S. EPA Region 8
MailCode: 8WP-SUI
1595 Wynkoop Street
Denver, CO 80202-1129
Fax: (303) 312-6741
Email: shea.valois@epa.aov
From:
Sent: Friday, April 07, 2017 4:00 PM
To: Shea, Valois
Subject: Power Tech/Azarga aquifer contamination concerns
Hi Valois,
I write to you regarding my concern for our drinking water supply, which I believe may be in jeopardy
if the Dewey Burdock Uranium project is approved. I am attaching my personal well report along with
just a small sample of others that I am aware of. According to Hollenbeck, Power Tech/Azarga plans
on re-injecting the solution they use to extract uranium, back into the Minnelusa Aquifer. That is were
so many of us get our drinking water and this is unacceptable!! I feel an urgent need to provide you
with the link and person who is my 'go to pro' at the SD DENR to verify and answer any questions you
have while trying to determine whether this project should be allowed. Please do your due diligence
and throughly research the aquifer use. Even the most successful in-situ mining operations have left
the water worse than it was before they started and we are not willing to run any risks with our
drinking water! Hollenbeck keeps saying we have nothing to loose, but he is wrong! Thank you!
the link is
SD DENR Wells Completion Reports
You can contact at
SD DENR Wells Completion Reports
For all of your real estate needs!
2
-------
3
-------
Shea, Valois
From:
Sent:
To:
Subject:
Attachments:
Tuesday, May 09, 2017 5:14 PM
Shea, Valois
Fw: Well Log Data for Fall River County SD
WellLogsSearch_20170509023905.csv; State Veterans Home Well Report.pdf
Hi Valois,
Here are only a few of the Fall River County Well Reports that were recorded in Pierre, SD. This is only a list
of the domestic wells and does not include municipal wells. I have not had enough time to thoroughly analyze
the reports, but I can assure you that The Minnelusa aquifer provides water to this region and cannot be
jeopardized by injecting waste water from the in-situ mining process. I am also attaching the well report for our
new State Veterans Home, which is also in the Minnelusa aquifer. We cannot allow anyone to jeopardize our
water supply by injecting anything into our aquifers or by depleting our, already limited supply, of water for this
process. Our water is finite and must be protected!
Renewable energy is making nuclear power obsolete. The price of uranium is already going down and will
continue to do so. It is not worth taking any risk knowing that these companies will eventually fold and ride off
into the sunset as, is typically the case, leaving the locals with their mess. There is no amount of money that can
be held to restore what we currently have when that happens....it's just a matter of time.
As you probably know, Edgemont became a super fund clean up site and the tailing were eventually buried,
however, there still remain old mines that have not been reclaimed to this day, They continually jeopardize our
ground water and there are no plans to reclaim those sites after all of these years. How can the EPA even begin
to consider another uranium mining project without ensuring that land be reclaimed from the previous fiasco?
I lived in Edgemont in the 1980s while the tailings pile was still on the edge of town. From my home on a hill,
overlooking town, I would regularly see the cloud of tailings blow into town. I called the State of SD to report it
and they referred me to the Denver office of the EPA, to a gentleman named Mike Hammer. I explained the
problem, He said that the tailings pile should have at least a 3 in. cover of top soil and be hosed down regularly
to keep it from blowing around. He went on to empathize that our State of SD has very lax environmental
oversight when it came to protecting the environment and that there was nothing the EPA could do. I called the
mill and spoke to an employee to see if, in fact, they were following the guidelines to keep the tailings from
blowing into town. He laughed at me and said that, "the tailings were all over his desk and that the mill was
literally getting away with murder". He went on to explain that no one ever checked to make sure they were
doing things that they knew they were required to do. I was horrified and began the process of moving out of
town. No one has been able to ensure that our water and air are protected and I expect that will only get worse
with this new administration.
They claim that In-situ mining is safe, there is no safe, clean in-situ mining. Crawford, NE had violations that
were discovered by their State oversight.We can assume, from past experience, that our State of SD will not be
actively involved with monitoring this project. By the time we realize there is a problem, it will be too late.
The water will never be returned to its current state. The EPA standards are merely lowered to make it OK once
the water is contaminated. I understand that the EPA is already proposing to exempt the portion of the Inyan
Kara aquifer in the project area from the Safe Drinking Water Act, something that is necessary for mining to
occur!!!!!!!!!!
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If the EPA decides to grant these permits, they will be responsible for the outcome. There will be no way to
restore
or replenish our water supply and that will be a sin.
For all of your real estate needs!
— Forwarded Message —
From:
Sent: Tuesday, May 9, 2017 1:39 PM
Subject: Well Log Data
The attached file contains data generated from the South Dakota Dept. of Environment and Natural
Resource's Well Logs Database.
2
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Shea, Valois
Sent: Wednesday, May 17, 2017 12:33 PM
To: Shea, Valois
Subject: Articles on the seismic testing south of the proposed Dewey Burdock Project
Hi Valois,
Thank you again for taking the time to hear our concerns for the Dewey Burdock project on our water last
week.
As you may already know, we just learned that there is probably going to be seismic testing south of the Dewey
Burdock site. These articles are timely and I believe they may be critical to the future of the Dewey Burdock
project as well as the old mining sites that still remain a threat to our water and the buried weapons at Igloo.
Realizing there are faults in this region, we, the residents of the Black Hills, are even more concerned with this
new realization that seismic testing and perhaps eventual fracking will take place on and near the former army
depot site at Igloo!!!!!!!!!!!!! God Help us!!!!!!!!!
It is common for Cascade Spring to flow red as a result of previous seismic tests, heavy machines working
miles away, not to mention unknown causes for this phenomena. IT IS A DELICATE ENVIRONMENT AND
WHAT HAPPENS IN A GIVEN AREA HAS AN IMPACT MILES AWAY! I cannot imagine what effect
these seismic tests and/or the effect of eventual fracking may have on the Dewey Burdock site even with the
best attempts at confining the toxins they will be disturbing, creating and re-injecting into the earth and our
water supply, which is a bad idea without the additional issues created by the seismic testing at Igloo!!!!!
Please educate yourselves on the future plans for seismic testing in this hazardous area and its possible effect on
the Dewey Burdock Project!!!! The results may be catastrophic! I sincerely pray that the EPA will protect us
because there will be no way to clean up the possible devastation and/or to restore what we now have. Thank
you!
rapidcityjournal.com/news/local/seismic crews want to.,
rapidcityjournal.com/news/local/communitics/hot-springs/..
rapidcityjoumal.com/news/local/communities/hot-springs/...
rapidcityjournal.com/news/local/communities/hot-springs/...
rapidcityjoumal.com/news/south-dakota-oil-reserves..
rapidcityjoumal.com/former-army-depot-site-for...
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Shea, Valois
From:
Sent:
To:
Subject:
Monday, June 19, 2017 4:42 PM
Shea, Valois
Uranium mine permits and exemption -public comment re: Dewey Burdock and Region
8
Dear EPA officials,
As a citizen of South Dakota, a former scientist in the area of cell biology, a medical health professional, and more
recently a mother of five young adults, I beg you to think beyond corporate business interests, and other parties who
hope to benefit financially from the two Underground Injection Control Area Draft Permits and the aquifer exemptions
in Region 8. The Dewey-Burdock uranium in-situ recovery (ISR) site located near Edgemont, South Dakota, is requesting
an exemption from the authority of the Safe Drinking Water Act and UIC program regulations. The Dewey-Burdock site is
located in southwestern Custer County and northwestern Fall River County, on the Wyoming/South Dakota border.
I hope that you will strongly consider the facts being presented by the opposition to these permits and exemption,
especially as they contain the contamination risk to the region's most valuable resource: water. As an area not
unfamiliar to drought, our water is our gold, our life. The risk, even if infinitesimal per the so-called experts, is not worth
the benefit, which to date, has been under much debate that I need not reiterate.
Radioactive contamination of our water would not be able to be contained in an aquifer that has nondescript
boundaries. That is more than obvious! And the half life of the contaminants is much longer than anyone today should
consider acceptable. History has proven this fact.
Enact the will of the majority of people, for your children, and your grandchildren, and leave our earth below the
surface, the one that contains the roots of all grasses and all plants, that all livestock depend on, alone, AND refuse ANY
exemptions to guarantee our permanent source of clean non-radioactive water.
You hold a very, very, important power in your hands. It is more important than nuclear power, believe it or not. Please,
do not abuse it. Hear us today, as tomorrow's voice will be drowned out by dollars.
We are carefully taking note of the listening capability of your organization, the EPA, that claims to "protect" the people
of this fair country.
Respectfully yours,
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Shea, Valois
From:
Sent:
To:
Subject:
Sunday, April 09, 2017 7:26 PM
Shea, Valois
In situ leach mining, Black Hills
Hello. I am writing to express my opposition to the Underground Injection Control (UIC) Draft Area Permits
and one associated proposed aquifer exemption decision for the Dewey-Burdock uranium in-situ recovery
(ISR) site located near Edgemont, South Dakota.
These aquifers belong by treaty to the Lakota Sioux people, who have been working toward the return of their
ancestral lands. It is a matter of moral outrage that the lands were taken to begin with; poisoning the water
there with mining waste which is inevitably left after "restoration" is unacceptable.
Thank you for your time and attention to this matter.
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Shea, Valois
From:
Sent:
To:
Subject:
Monday, April 03, 2017 4:26 AM
Shea, Valois
Oppose allowing injection of hazardous mining waste into Black Hills
The Hong Kong/China based uranium milling company, Powertech/Azarga that has been pursuing ISL (in situ
leach recovery) milling permits in the Dewey-Burdock, Edgemomt area of the Black Hills, is currently
requesting permits from the EPA for waivers from the Clean Water Act for the Inyan Kara aquifer in order to
implement IJIC injection wells for milling, and for hazardous waste permanent deposition, from mining activity
in the Minnelusa. aquifer.
Pleas T
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Shea, Valois
From:
Sent:
To:
Subject:
Sunday, May 14, 2017 10:13 PM
Shea, Valois
OPPOSE Dewey-Burdock Uranium Mine project
To Whom It May Concern:
I am writing to voice my opposition to the Dewey-Burdck Uranium Mine project in the Black Hills, South
Dakota. This project is harmful and destructive to the land, the Lakota people, and all other people who live in
the Black Hills area and depend on the aquifer. Clean freshwater is essential for ALL people, and this mining
project would likely contaminate this resource for not only the Lakota but EVERYONE in the vicinity. Please
DO NOT allow this mining project to proceed. Thank you for your consideration.
Sincerely,
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Shea, Valois
From:
Sent:
To:
Subject:
Monday, June 19, 2017 8:17 AM
Shea, Valois
Uranium from the Black Hills
I urge you to reject the plan to mine Uranium in the Black Hills. Please protect the Hills and the aquifer below
them. Respect the Treaties.
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Shea, Valois
From:
Sent:
To:
Subject:
Monday, June 12, 2017 10:27 AM
Shea, Valois
Uranium mining permit for Powertech/Azarga
Dear Valois Shea,
Yesterday I saw this article in our local newspaper. So, I wanted to give you the link, thus the email.
http://rapidcitviournal.com/news/local/ranchers-face-tough-decisions-as-dakotas-remain-mired-in-
drought/article c43f5807-2b32-5alc-82be-
Idf586c745d2.html#utm source=rapidcitviournal.com&utm campaign=%2Femail-updates%2Fdailv-
headlines%2F&utm medium=email&utm content=2D51DBl 195DBB4FF137F8663195C78196DEF84B9
I wanted you to have a better understanding of why our water resources in South Dakota are so very important.
Ranching and farming are our number one economic source. Along with Tourism, which is number two. Our
economy suffers greatly when our agriculture operations are compromised. I have lived here for 15 years and
many of those years have been during droughts. Stock dams dry up, wells need to be dug deeper, many into
deep aquifers, or water must be hauled.
We cannot afford to take a chance on contaminating our water resources and we certainly cannot afford to give
away 9,000 gallons of water per minute through 4,000 wells to mine uranium for ten years. That's equivalent to
the water used by the second largest town in South Dakota, Rapid City. To give away that water is just down
right criminal. Even if it wasn't contaminated.
I want to share this local article with you also:
http://rapidcitvjournal.com/news/opinion/forum-coming-to-south-dakota-bring-vour-own-drinking-
water/article 4d2d4783-6635-5bl8-8c0d-b07229e1 dda8.html
Not only would ranchers suffer, but the second economic source is Tourism. If the perception of tourists is,"
that it's not safe to go there." They will take their vacations somewhere that hasn't been compromised.
We have a healthy real estate market in the Black Hills as well. If the water in the Angostura Recreation Area is
compromised more than it already has been, due to run off from old mines. Those people would stand to loose
all they invested. They would end up with real estate prices, like you find in Edgemont. Not to mention the
health risks.
It just doesn't make economic sense to risk so much water. Especially in an area that suffers from extreme
droughts.
I hope the EPA uses their common sense to tell Powertech/Azarga that it cannot allow this operation to happen,
it cannot take the risk for the extraction of uranium, and all the other harmful elements it extracts with it. The
recovery rate is NOT 100%, so pumping this contamination down into lower aquifers only gives the company
time to make their money and leave the mess for others to deal with, if they can. Contaminating a whole area of
South Dakota, and risking severe health risks to innocent people is again criminal. With the price of uranium
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now, it's just not worth the risk. Hopefully the price of uranium drops to below $10 a lb. because the
technology for renewables exceeds nuclear power. Which is headed in this direction.
Sincerely,
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Shea, Valois
Sent: Monday, March 13, 2017 6:55 AM
To: Shea, Valois
Subject: Uranium waste disposal
My opinion - NO, Never this shouldn't even be a question. At what point would you think that an element that renders
large swaths of land unlivable (plenty of examples to research) would be okay to dump into an underground aquifer
where most people are probably living on well water.
Just to reiterate my answer is NO
Sent from my iPhone
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Shea, Valois
From:
Sent:
To:
Subject:
Sunday, June 18, 2017 4:15 PM
Shea, Valois
Dewey Burdock Uranium Aquifer
Territories governed by treaty should be protected from exploitation of people and resource. The uranium mining above
an aquifer under their promised tribal lands does that. This would put the country in violation of international law, and
our own Constitution. It could open a state or the country as a whole to sanctions by governing bodies. Also consumer
boycotts of great expense and exorbitant legal challenges that will get my consideration for support. Hope the next time
we communicate not prior notice. Thanks,
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Shea, Valois
From:
Sent:
To:
Subject:
Tuesday, March 14, 2017 10:33 AM
Shea, Valois
Draft Permits for UIC
Dear Valois,
I am writing to you as a concerned American regarding the proposed Draft Permits to allow UIC a permit for
injection wells for the in-situ recovery of uranium in the Inyan Kara Group aquifers and a permit for deep
injection wells that would be used to dispose waste fluids into the Minnelusa Formation below the Inyan Kara
after treatment.
As we have seen in the past, while all precautions claim to be taken, what happens when the monitoring of
the underground sources of drinking water become contaminated? It's too late then.
Also with regards to the aquifer exemption of uranium-bearing portions from the Safe Drinking Water Act. I
am trying to figure out what good can be gained from this exclusion?
I am respectfully requesting that the EPA, in its infinite wisdom not grant these permits or exemptions. The
Safe Drinking Water Act was put in place for a reason. Our future depends on the actions of the present.
Thank you for letting my voice be counted.
Best
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Shea, Valois
Sent: Tuesday, March 14, 2017 5:42 PM
To: Shea, Valois
Subject: Protect Out Aquifers!
Please do not provide an exemption for the uranium mining project in South Dakota. Aquifers are a water
resource that many rely on for clean water. Protect the aquifer!
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Shea, Valois
Sent: Tuesday, May 16, 2017 10:22 PM
To: Shea, Valois
Subject: Powertech Uranium
Dear Mends at the EPA,
I understand that you are seeking public comment on a project where uranium could be used on Lakota lands.
As a citizen, my comments is please, please, no. This seems an egregious betrayal of too many treaties and
against the common good of both Lakota nation and United States citizens. This project seems as if it could
endanger important aquifers that supply water.
Thank you for you time,
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Shea, Valois
From:
Sent:
To:
Subject:
Please don't destroy the aquifer in South Dakota with uranium mining waste disposal.
Thanks,
Sunday, March 12, 2017 8:43 PM
Shea, Valois
Uranium mining in South Dakota
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Shea, Valois
Sent: Monday, March 13, 2017 1:56 PM
To: Shea, Valois
Subject: Uranium Mining Waste Disposal
Shea,
Are you people out of your goddamn minds? No it is not okay to dump that kind of waste into an aquifer that
people use to wash their clothes, cook their food, brush their teeth and serve to their families.
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Shea, Valois
Sent: Wednesday, March 15, 2017 8:35 AM
To: Shea, Valois
Subject: Aquifers
Please do not allow the aquifers to be injected with this waste. We cannot continue to contaminate
resources needed for our survival.
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Shea, Valois
From:
Sent:
To:
Subject:
Thursday, March 16, 2017 9:42 AM
Shea, Valois
UIC Permits for Edgemont, South Dakota
Dear Ms. Shea,
Please accept this communication as a formal comment regarding the proposed two Underground Injection Control (UIC) Draft
Area Permits and one associated proposed aquifer exemption decision for the Dewey-Burdock uranium in-situ
recovery (ISR) site located near Edgemont, South Dakota, under the authority of the Safe Drinking Water Act and UIC
program regulations.
I urge the EPA to deny both of these permits. Among other hazards, radon emissions, toxic heavy metals and other pollutants,
including chloride, sulfate, sodium, radium, arsenic and iron, are in ISR wastewater ponds. Accidents and leaks in this kind of
operation are inevitable, raising concerns about runoff into the Cheyenne River and Angostura Reservoir. As you are aware, the
most serious radiation release in the US came from a tailings pond spill at a uranium mine in New Mexico.
We can live without uranium but not without clean water and soil.
Best regards,
1
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Shea, Valois
From:
Sent:
To:
Subject:
Tuesday, June 06, 2017 11:37 AM
Shea, Valois
Uranium Mining and Disposal Permit in Black Hills
to know that our precious aquifers are being considered as a source for uranium mining and subsequent
contaminated waste water disposal. My well accesses the drinking water for my family, friends and livestock
from the Minnelusa, the same formation being targeted for the deep disposal injection wells.
I find it appalling that anyone would approve disposal of waste from uranium mining activity into a potable
water source for this area. In addition, the Minnelusa sits above the Madison aquifer, a major source of
drinking water for many communities, therefore, hundreds of thousands of people in western South Dakota and
eastern Wyoming. Since the Black Hills were formed from an uplifting of the earth, no one can guarantee that
each aquifer is isolated from the one below it. Fissures are known to exist that would allow transfer of water,
and in this case, contaminates, to move freely to other aquifers.
As stated in South Dakota Department of Environment and Natural Resources water regulation, the water
belongs to the residents of this state. It would be a travesty for an outside agency to determine that it is alright
for a foreign corporation to not only have access to a huge amount of our water for free but also be able to
inject their waste stream back into our potable water.
I totally disapprove of in situ mining. However, if you are to go forward with approval, I highly encourage you to
only authorize disposal into the Deadwood formation below the Madison aquifer to minimize any risk to our
water supply.
As a side note, please consider that this is a foreign corporation making this request to mine our uranium and
highly likely to pollute our water. They can make grandiose claims that their process is safe and their practices
are sound, however this company has never performed in situ mining. I'm very skeptical of their true intentions
and personally expect them to sell the entire operation once all the required permits are obtained. The
Russians have already obtained ownership of 20 percent of this country's uranium. I would hate to see any
more of our uranium fall into foreign hands. Additionally, too many companies grab what they want of our
resources, then leave a polluted mess, which falls on the tax payers to finance the cleanup, if it is even
possible.
Respectfully,
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Get Outlook for Android
2
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Letter to the Editor
Tell the EPA to deny permits to pollute Black Hills water
It is dismaying that our precious aquifers are being considered for uranium mining and waste water
disposal. My well accesses the drinking water for my family, friends and livestock from the Minnelusa,
the same formation targeted for injecting the waste.
It appalls me that anyone would approve disposal of waste from uranium mining in our potable water
source. Since the Black Hills were formed from an earth uplift, nothing guarantees that each aquifer is
isolated. Known fissures could allow water and contaminants to move freely between aquifers.
It would be a travesty for an outside agency to decide that a foreign corporation can come in and pollute
our supply. South Dakota regulations declare the water belongs to the residents of this state.
The company has never even performed this kind of mining. I expect them to sell the entire operation
once all the permits are obtained. The Russians already own 20% of this country's uranium. I would
hate to see more of it fall into foreign hands.
The company has never even performed this kind of mining. I expect them to sell the operation once
the permits are obtained. The Russians already own 20% of this country's uranium. I would hate to see
more of it fall into foreign hands.
Too many companies grab our resources, then leave a mess for tax payers to try and clean up. If you
agree, tell the EPA to deny water permits for Azarga Uranium Corp. by June 19 at
shea.valois@epa.govSincerely,
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Shea, Valois
Sent: Tuesday, May 16, 2017 2:59 PM
To: Shea, Valois
Subject: Business
Hello, my name is^^B anc' ' m Just curi°us as to why you think it's a good idea to store uranium on American Indian
lands. One it's against the treaty's and 2 it's just plain wrong. Besides the history and the usual blah blah blah tell me
why you think it's a good idea? I know it's awful for the environment, I know it can ruin people's lives, So is money the
main push here because if it is I ask you to reconsider the actual facts not just what some government official tells you.
Please reconsider may 19 to never. I mean this in the most peaceful polite way. All I ask is you research true facts! When
you find those "true facts" dig deeper please think for yourself? What did you want to be as a kid? A government EPA
official who destroys the world? No, im sure you saw trash and wanted to help the environment well now you are just
plain destroying it. Please shut the whole operation down. Thank you I Peace love and light to you. V •
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Shea, Valois
Sent: Wednesday, March 15, 2017 8:29 PM
To: Shea, Valois
Subject: Public comment for draft permits and aquifer exemption for uranium mining project in
southwestern South Dakota
I oppose both permits related to the proposed uranium recovery project in the southern Black Hills
region in Custer and Fall River. Injection wells for disposing of waste fluids into aquifers is a
bad idea be it trested or not. How much control or manpower is available to oversee that the
injections do not include toxic chemicals being purged into our precious water supply. The
companies that dispose this way have not been overly forthright in listing the chemicals that
are used in their processes. Slow moving aquifers would not be able to cleanse toxics for
decades or more endangering those that rely on the water for life.
Removing these aquifers from the safe drinking water act just exasperates the problem. We
need more safe water not less. Sincerely,
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Shea, Valois
From:
Sent:
To:
Subject:
Tuesday, March 14, 2017 6:09 PM
Shea, Valois
Uranium Mining in SD
Hello, please enter my formal comments as NO! I do not think it's ok for mining waste to be injected into
underground aquifer's.
https://www.epa.gov/newsreleases/epa-seeks-public-comment-draft-permits-and-aquifer-exemption-uranium-
mining-proiect
Thank you.
0!
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Shea, Valois
Sent: Tuesday, March 14, 2017 7:57 AM
To: Shea, Valois
Subject: Inyan Kara Aquifers
I would like to comment on exemption request to inject uranium-bearing waste water into
Inyan Kara Group aquifers from protection under the Safe Drinking Water Act. I object and
wonder how can this even be considered. What in the world is gong on with EPAULETS to
even consider this.
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Shea, Valois
From:
Sent:
To:
Subject:
Tuesday, May 16, 2017 2:47 PM
Shea, Valois
Black Hills Uranium Mining
Dear Valois
I have read that I can email comments about the EPA's plan to allow Azarga/Powertech to mine Uranium
near the Black Hills of SD to you such that they will be considered during the approval process.
While serving in the Air Force many years ago, I worked in a radio lab collecting and detecting information
on who was doing what around the world as far as developing nuclear arms. It was exciting
and fascinating work. While I understand that this proposed mine would be to gather material for peaceful
means, it is painfully obvious to me that doing so puts clean water at risk. Furthermore, permitting
a foreign company a permit to ship in and inject waste material from other places is totally unacceptable.
Later in my career with the Forest Service part of my duties were to survey and catalog the many
abandon mines around the area. It is obvious that mining companies care little about what
they pollute and what they leave behind. The EPA nor any other governmental agency seems to be able
to protect the American citizens from mining companies. When all the old mines and dumps are cleaned
up and programs to monitor and enforce rules agains the mining companies such that the companies and
their share holders can be held responsible for what they destroy, I maybe can understand a time when
we could consider such actions, but that time has never happened yet and seems to be a long ways off
before we get there.
I am very against the proposed Uranium mining and disposal of waste in this area. I do not feel
that government currently has the power to protect the American people and our unrecoverable resources
such as fresh water.
I hope that the EPA will do all it can to deny any and all proposed Uranium mining and waste disposal
projects that would affect such aquifers as the Inyan Kara and the Minnelusa or any other water source. I
value clean water more then off shore profits of off shore mining companies. Politicians may be swayed
by payoffs and the promises of jobs in the area, but I expect the EPA to decline these permits because
they clearly cannot monitor them therefor should not allow them to proceed.
If the waste that is to be pumped into the Minnelusa aquifer is so safe, let the owners and shareholders
of Azarga/Powertech pump it into the ground in their own backyard for their children to enjoy.
Sincerely,
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Shea, Valois
Monday, March 13, 2017 10:29 PM
Shea, Valois
re aquifer exemption for uranium mining project
Hi,
No. Just, no.
Thanks,
From:
Sent:
To:
Subject:
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Shea, Valois
From:
Sent:
To:
Subject:
Tuesday, March 14, 2017 2:54 PM
Shea, Valois
permits and aquifer exemption for uranium mining
I am writing in regards to the draft permits and aquifer exemption for uranium mining project in South Dakota
(https://www.epa.gov/newsreleases/epa-seeks-public-comment-draft-permits-and-aquifer-exemption-uranium-
mining-project')
Clean and safe drinking water need to be the preeminent concerns. The proposed mining could do irreparable
harm to the drinking water and should not be granted an exemption.
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Shea, Valois
From:
Sent:
To:
Subject:
Tuesday, March 14, 2017 8:27 AM
Shea, Valois
Opposition to Powertech Aquifer Exemption
Hello,
I'm sure your inbox has been inundated since the story went on twitter, so I'll keep this brief.
I am a citizen of the United States and the State of California. I feel that drinking water is going to grow
significantly in importance in the near future, so I oppose any measures that threaten the safety and cleanliness
of said water. I request that you deny any aquifer exemptions requested by Powertech.
Thank you for your time.
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Shea, Valois
Sent: Saturday, March 18, 2017 5:16 PM
To: Shea, Valois
Subject: No Mining
There should not be any mining in the Black Hills. US Treaty clearly states this is Native land. A Sovereign
Nation,
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Shea, Valois
From:
Sent:
To:
Subject:
Friday, March 17, 2017 8:09 AM
Shea, Valois
No uranium permits please!
Dear Ms. Shea,
Please accept this email as a formal comment regarding the proposed two Underground Injection Control
(UIC) Draft Area Permits and one associated proposed aquifer exemption decision for the Dewey-
Burdock uranium in-situ recovery (ISR) site located near Edgemont, South Dakota, under the
authority of the Safe Drinking Water Act and UIC program regulations.
I urge the EPA to deny both of these permits. Among other hazards, radon emissions, toxic heavy metals and
other pollutants, including chloride, sulfate, sodium, radium, arsenic and iron, are in ISR wastewater ponds.
Accidents and leaks in this kind of operation are inevitable, raising concerns about runoff into the Cheyenne
River and Angostura Reservoir. As you are aware, the most serious radiation release in the US came from a
tailings pond spill at a uranium mine in New Mexico.
We can live without uranium but not without clean water and soil.
Best regards,
-------
Shea, Valois
From:
Sent:
To:
Subject:
Friday, May 19, 2017 9:02 PM
Shea, Valois
Dewey Burdock Azarga Project Permitting
Dear Ms. shea,
As a former council woman for the city of Hot Springs, and as a current resident of Fall River County, I strongly oppose anything
that would pose potential harm to our water. Insitu mining of uranium and the depositing of toxic mining waste into our aquifers and
ground would contaminate our water.
Furthermore the NRC ordered Powertec Azarga company to plug the more than 7600 test drilling bore holes in Fall River and
Custer counties. This was ordered two years ago and not one hole has been filled.
Having attended the state of South Dakota tourism meetings, we in hot springs in Fall River County have more to offer in tourism
than any other part of the Black Hills. Hot Springs was the only city in the Black Hills that got its start in tourism rather than mining as
in the other cities.
We have great possibilities for being an extensive organic farming and ranching area. A few years ago the city of Hot Springs
purchased Evans Plunge, a world-famous natural spring mineral water pool. The city has invested millions. The Evans Plunge would
being damaged beyond use if the powertec Azarga permits would be given. This area would be unfit to live in due to the fact of having
unsafe water quality for human, livestock and farming purposes. I say start up a Superfund Site in the Dewey Burdock site instead.
Thank you,
1
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Shea, Valois
Sent: Sunday, March 12, 2017 10:46 AM
To: Shea, Valois
Subject: Drilling for drinking water
If accessing this water will be for profit then you will just be adding to the stresses of mankind.
If you get it done in a not for profit manner i can agree with it, otherwise my answer will be no
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Shea, Valois
Sent: Monday, June 19, 2017 11:01 AM
To: Shea, Valois
Subject: No uranium
Please no uranium in the Black Hills . They have the most pristine aquifers in the world . We can't afford to kill them
it's not right! This is treaty territory for our natives and it's against treaties to destroy this area for uranium.
Sent from my iPhone
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Shea, Valois
Sent: Thursday, June 15, 2017 3:48 PM
To: Shea, Valois
Subject: Uranium mining in Edgemont South Dakota
I am totally against uranium mining is Edgemont, South Dakota. I live in Hot Springs, Sd and have a well that services my house, my
livestock, and my business which is a campground.
If water is allowed to be reinjected back into the ground there is a very good chance my water will be contaminated and unusable. I
beg you to not allow any uranium mining in Fall River County in South Dakota. If any used water from mining is allowed to be
spread on the surface of the ground it is my understanding that hazardous waste will be left behind that will be blown up into the air as
dust and will contaminate our air.
I do not want our land and water contaminated by anyone, much less a foreign company which absolutely cannot guarantee that this
will not happen. The aquifers here can all be connected by cracks and splits and no one has any idea what really goes on underground.
Thank you,
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Shea, Valois
Sent: Tuesday, March 14, 2017 6:32 PM
To: Shea, Valois
Subject: quifer exemption for uranium mining project in southwestern South Dakota
I find this shocking. No, the uranium bearing portions of the Inyan Kara Group aquifers SHOULD NOT BE
EXEMPT from protection under the Safe Drinking Water Act.
What in the world is going on? Please, do your job and protect our drinking water.
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Shea, Valois
From:
Sent:
To:
Subject:
Wednesday, May 17, 2017 10:28 AM
Shea, Valois
My comments on Uranium mining in the Black Hills.
Dear EPA, Region 8:
Here are my comments on the Underground Injection Control Program's Draft Permits for the Proposed
Dewey-Burdock Uranium Mine and Deep Disposal Wells:
"The Madison and Minnelusa aquifers are two of the most important aquifers in the Black Hills area because of
utilization for water supplies and important influences on surface-water resources resulting from large springs
and stream-flow-loss zones." - United States Geological Survey: Geochemistry of the Madison and Minnelusa
Aquifers in the Black Hills Area, South Dakota
It will be impossible to adequately oversee the quality of liquid wastes pumped into the Minnelusa Formation
through the proposed deep disposal wells, our groundwater is likely to be irreversibly contaminated. There are
well documented faults, fractures, breccia pipes, and over 7000 old boreholes that have not been properly
plugged in the area of proposed mine and deep disposal wells. It will be impossible to contain mining fluids or
waste liquids, contamination of our groundwater is highly likely.
The history of uranium mining indicates that uranium mining cannot be done without creating and leaving
contamination. This project should be stopped until it can be proved to be safe, rather than relying on
imperfect protection and clean-up processes.
As an RN, I find the health issues related to the risks exposure of uranium contamination at any level are
deeply concerning. Even one death or illness as a result of uranium mining is totally unacceptable.
The Black Hills are a semi arid area prone to regular drought. The vast quantities of ground water needed for
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the mining and the potential for contamination are unacceptable. Aquifers are not replenished overnight.
Water IS life! Please do not risk it just for money.
We do not inherit the earth from our ancestors, we borrow it from our children and our grandchildren. Let us
leave the Black Hills as a safe, enduring, beautiful area for those who follow us without risk of contamination in
our water supply. Once this contamination is present, it can never be removed. The purity of our water can
never be resolved. Is this to be our legacy to our children and our grandchildren?
Sincerely,
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Shea, Valois
From:
Sent:
To:
Subject:
Monday, June 19, 2017 10:18 PM
Shea, Valois
NO to Uranium MINE
Please, please consider NOT ALLOWING a Chinese owned company to come into our state, mine out the uranium, take
it to China to perhaps use against the Americans, and then contaminate our water in South Dakota. Can't imagine what
you are thinking to even consider this. I was raised in South Dakota and I love this state. Don't give it to a foreign
government!!!!!!!!!!!!!!!. Our people are worth more than money. Hopefully this isn't about some corruption. Vote
NO to uranium mining by a foreign owner. Only look to what happened to the gold mining near Lead S.D. A Canadian
company defaulted and left the people of S.D. to pay for clean-up. Please think smart. Thank you.
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Shea, Valois
Sent: Friday, March 17, 2017 6:12 PM
To: Shea, Valois
Subject: NO to Uranium Mining
Uranium mining of the Black Hills is not only an assault on Native
sovereignty over a religious, cultural, and historic site for many
Nations, but uranium mining is an environmental disaster itself, even
if it all goes as intended.
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Shea, Valois
Sent: Tuesday, May 09, 2017 10:52 PM
To: Shea, Valois
Subject: Comment on Dewey-Burdock Class III and V Injection Wells
I voice strong opposition to this uranium mining project. As a private landowner I incur extra expense to
comply with strict septic regulations that protect our water sources in the Black Hills. Our homeowners
association encourages water conservation for the longevity of our well source. But I understand the premise -
clean water is that vital - and such a basic right. And all this effort by state and local governments to protect
water sources could be negated quickly and tragically if the federal government permits PowerTech to proceed
with this project. Please don't allow it to proceed. Thank you for the opportunity to comment.
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Shea, Valois
From:
Sent:
To:
Subject:
Thursday, March 09, 2017 9:57 AM
Shea, Valois
Comments for the record: Dewey-Burdock / Application for ISR and UIC permits
Comments for the record:
It is time to stop injecting poisons into our earth for the sole purpose of a business venture to extract minerals for profits.
The future cost of poisoning aquifers is beyond calculation.
Once injected, those poisons are at the mercy of geologic forces which humans cannot control and will eventually
contaminate clean water.
The benefit to one business enterprise is simply not the risk to the human race, the plants, the animals, the water and the
air.
No method of containment can insure protection.
The simple answer is "NO MORE POISON SHALL BE INECTED INTO THE EARTH."
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Shea, Valois
From:
Sent:
To:
Subject:
Tuesday, March 07, 2017 7:44 AM
Shea, Valois
Comment FW: Exemption on Aquifer Requirements for Uranium Mining
I guess this is a public comment.
From:
Sent: Monday, March 6, 2017 8:15 PM
To: McClain-Vanderpool, Lisa
|>
Subject: Exemption on Aquifer Requirements for Uranium Mining
Without doing a thorough assessment of the draft permits, just the concept of any exemption on aquifer requirements for
Uranium mining seems crazy! As far as the details of the regulations I hope they are based on solid science and the need
to proteck our environment (and especially drinking water) from long term hazardous contamination, but not knee jerk
"anti-nuke" sentiments. In the past I've trusted the EPA to make sure judgements, hopefully this is still the case.
Respectfully,
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Shea, Valois
From:
Sent:
To:
Subject:
Monday, May 15, 2017 10:14 AM
Shea, Valois
Reject Permits for Dewey-Burdock Uranium Mine
Dear EPA,
I am commenting on the Underground Injection Control Program's Draft Permits for the Proposed Dewey-Burdock
Uranium Mine and Deep Disposal Wells.
The proposed mine and deep disposal wells are in an area that is documented to have faults, fractures, breccia pipes,
and over 7000 old boreholes that have not been properly plugged. It will be impossible to contain mining fluids or waste
liquids, and contamination of groundwater resources is very likely.
I am also concerned that groundwater is likely to be contaminated due to inadequate oversight of the quality of liquid
wastes pumped into the Minnelusa Formation through the proposed deep disposal wells.
Uranium mining cannot be done without creating and leaving contamination. Groundwater has never been returned to
its original condition at any existing leach uranium mine in the U.S.
I urge you oppose these permits until it can be proven that groundwater resources will be protected.
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Shea, Valois
From:
Sent:
To:
Subject:
Monday, June 19, 2017 8:09 PM
Shea, Valois
Underground Injection Control Program's Draft Permits for the Proposed Dewey-
Burdock Uranium Mine and Deep Disposal Wells
In the 1980s I researched the Dewey Burdock area for the Technical Information Project. TIP was involved in several
contested case hearings in before the South Dakota Board of Minerals and Environment and its predecessor board. We
were also involved in several appeals before the US Forest Service for previous attempts to explore and/or mine
uranium in this area. I also was involved in the research TIP conducted at the Gilt Edge Mine, operated by Brohm Mining
Company. TIP sued EPA to get proper NPDES permitting for that mine, but soon acid rock drainage would overwhelm
the site. It is now a Superfund site, and EPA is spending a lot of money to bring the problems there under control.
I am concerned a similar fate awaits Powertech's Dewey-Burdock uranium operation if it allowed to proceed. Dewey-
Burdock area has thousands of boreholes drilled through the upper confining layers of this proposed ISR operation, and
perhaps nearly as many through the lower confining layer. Laws at the time required surface capping only, not fully
cemented holes. Further, inspections of the cementing of the holes was extremely haphazard, with, at most, 10 percent
of the holes actually inspected. Many of these holes have probably collapsed by now, but they still have punctured the
confining layer(s) in multiple places. My concern is that operating an in-situ project in this area will be a disaster.
I am very concerned that continuous oversight of the mine and the quality of liquid wastes pumped into the Minnelusa
Formation through the proposed deep disposal wells will be impossible. If this is allowed to proceed, there must be a
qualified third-party monitor who is continuously on-site during operations.
Thanks for this opportunity to comment.
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Shea, Valois
Sent: Thursday, April 27, 2017 4:20 PM
To: Shea, Valois
Subject: Dewey-Burdock ISL uranium mine (SD)
Follow Up Flag: Follow up
Due By: Monday, May 01, 2017 9:00 AM
Flag Status: Flagged
Dear Ms. Valois,
As a Black Hills resident and retired pathologist, I am strongly opposed to any attempt to mine local aquifers for uranium. I
have carefully reviewed as much data as I can find on the reliability of prevention of cross-aquifer contamination by
lixiviant and liberated heavy metals using current techniques. I find no assurance that a mined aquifer can be returned to
a pre-mining condition. I'm also concerned by the vast volumes of water required by this process, considering that we live
in a semi-arid environment.
I am a proponent (and an experienced user) of renewable-energy generation of electricity. Given the current economics
and feasibility of renewable energy plus storage for our electricity needs, I find no justification for potential environmental
and public-health risks inherent in further reliance on nuclear power.
Thanks for your consideration of these comments.
Sincerely,
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Uranium and the Winters Doctrine
The Winters Doctrine, which I discussed at the Edgemont hearings, was just
upheld by a June 14, 2017 court decision for the Standing Rock Sioux Tribe in the latest
North Dakota Pipeline decision. This reaffirmed their rights against water pollution.
The Winters Doctrine mentioned in this case is a cornerstone of Native American Law.
This confirmed their rights to an ancestral home, which implies original water rights
dating from the original treaty agreement. This allows for present and future water
needs along with things like hunting and fishing.
It did not matter that Dakota Pipeline was upstream from the reservations: any
potential disasters were still a threat to a basic concept of a livable reserved homeland.
In the Edgemont, South Dakota hearing I presented 11 pages on the Winters
Doctrine. This doctrine provides a legal framework to hang all testimony in defense of a
reserve homeland by the Tribes. These concepts have just been upheld in court.
These concepts have grown wider in application over time, and now apply reserve
rights to things like National Grasslands, National Parks, and National Recreation Areas
as well as tribal reservations.
The Rapid City Journal notes rancher John Sides of the Fall River County
Conservation District says a uranium exemption and development could devastate 125
wells. "It would turn communities into ghost towns and ranches into wastelands ."
In applying the Winters Doctrine to National Grassland ranching, it does not
matter that contaminated wells for leases would be located just outside the Grassland
boundary. It is still the same aquifer and the effect is still disastrous on the federally
reserved resource, hence unallowable.
The same applies to all federally reserved lands from the time of their inception.
The Standing Rock decision brings this water law doctrine into the 21st century for
Native American issues.
Even if amounts are not easily quantifiable, a usable homeland cannot have zero
usable water. Left overs and contaminated dregs destroy the concept of a reservation.
Original treaties were based on what was understood at the time, not on some
rules, policies, executive actions, or laws made up decades or centuries later. In the
years following 1950 the government and President Nixon made a decision that areas of
the country would be considered sacrificial areas mandated by atomic pollution. This
decision and the resultant succeeding culture spawned countless decisions that were
damaging and poisonous to the Cheyenne River and Sioux homelands. Just like the
pipeline decision these were considered inconsequential since they were outside the
reservation boundaries. A poor minority would receive the negative results while the
powerful got rich.
How well would a poor minority be able to defend themselves anyway? This
totally ignores that the federal government holds these rights in trust for the Tribes. The
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government must defend these rights as their own and all decisions must be in the
Tribes' favor.
For decades or more uranium decisions have not been made in the Tribes' favor,
or even in the favor of other federally reserved areas, such as the Badlands National
Park, where the Cheyenne River flows.
The issue of uranium is not just whites versus Indians. The Winters Doctrine
applies to at least nine local federally reserved areas, including the two reservations.
Edgemont water quality analysis shows above acceptable radiation limits, and uranium
near the limits in two categories. It is time for the EPA to reopen investigation and
enforcement of suspect private uranium mines and gain physical entrance, as per
multiple tribal and non-tribal requests at the hearings.
Such questions under investigation should not allow further questionable, likely
damaging, and possible irreversible actions to the environment to be made. It is time for
the federal government to stand up to their trust responsibilities under the Winters
Doctrine.
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Shea, Valois
From:
Sent:
To:
Subject:
Monday, June 19, 2017 3:53 PM
Shea, Valois
No to Azarga-
Here are my comments on the Underground Injection Control Program's Draft Permits for the
Proposed Dewey-Burdock Uranium Mine and Deep Disposal Wells:
I live in and own property in the Black Hills. I work in the tourism industry and know that the
economic impacts of hosting millions of tourists and being a premier retirement area far outweigh
any economic and environmental promises a poorly-funded company like Azarga/Powertech (Stock
at .28 a share on Inn 16, 3:46 PM EDT) might have made over the years.
I am alarmed by their expansion of a plan to drill 4,000 in situ leach mining wells instead of the
original 1,500. These toxic wells would be drilled into the Inyan Kara aquifer on the southwest
edge of the Black Hills, which is used by families for their drinking water. After mining, the
company's plan is to pump uranium mining wastes back underground into the Minnelusa
aquifer through as many as four deep disposal wells, endangering yet more communities water and
well-being.
Assurances that their mining and pumping processes are safe are totally based on the word of
company officials with sparse scientific data. On the other hand, the history of uranium mining here
in South Dakota indicates that uranium mining cannot be done without creating and leaving
contamination. Cancer rates in areas where uranium was mined are alarmingly high. A poorly-
financed company without a proven track record, Azarga cannot guarantee that it will be
responsible for costly safety measures, for accidents, and for prompt and thorough cleanup.
Azarga/Powertech's record at the Dewey-Burdock site is poor even as they know they must prove
to the public that they are a good corporate citizen.
For health and economic reasons, I urge that the Environmental Protection Agency deny a permit.
It IS in our national interest to have safe water and soils for generations to come. It IS in our
national interest to protect our citizens' health. It is NOT in our national interest to issue permits to
a company with a problematic environmental record.
Respectfully submitted,
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Shea, Valois
From:
Sent:
To:
Subject:
Thursday, May 18, 2017 2:31 PM
Shea, Valois
Uranium Mining
Why would anyone think that it should be allowed to issue permits that would
needlessly expose the Lakota Oyate to the devastation of uranium mining and
continue America's war against Red Nations' peoples.
Powertech, is a multinational corporation and division of Azarga Uranium
Corporation of Canada, a foreign corporation. Why should the U.S. take the
radioactive tailings and deposit them in the Inyan Kara system of underground
aquifers? What part of NO does a Canadian corporation not understand?
Keep the U.S. out of your equation of ridding your operations of radioactive
materials.
NO. NO. No.
I'll even leave you my phone number so you can call me. I dare you.
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Shea, Valois
From:
Sent:
To:
Subject:
Thursday, March 16, 2017 8:52 AM
Shea, Valois
Uranium mining and our groundwater
Dear Ms. Shea,
Please accept this email as a formal comment regarding the proposed two Underground Injection Control (UIC) Draft Area
Permits and one associated proposed aquifer exemption decision for the Dewey-Burdock uranium in-situ recovery (ISR)
site located near Edgemont, South Dakota, under the authority of the Safe Drinking Water Act and UIC program
regulations.
I strongly urge the EPA to deny both of these permits and stand up for the American people. Among other hazards,
radon emissions, toxic heavy metals and other pollutants, including chloride, sulfate, sodium, radium, arsenic and iron, are
in ISR wastewater ponds. Accidents and leaks in this kind of operation are inevitable, raising concerns about runoff into
the Cheyenne River and Angostura Reservoir. As you are aware, the most serious radiation release in the US came from a
tailings pond spill at a uranium mine in New Mexico.
We can live without uranium but not without clean water and soil. How will our children and grandchildren survive without
clean water. I believe that the EPA's existence is to protect our environment for future generations. Science has proven
that mankind has abused our resources and has given us a path forward to ensure we all have clean water and air. Please
stand up for us. We already have been let down by the EPA allowing the pipeline to proceed.
Regards,
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Shea, Valois
From:
Sent:
To:
Subject:
Sunday, June 04, 2017 12:52 PM
Shea, Valois
Dewey-Burdock Class III & V Injection Wells
Dear Madame,
We are writing to ask you to REJECT the two Underground Injection Control (UIC) Draft Area Permits and one associated proposed
aquifer exemption decision for the Dewey-Burdock uranium in-situ recovery (ISR) site located near Edgemont, South Dakota, under
the authority of the Safe Drinking Water Act and UIC program regulations.
While we understand uranium is naturally occurring in our environment and that waste products generated from extraction, etc needs
highly effective containment, we shudder to think the EPA would allow any risk of contamination of our finite water resources with
said waste fluid injection. Even a slight risk of contamination to the aquifer at the Minnelusa Formation is too much of a risk.
WATER IS LIFE and its purity must be protected at all costs.
Thank you for placing my comments into the record opposing these permits to Powertech (USA) Inc..
Sincerely,
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Shea, Valois
Sent: Monday, March 13, 2017 4:23 PM
To: Shea, Valois
Subject: uranium injection
I strongly oppose injecting, any material, into or around any aquifers. Particularly waste materials
from uranium clean up projects. I request public hearings on this issue before any funds are diverted
to those ends.
Thank you
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May 15, 2017
TO:
FROM
SUBJECT: HAZARDOUS WASTE MATERIAL.
I am a resident of Oglala, SD and I lived here most of my life. I grew up drinking water
from Makizita Wakpa (White River) that runs through the western end of the Pine Ridge Indian
Reservation. The water was naturally drinkable at that time, today it is contaminated with
sewage, chemicals, medical waste, pesticides, herbicides, oil, trash, etc. and unsafe for drinking
today and causes cancer. I am a cancer patient, I may have contracted the disease from working
at Igloo, SD moving houses to the Pine Ridge Indian Reservation.
There are 37 test holes at Slim Buttes, SD north of Chadron, NB. In 1981, there was a
sudden breakout of SIDS and took the lives of many new born Indian children. Doctors at the
IHS Indian hospital did report that it was caused from something in the air, perhaps radium -
radon from the open test holes, so authorities transferred out the doctors. At that time, it was not
clear if those test holes were capped, they sure did have lids. Capping is when cement is used to
seal off each layer of sediment (rock, oil, natural gas, uranium etc.)
When I was small Hoksila (boy) my parents told me that someday we will be asked if we are
Christians. If you say yes then you will be punished or killed. Native Americans had their own spiritual
beliefs like the cannunpa that a spirit woman brought to the Lakota Dakota Nakota people, 500 years
before Christians came to turtle island, an anti-Christ followed them here, like another church called free
mason, and 13 colonies formed a united constitution and declared themselves an independent
government. Every U.S. president since has been a mason, native Americans were neither Christian nor
mason, with the power of the $$$$ they ruled turtle island by their application of federal laws on
everything, then they said we are citizens, but we are Ikce wicasa (natural people) and we have right to
live this way because we have our own laws, spiritual or otherwise.
Now it is threatened with the contamination from radio-active hazard material. I am
opposed to fracking and mining of yellow cake uranium at Crow Butte, in Crawford, Nebraska
that threatens our Oglala, Mniluzahan aquifers, Inyan Kara, etc. aquifers.
What is underground in the underworld must remain forever. Pro Dewey/burdock people
believe that it is perfectly safe for hazardous mining waste deposition in the Mniluzahan aquifer. A speaker at
Edgemont E.P.A. hearing quoted a story, "Bible creation story tells of Eve take an apple from forbidden tree
and gave it to Adam. They were driven away from the garden, in shame Adam took the apple and buried it in
Environmental Protection Agency EPA
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the ground to remain forever. The apple represents the underworld where the oil, the uranium, and other evil
things are. They are not to bring these up to the upper world or it would destroy all life."
TOld uranium mines in the Dewey-Burdock area should be fully reclaimed before new mining is
permitted.
Adequate oversight of the quality of liquid wastes pumped into the Mniluzahan Formation through the
proposed deep disposal wells will be impossible, and our groundwater is likely to be contaminated.
A full survey of cultural and historical sites is needed before mining or deep disposal is
allowed. Cultural and historical sites must be protected.
The proposed mine and deep disposal wells are in an area that is documented to have faults, fractures,
breccia pipes, and over 7000 old boreholes that have not been properly plugged. It will be impossible to
contain mining fluids or waste liquids, and contamination of our groundwater is very likely.
The history of uranium mining indicates that uranium mining cannot be done without creating and
leaving contamination. This project should be stopped until it can be proved to be safe, rather than relying on
imperfect protection and clean-up processes.
"URANIUM IS NOT SAFE, IT NEVER WAS, AND NEVER WILL BE.
Sincerely,
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Shea, Valois
Sent: Tuesday, May 09, 2017 6:44 AM
To: Shea, Valois
Subject: No uranium mining in the Black Hills
We must stop depredations of the earth and the waters on which we all depend for life.
Thank you for your attention and restraint.
The Maeve Chronicles are available as hardcovers, paperbacks, ebooks, and audiobooks
So Ecstasy Can Find You is my latest collection of poetry
Available now: hardcover, paperback and ebook: Murder at the Rummage Sale
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you might be a star
in someone's dark night
-from So Ecstasy Can Find You
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Shea, Valois
Sent: Monday, May 15, 2017 12:15 PM
To: Shea, Valois
Subject: Do not support Dewey Burdock uranium aquifer mining
Ms Valois,
I am writing to express my concern about the effects on the environment and very real health risks of the proposed
uranium aquifer mining at Dewey Burdock location in the black hills. I do NOT support this and demand that such be
denied to go forward. Given that the current administration is also cutting back on health care coverage it is even more
imperative that uranium mining be stopped as it will be a health hazard and most will not be able to cover cancer costs
and lose life. This is not good for people of the black hills areas.
Thank you for your voting against this initiative.
Sincerely,
Sent from my iPhone
1
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Shea, Valois
Sent: Tuesday, May 16, 2017 8:10 AM
To: Shea, Valois
Subject: Public comment on uranium mining in the Black Hills
Dear Dr. Shea,
In considering uranium mining in the Black Hills, I urge the EPA to clean up old mines before any new permits
are issues, to consult with the Sioux nation before any action, to conduct tribally approved archeological and
cultural surveys, and to have a Lakota translator/transcriptionist present at all hearings.
Thanks,
l
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Shea, Valois
From:
Sent:
To:
Cc:
Subject:
Tuesday, March 14, 2017 7:50 AM
Shea, Valois
https://www.epa.gov/uic/uic-epa-region-8
Absolutely no! This is completely insane!
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Shea, Valois
From:
Sent:
To:
Subject:
Tuesday, May 16, 2017 7:54 AM
Shea, Valois
EPA public comment: Dewey-Burdock Class III and Class V Injection Well Draft Area
Permits
Dear Valois Shea,
Here are my comments on the Underground Injection Control Program's Draft Permits for the Proposed Dewey-Burdock
Uranium Mine and Deep Disposal Wells:
• Old uranium mines in the Dewey-Burdock area should be fully reclaimed before new mining is permitted.
• Adequate oversight of the quality of liquid wastes pumped into the Minnelusa Formation through the proposed deep
disposal wells will be impossible, and our groundwater is likely to be contaminated.
• A full survey of cultural and historical sites is needed before mining or deep disposal is allowed. Cultural and historical
sites must be protected.
• Tribally defined consultation, Lakota translator/transcriptionist at hearings.
• The proposed mine and deep disposal wells are in an area that is documented to have faults, fractures, breccia pipes,
and over 7000 old boreholes that have not been properly plugged. It will be impossible to contain mining fluids or waste
liquids, and contamination of our groundwater is very likely.
• The history of uranium mining indicates that uranium mining cannot be done without creating and leaving
contamination. This project should be stopped until it can be proved to be safe, rather than relying on imperfect
protection and clean-up processes.
Thank you for your consideration,
l
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Shea, Valois
From:
Sent:
To:
Subject:
Sunday, June 18, 2017 8:21 PM
Shea, Valois
NO to Dewey Burdock Uranium Aquifer Mining
Hello,
Sending public comment on Dewey Burdock Uranium Aquifer Mining. Don't allow mining there. No uranium
on treaty territory.
Thank you,
Chicago, IL
Virus-free, www.avast.com
l
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Shea, Valois
From:
Sent:
To:
Subject:
Wednesday, May 17, 2017 9:38 PM
Shea, Valois
Don't Allow Uranium Waste Storage on Lakota Land
Dear Valois Shea,
I'm writing to ask that the EPA deny the permits for the proposed Dewey-Burdock Uranium Mine project. This
proposed mining project is likely to contaminate aquifers of the Black Hills and put the health and safety of
those drinking that water at risk. In addition, the mining project is next to the Black Hills, and is within the
boundaries of an area set aside for the tribes of the Great Sioux Nation by treaties signed in 1851 and 1868. The
Black Hills are sacred to the Lakota Nation. These tribes oppose this mining project; it violates their 1851 &
1868 Treaty Rights and they did not give up their water rights or mineral rights to these areas. The EPA must
deny these permits.
Thank you very much for your time.
All best,
l
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Shea, Valois
From:
Sent:
To:
Subject:
Monday, June 19, 2017 1:30 PM
Shea, Valois
NO mining in the Black Hills
I am writing to submit my comments on the Underground Injection Control Program's Draft Permits for the
Proposed Dewey-Burdock Uranium Mine and Deep Disposal Wells:
I deeply oppose mining in the Black Hills for a number of reasons. I am from Pennsylvania, where the water on
my parents' property is still undrinkable, 40 years after the strip mining contaminated the water supply. They
have been actively remediating the water and soil for my entire life, and it is much improved over the
surrounding areas which have not been remediated in any capacity, but it is still unsafe for drinking, and unsafe
for growing food.
It is impossible to mine — especially uranium — without contaminating the water. Even if someone chooses to
disregard the importance of native and settler relationships and the criticality of leaving sacred spaces
unmolested, geological impacts of mining are extremely widespread.
Thank you for your consideration,
l
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Shea, Valois
Sent: Sunday, March 12, 2017 10:48 PM
To: Shea, Valois
Subject: Draft permits and aquifer exemption for uranium mining project in southwestern South
Dakota
I think the job of EPA is to protect aquifers, not provide exemptions to companies that want to extract
hazardous substances near water supplies. This is a continuation down the path of environmental degradation
and a lack of concern for local drinking water. Please don't issue the permits.
"If one way be better than another, that you may be sure is nature's way." - Aristotle
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Shea, Valois
From:
Sent:
To:
Subject:
Tuesday, May 16, 2017 8:23 PM
Shea, Valois
Dewey Burdock uranium project
Dear Ms. Shea,
I am writing in regards to the proposed Dewey-Burdock uranium project. It is absolutely absurd that we are
even considering ANOTHER uranium mine, when the disaster that occurred on June 11th, 1962 has yet to be
cleaned up properly. The discussion we should be having is about what to do with the uranium tailings still
present on the Pine Ridge Indian Reservation and in Edgemont, as a result of Total Mine Development's failed
project.
Uranium tailings, as you are well aware, are no joke. According to Robert Pole, physics professor at Cornell
University, the estimated deaths as a result of uranium mining may be grossly underestimated. I, on some
level, can understand why some people, in this day and age, might be fighting for crude oil pipelines, but
uranium mines?!? - who, except for the numbered people who will directly profit from this venture, could
possible be in support of this project? White moms in Rapid City, native grandmothers on the reservation,
ranchers who's cattle depend on ground water, republicans, democrats, independents, all say no to radioactive
waste.
As a resident of Rapid City, I am concerned with the impact this project will have on my family's well being, on
our drinking water, air quality and my children's future. As the wife, and mother, of enrolled members of the
Oglala Sioux Tribe, I am even more concerned what impact this project will have on the well being of my
native brothers and sisters. It is clear, if history is any indicator, that this proposed project will leave them most
vulnerable.
I understand that your organization is currently facing opposition, due to the current Administration's total
disregard for science and the well being of humanity in general, but I beg you to do what you can to not allow
this project to move forward. Short term-private wealth is not worth the cost of radioactive waste.
Thank you so much for hearing me out and the work that you do as a public servant.
Sincerely,
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Shea, Valois
From:
Sent:
To:
Subject:
Monday, May 15, 2017 5:12 PM
Shea, Valois
Re: Thank you for your comments
Awesome, thank you Valois and bless the critical work of the EPA!
On Mon, May 15, 2017 at 4:03 PM, Shea, Valois wrote:
Thank you for emailing me your comments on the draft UIC Dewey-Burdock permitting actions. I have added
your email to the list of public comments received. I have also added you to my contact list to keep you
informed on future EPA actions related to the site.
l
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Shea, Valois
From:
Sent:
To:
Subject:
Monday, March 13, 2017 8:28 AM
Shea, Valois
Aquifer exemption for uranium mining
RE: EPA has issued two draft Underground Injection Control (UIC) Area Permits to Powertech
(USA) Inc., for injection activities related to a proposed uranium recovery project in the
southern Black Hills region in Custer and Fall River Counties of South Dakota.
I am writing as a concerned citizen regarding the recently announced application for
exemption from what can only be called sensible guidelines for the protecting of a water
aquifer. The potential for water contamination by uranium must be taken very
seriously, particularly given the long term threat posed to not just human life, but all life, such
as the increased rates of cancers due to increases in mutation rates. As I am sure you
know, this potential for environmental damage is exacerbated by the presence of nitrates,
which are practically ubiquitous in just about every region of the US.
I strongly urge the EPA, the guardians of our environment, not to approve such a blatantly
dangerous exemption.
Ms. Shea,
Kind Regards,
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MAY I 1 2017
S/i
Region 8
U.S. Environmental Protection Agency
1595 Wynkoop Street
Denver, CO 80202 Re: Dewey Burdock Uranium Mining Proposal from Azarga
Uranium Mining Co,, formerly Powertech Uranium
Mining Co., and Superfund Investigation brought by
The Wild Horse Sanctuary, Hot Springs, SD
it has come to my attention that a request for a full blown investigation of the Dewey Burdock
mining area and surrounding areas mined in the 1950's and 1960's near Edgemont, SD was
denied by the EPA because various owners of the huge open pit mines abandoned by uranium
mining companies would not allow access to the EPA for testing of water and to observe
erosion.
There are over 200 open mines in the Dewey Burdock area, both within and adjacent to the
10,400 acre Azarga proposed mining area. Of these there are four huge mines which are over a
mile across and which have estimated depths of at least 90 feet. The water in these open pit
mines is extremely toxic, containing highly radioactive water and heavy metals, including high
concentrations of arsenic, plus dissolved solids and other contaminants resulting from the
previous mining activities,
I own property in both Custer and Fall River Counties. I feel that the environmental health of
both counties is at stake and that this area should long ago have been designated a SuperFund
Site.
By this letter I am requesting that the EPA reopen the investigation into the problems being
caused by the mining of the 1950's and 1960's and suspend the Powertech Azarga permit
application currently being heard by Region 8 EPA for 4000 deep well injection wells.
In July of 2014 and subsequent to that I flew over the Dewey Burdock and photographed the
old mines and the drainage of the site which flows into Pass Creek and Beaver Creek. These
creeks then combine and the water flows into the Cheyenne River near Edgemont. The
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Cheyenne flows into Angostura Dam, the largest fresh water irrigation and recreation dam In
western South Dakota. This dam leads into the Missouri River.
It is my contention from observing the drainage patterns of the site towards these creeks and
the Cheyenne that substantial leakage from the mining areas is occurring and contaminating
Beaver and Pass Creeks and then the Cheyenne River, and Angostura Dam with the potential to
contaminate the Missouri River.
With this letter 1 am submitting a CD of 92 pictures taken from the air which illustrate the
drainage patterns, substantial erosion, and evidence of vegetation anomalies which belie the
extreme toxicity of the water held in the larger open pit mines.
Within the 2014 and 2015 time frame there was a major rain incident which sent a 4 foot high
wall of water toward the railroad tracks in the Dewey Burdock which derailed at least 4 railroad
cars. This was documented in the Edgemont Herald Tribune at the time.
The continued pollution of the Cheyenne River will continue to impact the Wild Horse
Sanctuary and other lands that border the Cheyenne River as well as the town of Edgemont.
I specifically call your attention to the following image numbers on the enclosed CD which show
various aerial views of the Dewey Burdock area. These are: 2385, 2388, 2392, 3091, 3095,
3096, 3097, 3099, 3103, 3124, 3136, 3140, 3142, 3143, 31144, 3150, 3154, 3156, 3162, 3163,
3164, 3165, 3134, and 817. images 3162 and 3163 show massive erosion areas on one of the
open mines that is typicai of many of the mines.
Please advise me as soon as possible as to what action you intend to take regarding the
reopening of this SuperFund Investigation of the Dewey Burdock Area and the Cheyenne River.
I stand ready to provide further information as needed. You have only to call me for assistance.
In closing, please evaluate this site more carefully, it is only going to get worse and will
ultimately result in an ecological disaster of massive proportions. We need your help.
Very truly yours,
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Shea, Valois
From:
Sent:
To:
Subject:
Monday, March 27, 2017 8:58 AM
Shea, Valois
Injection wells at Dewey Burdock
Dear shea valois:
As this issue has been extended for quite a while now, I will not start
from scratch is detailing how unacceptable is the EPA consideration to
allow injection of toxic waste into usable aquifers here in south west
South Dakota. I will simply bring to your attention the fact that the EPA
stands for Environmental Protection Agency not "Environmental Destruction
Agency". It is sad enough to consider uranium mining when there is no
profit available, no safety from radiation exposure and no protection from
drainage into surrounding watersheds. To purposely ruin usable, potable
and important local aquifers and state water supplies is mindless at best.
Now we learn that there will be no uranium mining in the foreseeable
future but rather the foreign company plans on accepting toxic wastes from
outside the area to make their profits at the expense of local population
and necessary water supplies.
Please. Please. Protect our environment from these profit mongers.
Thank you for your time and consideration.
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Shea, Valois
From:
Sent:
To:
Subject:
Thursday, May 25, 2017 8:59 AM
Shea, Valois
Re: PowerTech/AZARGA
Dear Ms. Shea:
Recently, I sent along a request asking the EPA to consider reviewing the
Dewey/Burdock site and the surrounding area of Edgemont with an eye
towards designating that area as a SuperFund Site. I believe Susan
Henderson did as well, you may have also received a water sample from an
Edgemont resident from the Madison aquifer showing contamination of that
water source. ( You may already be aware of the contamination in the
Cheyenne River from the area runoff through the wild Horse Sanctuary, the
Angostora reservoir, through Pine ridge Indian reservation and on to the
Missouri River.)
My question is simply whether you or your office has received said
mailings and if anything is planned to deal with it.
Sincerely,
On Tuesday, April 25, 2017 9:51 PM, "Shea, Valois" wrote:
Hello
Thanks for sending me a copy of the statement you will be presenting at the Hot Springs public hearing. I
appreciate your effort in providing me with the information ahead of time. I look forward to meeting you at the
Hot Springs hearing.
It would be helpful if you provide a printed copy of your statement at the time of the hearing.
Thanks!
Valois
Valois Shea
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My name is ancl my wife ancl'live on a small ranch
south of Pringle and have been there for 26 years. Thank you for
this opportunity to comment on Deep Well injection and uranium
mining. My comments here were given at an earlier public meeting
opposing the mining, injection
I am not a scientist nor an engineer nor do I receive payment of any
kind for being opposed to the permits in question.. I am not a for profit
corporation. I have no loyalties or any responsibilities to show a profit
to any stockholders. I am free to do the right thing.
When commissioned as an officer many years ago, I swore an oath
to uphold and defend the Constitution. The Constitution and the Bill
of Rights of course support a prime directive: Clarify the
responsibilities of the government and the rights of the people. Not
businesses nor corporations' rights but citizen's rights. Our
governments' responsibility is to the health and welfare of those
citizens. Every civil servant, every citizen's board, every governor is
accountable to the citizens who have allowed them to serve and if
they do not protect the health and welfare and the rights of the people
then they have abrogated their prime directive.
My references for this talk are the Power Tech/AZARGA permit
application available from the South Dakota DENR most of which I
have read, as well as the website of the NRC and the state laws
regarding water and mining. I hope to bring your attention to what I
believe are discrepancies and contradictions which should
provide reasons for the denial of this permit application.
Despite P/T's repeated assertions that this operation would be safe,
that is simply untrue. Nor is it true that radiation is actually good for
you, nor that one can destroy radiation contamination by washing it
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off. PT spokespersons have been willing to freely state that scientific
truths are nonsense apparently comfortable in saying anything that
will support their cause regardless of it's falseness. This alone should
force a denial of the permit. There are several issues that could
interfere with the ability of P/T to actually perform this requirement
not the least of which is that no ISL mining operation has ever
remediated the land, waters and aquifers to baseline. Exemptions
are asked for and usually given. This just provides the excuse to
contaminate and not remediate. This obviously does not a safe
operation make. If P/T actually cleans up and remediates the land
and waters to a clean uncontaminated state, it will be the first
operation to do so in the history of in situ mining. This is well known
and incontrovertible.
First: 5.6.2.1 of the application states that the slope of the permit
area is 2 to 6 degrees to the SW. Due to the location of Pass Creek
and Beaver Creek, this slope will force any drainage from leaks and
spills and land applications of contaminants plus precipitation to flow
SW into these creeks and thus to the Cheyenne River and to
Angostora, the Pine Ridge and the Missouri River. This is especially
true during heavy downpours such as we experienced this summer
which created a 4 foot wall of water that derailed dozens of RR cars
and the damaging flooding in the Boulder area which released
gallons and gallons of contaminants. These floods will happen
again. When they do, there will be precious little to prevent damage
to the mining area, not to mention a flooding of the contaminants on
the ground. As indicated in 3.39 of the application, and I quote," the
hazard for wind and water erosion... varies from negligible to
extreme" "to extreme"! This obviously should be of "grave concern"
to quote the Rapid City Council. And if the rainfall from our own
downpours can cause a train derailment then it can cause other
erosion as well. This indicates that the promises of safe containment
should be considered questionable.
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Second: PT will tell you that there is no communication between
aquifers because of confining layers. However, in 3.4.1.4 it states
that the Madison aquifer is 200 feet thick in the southern Hills up to
1000 feet regionally and could be connected to or communicate with
the Minnelusa and the Deadwood aquifers which are the chosen
repositories for the contaminated waste water, which will be injected
under pressure. This communication could prove to be unsafe for
obvious reasons. Additionally, in 3.4.1.7, P/T states that "no
evidence of karsting has been observed", (erosion due to dissolution
producing fissures and sinkholes) This is a below ground
phenomenon and simply because something has not been observed
at this time does not mean it will not occur later or that it is not there
now. As the cave system in the Hills is known to be everywhere, it
is only logical that there are fissures everywhere which will allow for
"communication" between aquifers as stated above.
Third: Figures 3.4-17 and 3.4-20 show the open pit mines, the
number of well holes and the down gradient and how the ore bodies
on the east will flow directly into Pass Creek, and thence to Beaver
Creek while the ore bodies on the west side will flow directly into
Beaver Creek. In 34.5.3.9 P/Ts plans will account only for a 100 year
flood. This plan does not take in account global warming, mega
storms, floods, tornadoes, droughts etc. and plan to stop the flooding
with a few well placed hay bales and ditches and berms. A 4 foot wall
of water will not be controlled by these meagre efforts. In 5.4.2.3.2
PT simply states that the runoff will be managed with no indication of
how they will actually do it beyond the attempts mentioned.
Fourth: In 3.6 P/T anticipates the potential for problems from winds
and wind erosion with Fig 3.6-39 showing the wind directions and
speeds in the mining and land application areas. The
evapotranspiration will leave contaminated residue on the land to be
blown away with the winds or washed away by the rains. In 3.11 "
The landscape comprising the permit area is erosional in nature."
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This admits to the problem outright and taken at face value should
indicate the inappropriateness of the area for the mining
project. Additionally, we are told that radium will be the main
contaminant and will simply sink to the bottom of the ponds ( where
it will sit up to 18 months with no covers before being removed or
injected) but Table 3.4-10 shows the other dangerous byproducts of
this type of mining. These include thorium, arsenic, cadmium,
mercury, thallium, polonium and radon in addition to the uranium and
radium. These dangerous by-products of ISL mining on the land
and in the water cannot possibly be considered safe for wildlife,
livestock or humans. In fact, P/T in 5.4.1.1.3, goes only so far as to
say that the lead and thorium will be "treated as necessary" but fails
to provide the details. In fact, how does one treat radon, or
radioactive cadmium or arsenic??? These poisons will become
concentrated due to the re-injection and recirculation of the water
into and from the IK making the IK more contaminated rather than
less. PT will tell you that the IK will get cleaner due to the bleed. I
believe this is illogical nonsense.
Fifth: In 5.0 it states that "potential environmental impacts will be
minimized". There are two problems with this statement: a) It admits
that environmental impacts will occur and b) it accepts the fact that
they have no intention or do not have the ability to actually remediate
these impacts just minimize them. This is not in the public interest
and indeed violates state law regarding non-contamination of public
waters. Of interest is 6.3.4.2 where it states that P/T will provide
"95% confidence that the ...units"... will..." meet the cleanup
guidelines or action levels". Minimum? 95% confidence? 95% of
the cleanup guidelines is unacceptable and if that is the best they
can do, then the permit needs to be denied. Indeed, P/T makes no
offer to do anymore than what they decide is
reasonable. Additionally, in 5.5, "Solid wastes such as pond sludge;
soils contaminated by leaks; spills of loaded or spent IX resin; filter
sand...parts; equipment...will be disposed of at an NRC...
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facility". This a very general statement which lacks specifics as to
the method of gathering up all this radioactive contamination which
will have drained into the soil in and outside of the permit area. The
fact that they know about the leaks, (such as the dozens of leaks at
Crowe Butte in Nebraska,) but cannot or will not prevent them must
be cause for alarm. The public needs more assurance than
this. 5.3.9.2 states only that erosion of disturbed areas will be
minimized. There are three problems with this assurance, a) P/Ts
admittance of the disturbed areas in the first place, b) they will not try
to prevent any erosion outside of the disturbed areas only minimize
the erosion inside the disturbed areas and c) they admit that they
will not even attempt to repair the erosion to its original state. Public
health is not served by this cavalier attitude towards runoff
prevention. In 5.3.4.4 it admits that " all grades will provide for
natural runoff" which as we have seen only further guarantees the
flowing of contamination into the creeks and rivers. In 5.4.2.2, In
reference to hazardous waste and "used oil"? " it is likely that this
project will be classified as a conditionally exempt small quantity
generator". CESQG This classification allows for up to 1000kg of
hazardous waste a month or 12000 kg a year. What if it isn't so
classified? Well, then, P/T simply assumes that they will obtain "the
appropriate approvals or permits". This expectation of creating
hazardous waste that needs yet another permit or approval due to
its dangerous qualities should cast additional doubt as to the viability
of this company to properly handle the responsibilities of this kind of
operation. Another concern is in 5.5.1.2.3, where it states that
excursions must be reported within 24 hours but the permit allows
for a delay in correction of the excursion up to 30 days. 30
days!!! This is not a minimization of contamination. With the DENR
no longer authorized to monitor and inspect the mining operation due
to SB158, the danger of failure to correct and the allowance of the
problem to continue is very real.
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Sixth: 5.6.2.1 Potential soil impacts: Two to six % slopes will cause
rain and wind erosion. Impacts to disturbed areas include:
compaction, loss of productivity, loss of soil, salinity, soil
contamination caused by clearing, excavation, leveling, stock piling,
and redistribution of soil. "Due to the use of heavy machinery and
high volume some soils have the potential of compaction." This
can "lead to decreased infiltration, thereby increasing run off". This
compaction "will be restored as possible following use." (Ten to
twenty years later!!!)
The hazard for wind and water erosion vary between negligible and
severe. Severe!!! PIT admits to the danger of compaction and
erosion and then PT admits to build up on land of disposals of waste,
salts, radionuclides, metals, metaloids, and the loss of soil fertility.
This is not 95%clean or minimized or reasonably achievable or even
a best effort. This is simply not proper and responsible work. Page
5-118
lists all the problems with spraying multiple contaminants on
land, which I won't belabor as it has been covered by
others. 5.6.5.1.3 PT accepts the potential of accidents which could
release pollutants such as bulk chemical products, uranium loaded
resin, dry yellow cake, solid by-product material. PT says it will simply
remove the contamination. They do not say how unless you count
their claim that it will wash off clean with water.They admit that the
consequences of these spills range from minor exposures to
"significant". And lest there be any doubt that this area will be
radioactive and dangerous to human health this sign will be posted.:
5.7. 2.4 ANY AREA WITHIN THIS FACILITY MAY CONTAIN
RADIOACTIVE MATERIAL.
Seventh: Another issue is the cost of reclamation. In their
socioeconomic report, P/T allows for $9 million. The bond is only 1.5
million (which is less than $150 per acre or about one hour of dozer
work) but it also acknowledges that the expected cost for reclamation
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could be as high as 75 million if I am not mistaken. And if WY is any
guide, it could be as high as 150 million. The ability of P/T to afford
even the 75 amount, depends on the amount of uranium removed
and therefore the amount of yellow cake produced. The other side
of the coin is the price for yellow cake to support this kind of
expenditure. P/Ts figures rely on the price of $65. This of course is
only a hopeful number as the current price is below $40. But even
at $40, there will not be profit of over $200 million available for this
kind of activity but rather, if my math is approximately correct, closer
to $50 million. If the remediation is to cost upwards of $75 million,
well...you can see that this just doesn't figure or as my rancher
friends like to say, it doesn't pencil. If the company can't sell at $40
then what is to become of the remediation after the mining? if they
can sell at $40 or below then what funds are going to be available to
attempt the remediation in the first place? This is a very unhealthy
set of circumstances.
Eighth: As we all know, and that includes the EPA, the NRC and
P/T, the USGS has stated that there has never been an ISL mining
operation that has returned the soil and water to a clean, before
mining status. Not WY, not TX. If P/T wants to mine uranium in the
Dewey-Burdock, then it has a debt to the people of the area and
should guarantee in writing that they will clean up the soil and water
to a clean uncontaminated state. That is what CO wanted. The
Project Manager said at his meeting at the Fall River Conservation
office recently that P/T would indeed guarantee completely that it
would clean up the permit area 100% with no mention of minimum,
no mention of 95%, no mention of putting forth a "best effort", but a
verbal guarantee to absolutely clean up the permit site and the
aquifers. Let us have a contract to that effect. It is my understanding
that P/T would not/could not provide that guarantee to Colorado nor
could it find 5 ISL operations that had cleaned up the water and the
land as proof that it could be done. That is why P/T left Colorado
empty handed and came to a sparsely populated area of the Black
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Hills in the hopes of trying it here. With some success I have to admit
due to the state legislature having failed the citizens of this state by
weakened the mining and water requirements for ISL mining and
removing DENR responsibility of oversight. Not surprisingly, the bill
was written by a P/T lobbyist. RCJ 22nd
Ninth: One of the serious problems I see with this operation is the
lack of mining experience of the people in charge. For example, the
company has yet to mine uranium. The Project Manager has never
been a project manager on any other ISL and in fact has done very
little "engineering" of any kind for many years The executives have
experience in the nuclear industry and in administration but not in
managing and mining an ISL uranium mine. At least not according
to the CVs. This is a very complicated and potentially dangerous
and very expensive proposition. One of P/T spokespersons is a
former Professor at the School of Mines. He has not mined any
uranium at an ISL mine The CEO has not mined any uranium at an
ISL mine. They have not developed yellow cake, they have never
remediated an ISL area. What they have accomplished is to file a
permit application. And that after many corrections from the NRC
and the DENR. I have to believe that this has to be their first filing
for an ISL mining permit. So...this will be a trial run for P/T personnel,
a first time operation. I am sorry but I have no faith in a lack of
experience. I need to see years of experience in the ISL industry
with a record of clean remediation and contamination
containment. Based on their inability to produce a clean permit
application without DENR and NRC assistance and their lack of
experience and their public admissions that there will be leaks and
spills and runoff and contamination of the soils, there is no reason to
expect P/T to be able to keep the public safe from this contamination
or remediate the operation to even a minimum standard. Indeed,
their stock price would not be pennies a share if investors had any
faith in this management and this operation. ARSD 74:29:07 clearly
states that "The individual who develops the reclamation plan must
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be competent in the management and planning of the specific type
or types of reclamation selected." With no prior experience in
reclamation, P/T clearly fails this test.
Tenth: 6.3 The project manager told me that I could actually drink a
glass of radioactive water with no ill affects, that if one were to be
subjected to radiation poisoning that this could simply be cleansed
by the normal body functions or washed off with no ill effects, that
radioactive equipment and material could be cleansed and made
neutral if you will, by a high pressure wash system. In my mind, this
demonstrates a complete lack of knowledge about radioactivity and
the dangers of radioactive contamination. P/T says it can
decontaminate the soil yet previously stated that contaminated soil
would be removed to a NRC approved site and that contaminated
equipment will remain radioactive and either be taken to another
site or if liquid, injected into existing aquifers. Contaminating aquifers
is not minimizing that contamination. It is just putting it out of sight.
We have heard about "permissible limits", 95% cleanliness,
minimized contamination, and recently a guarantee to contain the
contamination within the permit boundary. The NRC allows that the
permittee needs only to remove the contamination to as low as
reasonably achievable (or ALARA). But we are told that it will be
100% cleaned. As mentioned previously, the NRC knows it can't be
done cleanly so it abrogates its prime directive and puts the health
of the mining operation in front of the health and safety of the
citizens. The ALARA is in direct contradiction to that directive. Any
DENR approval of this operation is in direct contradiction of its
purpose to protect the people. There seems to be no true agreement
as to just exactly how far any remediation has to go to qualify for a
job well done and as we know, the contamination from an ISL mining
operation is not cleanable. This vagueness should be, especially at
this late stage, grounds for a denial.
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There are several situations that require the Mining Board to deny a
permit of this kind
(((They are 1-40-27:
(1) (a) If the permittee has intentionally misrepresented a fact
If the permittee has had any permit revoked (denied)under the
environmental laws of any state. (Colorado comes to mind.)
(2)The applicant substantially duplicates an application within the
past 5 years that has been denied, the denial having not been
reversed by a court of competent jurisdiction)))
45-6B-32:
(6) The proposed mining operation and reclamation cannot be
carried out in conformance with the requirements of 45-6B-35 (
grading, disposal of refuse, removal and handling of topsoil,
disturbance to hydrologic balance, slides-subsidence or damage
protection-fencing, and reclamation^ -38 states will not pollute
surface or ground water!!!)(-41 Disturbance to hydrologic balance.
Any disturbance to the prevailing hydrologic balance of the affected
land and of the surrounding area and to the quality and quantity of
water in surface and groundwater systems both during and after the
mining operation and during reclamation shall be minimized.)
45-6B-33:
Reclamation of the affected land pursuant to the requirements of this
chapter is not physically or economically feasible.
According to today's RCJ, P/T lobbyist and Program Manager
"speaking at a Rapid City Council committee meeting in August,
conceded that if the project goes through, the company will need to
somehow fund it." "They will need a larger financier going forward",
Hollenbeck said, adding that it could lead to a joint venture or selling
more stock, or perhaps selling the company. "It may be a sell-out of
the project," he said. "I don't know that." P/T hasn't the financing to
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even start the project even with over 50 million shares being
sold. How can this board approve this permit when they have
financing for neither the start nor the finish.
THIS HAS BEEN SHOWN AND THE PERMIT SHOULD BE
DENIED.
(2) Substantial disposition of sediment in stream or lake beds
,landslides or water pollution cannot be feasibly prevented
THIS HAS BEEN ADMITTED AND APPLIES. THE PERMIT
SHOULD BE DENIED
The proposed mining operation will result in the loss or reduction of
long range productivity of an aquifer, public and domestic water
wells, watershed lands, aquifer recharge areas, or significant
agricultural areas
AS A RESULT OF THE BILLIONS OF GALLONS OF WATER USED
AND CONTAMINATED, THIS IS HIGHLY PROBABLE AND THIS
PERMIT SHOULD BE DENIED.
The Board finds that any probable adverse socioeconomic impacts
of the proposed mining operation outweigh the probable beneficial
impacts of the operation. Contamination would affect tourism,
ranching, domestic water supplies, and the future economic health
of the region.
EVEN AT $65, THIS IS NOT A VIABLE ECONOMIC
UNDERTAKING. AT $40 IT IS A FINANCIAL
IMPOSSIBILITY. THIS BOARD HAS A CLEAR AND LEGAL
RESPONSIBILITY TO STRONGLY OPPOSE AND DENY THIS
OERMIT APPLICATION
**refer to the Letter of opposition from the FR Conservation District
as one example and the "grave concern" of the RC Council** I also
ask the Board to consider and recognize the hundreds of signatures
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of people who have signed their names in opposition to this
permit. As you know, these signatures represent upwards of 10 to
20 times those who are opposed. Please deny this permit.
Thank for your attention.
If time allows, I would like to read this at the May meeting in Hot
Springs and will provide a hard copy if requested.
Sincerely,
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Shea, Valois
From:
Sent: Friday, May 26, 2017 2:02 PM
To: Shea, Valois
iea:
liter update about the lac anium market.
Sincerely yours,
SlncereSwItzerland rejects nuclear power!
Switzerland has joined other European countries in rejecting nuclear power as the country's recent
referendum returned a majority "no" vote on May 21. The outcome means billions in funding will be
poured into renewable energy development to replace nuclear power. Switzerland's five nuclear
plants will be decommissioned and no new reactors will be built. Germany intends to be nuclear-free
by 2022 and powered at least 80% by renewable energy by 2050. Italy and Austria have also
resoundingly rejected nuclear energy which is on the decline globally, due to exorbitant costs, its
inherent and potentially catastrophic dangers, and the falling prices of wind turbines and solar panels.
Switzerland's decision demonstrates that closing nuclear plants and rejecting new build opens the
door for renewable expansion and not increased use of fossil fuel, as some pro-nuclear boosters
allege.
i
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Shea, Valois
From:
Sent:
To:
Subject:
Tuesday, May 30, 2017 2:29 PM
Shea, Valois
Dewey Burdock
Dear Ms. Shea:
I support the union n of Concerned Scientists and I have their most recent
publication called CATALYST, volume 16, Spring of 2017. I urge you to
avail yourself of this news up-date as it affects directly any decision
the EPA might make with regard the proposed uranium mining in South
Dakota.
I might also add that the 3 Mile island nuclear facility will be closing
down due to five years of losses and the absence of the billions of
dollars needed to cover the funding.
Power Tech spokespersons like to claim that one: the mining area will be
cleaned up and is safe and Two: the uranium to be removed will help the
country's energy balance. I would say again the it will not be cleaned up
because it is impossible to do so. as far as the need for U308 in this
country, remember that California will be shuttering their nuclear power
plants, Hawaii leads the nation in alternative energy sources and coal is
being replaced by gas. Wind farms are becoming the staple of the energy
system.
Switzerland is shutting their power plants down as has Germany. The EU is
transforming its energy balance away from nuclear.
would you be so kind as to remind the judge of these facts.
Sincerely,
-------
Shea, Valois
From:
Sent:
To:
Subject:
Monday, June 19, 2017 11:24 AM
Shea, Valois
final comments
Dear Ms. Shea:
Allow me a few minutes to summarize my concerns regarding the Dewey
Burdock mining proposal.
1). There is no market for uranium
2). The price of yellow cake is about 30 dollars below break even
3). The US has years and years of uranium and doesn't need anymore
4). There is no clean up known for ISL mining contamination
5). The UNC is not requiring P/T to decontaminate, only that it gets that
contamination as low as reasonably achievable
6). The mine sight is already radioactive as are the creeks that flow into
the Cheyenne River, thence to the wild Horse Sanctuary, Angostora
reservoir and on to the Missouri River
7). The water requirement exceeds the water usage of Rapid city at no cost
to the company. The desire to use upwards of 9000 to 15000 gem could also
water tens of thousands of cattle
8). The injection of contaminants will further the process of ruining the
area's aquifers (such as the main four in the area: Inyan Kara, Deadwood,
Minnelusa and the all important Madison) for human or animal usage unless
The EPA requires Super Fund designation
9). Linsey McLean, Susan Henderson, Dr. Stone from SDSMT and Dr. LaGarry
from Nebraska have presented you with chemical, biological and data
information proving the terrible danger of allowing this mining to
conti nue
10). Before any approval is considered for additional contamination, the
area must be placed in a SuperFund status.
11). The slope of the eastern mining area is a decline of a few degrees
from NE to SW and any flowing from surface spraying, rainfall or other
spills, which are endemic to the operation will simply flow in that
direction to the creeks and rivers not to mention leaking pi ton the
underlying aquifers. The western reacts the same as the east but runoff
and drainage decline from NW to SE. if this operation is allowed, then it
will only be a matter time before all surrounding waters will be unfit for
consumption
12). Previous mining operations, such as the TVA some decades ago found no
further viable sources of uranium
13). The Igloo compound has a history of contamination by such dangerous
poisons as lead, sarin gas and radioactive elements. Government
chemical weapons and testing have made that area ready for Super Fund
status. The sarin contamination is held in 50 to 60 year old 55 gallon
barrels, which are stored underground in burial trenches where leakage is
not that rare. Any seismological activity in this area will risk a:
fracturing of the sarin tunnels and release of the poison as well as
fracturing of the cave network that connects to all the underground caves
and aquifers.
14). Some polls indicate that upwards of 80% of South Dakotans are against
this mining and their opinions should hold sway.
-------
There is more of course but maybe this email will support denying any
permits in this regard. After all, would you feel comfortable with this
business in your back yard?
if I can be of any further support please let me know.
Sincerely,
-------
Shea, Valois
From:
Sent: Sunday, April 02, 2017 9:05 AM
To: Shea, Valois
Subject: Re: Injection wells at Dewey Burdock
Thank you for your response regarding deep well injection into usable and
used aquifers.
It is disheartening to realize how simple it is to save the water from
contamination yet witness the refusal of those responsible for that water
to safeguard it.
Sadly, The EPA has just allowed the continuation of a poisonous
herbicide/pesticide rather than remove it from use.
I look forward to the hearings.
Sincerely,
On Wednesday, March 29, 2017 9:38 AM, "Shea, Valois" wrote:
Thank you for emailing me your comments on the draft UIC Dewey-Burdock permitting actions. I have added
your email to the list of public comments received. I have also added you to my contact list to keep you
informed on future EPA actions related to the site.
Here is the link to the EPA UIC program website that contains all the information in the Administrative Record,
in case you do not already have it:
https://www.epa.aov/uic/administrative-record-dewev-burdock-class-iii-and-class-v-iniection-well-draft-area-
permits
The public comment period is in effect through May 19, 2017, in case you have any additional comments after
reviewing this information.
Thank you!
Valois
Valois Shea
l
-------
From:
Sent: Monday, March 27, 2017 8:58 AM
To: Shea, Valois
Subject: Injection wells at Dewey Burdock
Dear Shea Valois:
As this issue has been extended for quite a while now, I will not start from scratch is detailing how
unacceptable is the EPA consideration to allow injection of toxic waste into usable aquifers here in
south west South Dakota. I will simply bring to your attention the fact that the EPA stands for
Environmental Protection Agency not "Environmental Destruction Agency". It is sad enough to
consider uranium mining when there is no profit available, no safety from radiation exposure and no
protection from drainage into surrounding watersheds. To purposely ruin usable, potable and
important local aquifers and state water supplies is mindless at best.
Now we learn that there will be no uranium mining in the foreseeable future but rather the foreign
company plans on accepting toxic wastes from outside the area to make their profits at the expense
of local population and necessary water supplies.
Please. Please. Protect our environment from these profit mongers.
Thank you for your time and consideration.
-------
Shea, Valois
From:
Sent:
To:
Subject:
Sunday, April 23, 2017 9:34 AM
Shea, Valois
Re: Injection wells at Dewey Burdock
To: The Environmental Protection Agency
Re: Azarga plan for deep well injection
Please include the following to your comments about the Deep Well Injection. Thank you.
There are many reasons why the EPA should deny Azarga any permit to mine uranium and/or inject toxic fluids into currently used
aquifers in the Dewey Burdock area of South Dakota. The following will bring to your attention, once again, some of the most obvious.
1: The only reason this approach (4000 new bore holes for toxic waste disposal.) is being considered is the fact that the original plan to
mine uranium In Situ is now irrelevant due to the low value of the material, the lack of demand worldwide, the lack of verifiable amount of
uranium, a lack of verifiable funds to actually mine the radioactive product and of course the reality that alternative energy sources such
as wind and solar are now employing more new workers than the oil and gas industries. These realities beg the question: "Why are we
even considering this permit."?
One of the reasons for Azarga giving up on the mining was it's inability to clean up the waste from the mining effectively and intentioally
poisoning the underlying aquifers and land surfaces. The injection wells will create the same problems of toxicity except in the injection
scenario, the toxins will be forced into already necessary and utilized aquifers as opposed to the ruination of aquifer quality by
transmissivity. The injection directly into these usable aquifers will simply accelerate the contamination of the aquifers.
3. Professional geologists and chemists from the South Dakoata School of Mines,
Chadron State and private practice have testified most effectively as to the danger of this plan for all the residents in the area due
to the irreparable damage done to the water supply including the Deadwood, Minnelusa, Inyan Kara aquifers and the most important
aquifer of all, the Madison.
The misuse or contamination of the aquifers in the Black Hills flies in the face of good judgment due to the increasing importance of
usable water not just in drought affected South Dakota but the nation and the world. We are depleting our water supplies by allowing the
very kind of destruction envisioned by Azarga and the EPA. With the demand for water ever increasing due to continued world population
increases, it is imperative that the protection and careful usage of our water supplies be our guiding light. To actually embrace the
opposite behavior is to violate the EPA stated purpose of actually protecting the environment. It is no longer possible to deny the threats
to our remaining water supplies driven by In Situ mining and water ruination. Recent articles in several scientific publications have clearly
demonstrated the danger to our water quality and supply posed by this mining and bore hole toxicity. It is your responsibility to make
sure the water remains safe and by even considering a permit to allow this is a violation of your responsibility.
The fact that Platinum Partners, which is Azarga's largest share-holder, is being charged with a variety of misdeeds which if convicted
could provide prisoin terms for the guilty, should be a wake-up call to the EPA as the kind of people who are running the show for Azarga.
With the company based in China, overseeing a Canadian company with offices in Colorado, one can easily guess how Azarga feels
about the long term health of the citizens in this area when compared to the greed for profit.
This a boom/bust scenario which if approved will provide 100 or so temporary jobs for a year or so and then only a handful of
maintenace/mining operators. Whatever gain there might be for the employees and towns and counties will be more than offset by the
cost for cleanup which will be borne not by Azarga but by those same towns and counties to the tune of scores of millions of dollars. The
sad truth is that it cannot be remediated as it is well known that no In Situ mining operation, whether in Texas, Nebraska, or Wyoming or
any other place ,has ever been cleaned to original condition. It is not difficult to imagine that real estate values will drop, tax revenues for
the towns and counties will drop if this ill- conceived rape of the land and aquifers is appoved by the EPA.
Thank you for your attention. I hope this has been of some value in making your decision and I can only hope that you will make the right
one.
Sincerely,
1
-------
On Wednesday, March 29, 2017 9:38 AM, "Shea, Valois" wrote:
Thank you for emailing me your comments on the draft UIC Dewey-Burdock permitting actions. I have added
your email to the list of public comments received. I have also added you to my contact list to keep you
informed on future EPA actions related to the site.
Here is the link to the EPA UIC program website that contains all the information in the Administrative Record,
in case you do not already have it:
httDs://www.epa.aov/uic/administrative-record-dewev-burdock-class-iii-and-class-v-iniection-well-draft-area-
permits
The public comment period is in effect through May 19, 2017, in case you have any additional comments after
reviewing this information.
Thank you!
Valois
Valois Shea
U.S. EPA Region 8
MailCode: 8WP-SUI
1595 Wynkoop Street
Denver, CO 80202-1129
Fax: (303) 312-6741
Email: shea.valois@epa.gov
From:
Sent: Monday, March 27, 2017 8:58 AM
To: Shea, Valois
Subject: Injection wells at Dewey Burdock
Dear Shea Valois:
As this issue has been extended for quite a while now, I will not start from scratch is detailing how
unacceptable is the EPA consideration to allow injection of toxic waste into usable aquifers here in
south west South Dakota. I will simply bring to your attention the fact that the EPA stands for
Environmental Protection Agency not "Environmental Destruction Agency". It is sad enough to
consider uranium mining when there is no profit available, no safety from radiation exposure and no
protection from drainage into surrounding watersheds. To purposely ruin usable, potable and
important local aquifers and state water supplies is mindless at best.
2
-------
Now we learn that there will be no uranium mining in the foreseeable future but rather the foreign
company plans on accepting toxic wastes from outside the area to make their profits at the expense
of local population and necessary water supplies.
Please. Please. Protect our environment from these profit mongers.
Thank you for your time and consideration.
-------
Shea, Valois
From:
Sent: Sunday, April 23, 2017 9:52 AM
To: Shea, Valois
Subject: PowerTech/AZARGA
My name is and my wife and I live on a small ranch
south of Pringle and have been there for 26 years. Thank you for
this opportunity to comment on Deep Well injection and uranium
mining. My comments here were given at an earlier public meeting
opposing the mining, injection
I am not a scientist nor an engineer nor do I receive payment of any
kind for being opposed to the permits in question.. I am not a for profit
corporation. I have no loyalties or any responsibilities to show a profit
to any stockholders. I am free to do the right thing.
When commissioned as an officer many years ago, I swore an oath
to uphold and defend the Constitution. The Constitution and the Bill
of Rights of course support a prime directive: Clarify the
responsibilities of the government and the rights of the people. Not
businesses nor corporations' rights but citizen's rights. Our
governments' responsibility is to the health and welfare of those
citizens. Every civil servant, every citizen's board, every governor is
accountable to the citizens who have allowed them to serve and if
they do not protect the health and welfare and the rights of the people
then they have abrogated their prime directive.
My references for this talk are the Power Tech/AZARGA permit
application available from the South Dakota DENR most of which I
have read, as well as the website of the NRC and the state laws
regarding water and mining. I hope to bring your attention to what I
i
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believe are discrepancies and contradictions which should
provide reasons for the denial of this permit application.
Despite P/T's repeated assertions that this operation would be safe,
that is simply untrue. Nor is it true that radiation is actually good for
you, nor that one can destroy radiation contamination by washing it
off. PT spokespersons have been willing to freely state that scientific
truths are nonsense apparently comfortable in saying anything that
will support their cause regardless of it's falseness. This alone should
force a denial of the permit. There are several issues that could
interfere with the ability of P/T to actually perform this requirement
not the least of which is that no ISL mining operation has ever
remediated the land, waters and aquifers to baseline. Exemptions
are asked for and usually given. This just provides the excuse to
contaminate and not remediate. This obviously does not a safe
operation make. If P/T actually cleans up and remediates the land
and waters to a clean uncontaminated state, it will be the first
operation to do so in the history of in situ mining. This is well known
and incontrovertible.
First: 5.6.2.1 of the application states that the slope of the permit
area is 2 to 6 degrees to the SW. Due to the location of Pass Creek
and Beaver Creek, this slope will force any drainage from leaks and
spills and land applications of contaminants plus precipitation to flow
SW into these creeks and thus to the Cheyenne River and to
Angostora, the Pine Ridge and the Missouri River. This is especially
true during heavy downpours such as we experienced this summer
which created a 4 foot wall of water that derailed dozens of RR cars
and the damaging flooding in the Boulder area which released
gallons and gallons of contaminants. These floods will happen
again. When they do, there will be precious little to prevent damage
to the mining area, not to mention a flooding of the contaminants on
the ground. As indicated in 3.39 of the application, and I quote," the
hazard for wind and water erosion... varies from negligible to
2
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extreme" "to extreme"! This obviously should be of "grave concern"
to quote the Rapid City Council. And if the rainfall from our own
downpours can cause a train derailment then it can cause other
erosion as well. This indicates that the promises of safe containment
should be considered questionable.
Second: PT will tell you that there is no communication between
aquifers because of confining layers. However, in 3.4.1.4 it states
that the Madison aquifer is 200 feet thick in the southern Hills up to
1000 feet regionally and could be connected to or communicate with
the Minnelusa and the Deadwood aquifers which are the chosen
repositories for the contaminated waste water, which will be injected
under pressure. This communication could prove to be unsafe for
obvious reasons. Additionally, in 3.4.1.7, P/T states that "no
evidence of karsting has been observed", (erosion due to dissolution
producing fissures and sinkholes) This is a below ground
phenomenon and simply because something has not been observed
at this time does not mean it will not occur later or that it is not there
now. As the cave system in the Hills is known to be everywhere, it
is only logical that there are fissures everywhere which will allow for
"communication" between aquifers as stated above.
Third: Figures 3.4-17 and 3.4-20 show the open pit mines, the
number of well holes and the down gradient and how the ore bodies
on the east will flow directly into Pass Creek, and thence to Beaver
Creek while the ore bodies on the west side will flow directly into
Beaver Creek. In 34.5.3.9 P/Ts plans will account only for a 100 year
flood. This plan does not take in account global warming, mega
storms, floods, tornadoes, droughts etc. and plan to stop the flooding
with a few well placed hay bales and ditches and berms. A 4 foot wall
of water will not be controlled by these meagre efforts. In 5.4.2.3.2
PT simply states that the runoff will be managed with no indication of
how they will actually do it beyond the attempts mentioned.
3
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Fourth: In 3.6 P/T anticipates the potential for problems from winds
and wind erosion with Fig 3.6-39 showing the wind directions and
speeds in the mining and land application areas. The
evapotranspiration will leave contaminated residue on the land to be
blown away with the winds or washed away by the rains. In 3.11 "
The landscape comprising the permit area is erosional in nature."
This admits to the problem outright and taken at face value should
indicate the inappropriateness of the area for the mining
project. Additionally, we are told that radium will be the main
contaminant and will simply sink to the bottom of the ponds ( where
it will sit up to 18 months with no covers before being removed or
injected) but Table 3.4-10 shows the other dangerous byproducts of
this type of mining. These include thorium, arsenic, cadmium,
mercury, thallium, polonium and radon in addition to the uranium and
radium. These dangerous by-products of ISL mining on the land
and in the water cannot possibly be considered safe for wildlife,
livestock or humans. In fact, P/T in 5.4.1.1.3, goes only so far as to
say that the lead and thorium will be "treated as necessary" but fails
to provide the details. In fact, how does one treat radon, or
radioactive cadmium or arsenic??? These poisons will become
concentrated due to the re-injection and recirculation of the water
into and from the IK making the IK more contaminated rather than
less. PT will tell you that the IK will get cleaner due to the bleed. I
believe this is illogical nonsense.
Fifth: In 5.0 it states that "potential environmental impacts will be
minimized". There are two problems with this statement: a) It admits
that environmental impacts will occur and b) it accepts the fact that
they have no intention or do not have the ability to actually remediate
these impacts just minimize them. This is not in the public interest
and indeed violates state law regarding non-contamination of public
waters. Of interest is 6.3.4.2 where it states that P/T will provide
"95% confidence that the ...units"... will..." meet the cleanup
guidelines or action levels". Minimum? 95% confidence? 95% of
4
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the cleanup guidelines is unacceptable and if that is the best they
can do, then the permit needs to be denied. Indeed, P/T makes no
offer to do anymore than what they decide is
reasonable. Additionally, in 5.5, "Solid wastes such as pond sludge;
soils contaminated by leaks; spills of loaded or spent IX resin; filter
sand...parts; equipment...will be disposed of at an NRC...
facility". This a very general statement which lacks specifics as to
the method of gathering up all this radioactive contamination which
will have drained into the soil in and outside of the permit area. The
fact that they know about the leaks, (such as the dozens of leaks at
Crowe Butte in Nebraska,) but cannot or will not prevent them must
be cause for alarm. The public needs more assurance than
this. 5.3.9.2 states only that erosion of disturbed areas will be
minimized. There are three problems with this assurance, a) P/Ts
admittance of the disturbed areas in the first place, b) they will not try
to prevent any erosion outside of the disturbed areas only minimize
the erosion inside the disturbed areas and c) they admit that they
will not even attempt to repair the erosion to its original state. Public
health is not served by this cavalier attitude towards runoff
prevention. In 5.3.4.4 it admits that " all grades will provide for
natural runoff" which as we have seen only further guarantees the
flowing of contamination into the creeks and rivers. In 5.4.2.2, In
reference to hazardous waste and "used oil"? " it is likely that this
project will be classified as a conditionally exempt small quantity
generator". CESQG This classification allows for up to 1000kg of
hazardous waste a month or 12000 kg a year. What if it isn't so
classified? Well, then, P/T simply assumes that they will obtain "the
appropriate approvals or permits". This expectation of creating
hazardous waste that needs yet another permit or approval due to
its dangerous qualities should cast additional doubt as to the viability
of this company to properly handle the responsibilities of this kind of
operation. Another concern is in 5.5.1.2.3, where it states that
excursions must be reported within 24 hours but the permit allows
for a delay in correction of the excursion up to 30 days. 30
5
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days!!! This is not a minimization of contamination. With the DENR
no longer authorized to monitor and inspect the mining operation due
to SB158, the danger of failure to correct and the allowance of the
problem to continue is very real.
Sixth: 5.6.2.1 Potential soil impacts: Two to six % slopes will cause
rain and wind erosion. Impacts to disturbed areas include:
compaction, loss of productivity, loss of soil, salinity, soil
contamination caused by clearing, excavation, leveling, stock piling,
and redistribution of soil. "Due to the use of heavy machinery and
high volume some soils have the potential of compaction." This
can "lead to decreased infiltration, thereby increasing run off". This
compaction "will be restored as possible following use." (Ten to
twenty years later!!!)
The hazard for wind and water erosion vary between negligible and
severe. Severe!!! PIT admits to the danger of compaction and
erosion and then PT admits to build up on land of disposals of waste,
salts, radionuclides, metals, metaloids, and the loss of soil fertility.
This is not 95%clean or minimized or reasonably achievable or even
a best effort. This is simply not proper and responsible work. Page
5-118
lists all the problems with spraying multiple contaminants on
land, which I won't belabor as it has been covered by
others. 5.6.5.1.3 PT accepts the potential of accidents which could
release pollutants such as bulk chemical products, uranium loaded
resin, dry yellow cake, solid by-product material. PT says it will simply
remove the contamination. They do not say how unless you count
their claim that it will wash off clean with water.They admit that the
consequences of these spills range from minor exposures to
"significant". And lest there be any doubt that this area will be
radioactive and dangerous to human health this sign will be posted.:
5.7. 2.4 ANY AREA WITHIN THIS FACILITY MAY CONTAIN
RADIOACTIVE MATERIAL.
6
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Seventh: Another issue is the cost of reclamation. In their
socioeconomic report, P/T allows for $9 million. The bond is only 1.5
million (which is less than $150 per acre or about one hour of dozer
work) but it also acknowledges that the expected cost for reclamation
could be as high as 75 million if I am not mistaken. And if WY is any
guide, it could be as high as 150 million. The ability of P/T to afford
even the 75 amount, depends on the amount of uranium removed
and therefore the amount of yellow cake produced. The other side
of the coin is the price for yellow cake to support this kind of
expenditure. P/Ts figures rely on the price of $65. This of course is
only a hopeful number as the current price is below $40. But even
at $40, there will not be profit of over $200 million available for this
kind of activity but rather, if my math is approximately correct, closer
to $50 million. If the remediation is to cost upwards of $75 million,
well...you can see that this just doesn't figure or as my rancher
friends like to say, it doesn't pencil. If the company can't sell at $40
then what is to become of the remediation after the mining? if they
can sell at $40 or below then what funds are going to be available to
attempt the remediation in the first place? This is a very unhealthy
set of circumstances.
Eighth: As we all know, and that includes the EPA, the NRC and
P/T, the USGS has stated that there has never been an ISL mining
operation that has returned the soil and water to a clean, before
mining status. Not WY, not TX. If P/T wants to mine uranium in the
Dewey-Burdock, then it has a debt to the people of the area and
should guarantee in writing that they will clean up the soil and water
to a clean uncontaminated state. That is what CO wanted. The
Project Manager said at his meeting at the Fall River Conservation
office recently that P/T would indeed guarantee completely that it
would clean up the permit area 100% with no mention of minimum,
no mention of 95%, no mention of putting forth a "best effort", but a
verbal guarantee to absolutely clean up the permit site and the
7
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aquifers. Let us have a contract to that effect. It is my understanding
that P/T would not/could not provide that guarantee to Colorado nor
could it find 5 ISL operations that had cleaned up the water and the
land as proof that it could be done. That is why P/T left Colorado
empty handed and came to a sparsely populated area of the Black
Hills in the hopes of trying it here. With some success I have to admit
due to the state legislature having failed the citizens of this state by
weakened the mining and water requirements for ISL mining and
removing DENR responsibility of oversight. Not surprisingly, the bill
was written by a P/T lobbyist. RCJ 22nd
Ninth: One of the serious problems I see with this operation is the
lack of mining experience of the people in charge. For example, the
company has yet to mine uranium. The Project Manager has never
been a project manager on any other ISL and in fact has done very
little "engineering" of any kind for many years The executives have
experience in the nuclear industry and in administration but not in
managing and mining an ISL uranium mine. At least not according
to the CVs. This is a very complicated and potentially dangerous
and very expensive proposition. One of P/T spokespersons is a
former Professor at the School of Mines. He has not mined any
uranium at an ISL mine The CEO has not mined any uranium at an
ISL mine. They have not developed yellow cake, they have never
remediated an ISL area. What they have accomplished is to file a
permit application. And that after many corrections from the NRC
and the DENR. I have to believe that this has to be their first filing
for an ISL mining permit. So...this will be a trial run for P/T personnel,
a first time operation. I am sorry but I have no faith in a lack of
experience. I need to see years of experience in the ISL industry
with a record of clean remediation and contamination
containment. Based on their inability to produce a clean permit
application without DENR and NRC assistance and their lack of
experience and their public admissions that there will be leaks and
spills and runoff and contamination of the soils, there is no reason to
8
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expect P/T to be able to keep the public safe from this contamination
or remediate the operation to even a minimum standard. Indeed,
their stock price would not be pennies a share if investors had any
faith in this management and this operation. ARSD 74:29:07 clearly
states that "The individual who develops the reclamation plan must
be competent in the management and planning of the specific type
or types of reclamation selected." With no prior experience in
reclamation, P/T clearly fails this test.
Tenth: 6.3 The project manager told me that I could actually drink a
glass of radioactive water with no ill affects, that if one were to be
subjected to radiation poisoning that this could simply be cleansed
by the normal body functions or washed off with no ill effects, that
radioactive equipment and material could be cleansed and made
neutral if you will, by a high pressure wash system. In my mind, this
demonstrates a complete lack of knowledge about radioactivity and
the dangers of radioactive contamination. P/T says it can
decontaminate the soil yet previously stated that contaminated soil
would be removed to a NRC approved site and that contaminated
equipment will remain radioactive and either be taken to another
site or if liquid, injected into existing aquifers. Contaminating aquifers
is not minimizing that contamination. It is just putting it out of sight.
We have heard about "permissible limits", 95% cleanliness,
minimized contamination, and recently a guarantee to contain the
contamination within the permit boundary. The NRC allows that the
permittee needs only to remove the contamination to as low as
reasonably achievable (or ALARA). But we are told that it will be
100% cleaned. As mentioned previously, the NRC knows it can't be
done cleanly so it abrogates its prime directive and puts the health
of the mining operation in front of the health and safety of the
citizens. The ALARA is in direct contradiction to that directive. Any
DENR approval of this operation is in direct contradiction of its
purpose to protect the people. There seems to be no true agreement
as to just exactly how far any remediation has to go to qualify for a
9
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job well done and as we know, the contamination from an ISL mining
operation is not cleanable. This vagueness should be, especially at
this late stage, grounds for a denial.
There are several situations that require the Mining Board to deny a
permit of this kind
(((They are 1-40-27:
(1) (a) If the permittee has intentionally misrepresented a fact
If the permittee has had any permit revoked (denied)under the
environmental laws of any state. (Colorado comes to mind.)
(2)The applicant substantially duplicates an application within the
past 5 years that has been denied, the denial having not been
reversed by a court of competent jurisdiction)))
45-6B-32:
(6) The proposed mining operation and reclamation cannot be
carried out in conformance with the requirements of 45-6B-35 (
grading, disposal of refuse, removal and handling of topsoil,
disturbance to hydrologic balance, slides-subsidence or damage
protection-fencing, and reclamation^ -38 states will not pollute
surface or ground water!!!)(-41 Disturbance to hydrologic balance.
Any disturbance to the prevailing hydrologic balance of the affected
land and of the surrounding area and to the quality and quantity of
water in surface and groundwater systems both during and after the
mining operation and during reclamation shall be minimized.)
45-6B-33:
Reclamation of the affected land pursuant to the requirements of this
chapter is not physically or economically feasible.
According to today's RCJ, P/T lobbyist and Program Manager
"speaking at a Rapid City Council committee meeting in August,
conceded that if the project goes through, the company will need to
10
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somehow fund it." "They will need a larger financier going forward",
Hollenbeck said, adding that it could lead to a joint venture or selling
more stock, or perhaps selling the company. "It may be a sell-out of
the project," he said. "I don't know that." P/T hasn't the financing to
even start the project even with over 50 million shares being
sold. How can this board approve this permit when they have
financing for neither the start nor the finish.
THIS HAS BEEN SHOWN AND THE PERMIT SHOULD BE
DENIED.
(2) Substantial disposition of sediment in stream or lake beds
,landslides or water pollution cannot be feasibly prevented
THIS HAS BEEN ADMITTED AND APPLIES. THE PERMIT
SHOULD BE DENIED
The proposed mining operation will result in the loss or reduction of
long range productivity of an aquifer, public and domestic water
wells, watershed lands, aquifer recharge areas, or significant
agricultural areas
AS A RESULT OF THE BILLIONS OF GALLONS OF WATER USED
AND CONTAMINATED, THIS IS HIGHLY PROBABLE AND THIS
PERMIT SHOULD BE DENIED.
The Board finds that any probable adverse socioeconomic impacts
of the proposed mining operation outweigh the probable beneficial
impacts of the operation. Contamination would affect tourism,
ranching, domestic water supplies, and the future economic health
of the region.
EVEN AT $65, THIS IS NOT A VIABLE ECONOMIC
UNDERTAKING. AT $40 IT IS A FINANCIAL
IMPOSSIBILITY. THIS BOARD HAS A CLEAR AND LEGAL
ii
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RESPONSIBILITY TO STRONGLY OPPOSE AND DENY THIS
OERMIT APPLICATION
**refer to the Letter of opposition from the FR Conservation District
as one example and the "grave concern" of the RC Council** I also
ask the Board to consider and recognize the hundreds of signatures
of people who have signed their names in opposition to this
permit. As you know, these signatures represent upwards of 10 to
20 times those who are opposed. Please deny this permit.
Thank for your attention.
If time allows, I would like to read this at the May meeting in Hot
Springs and will provide a hard copy if requested.
Sincerely,
12
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Shea, Valois
From:
Sent:
To:
Subject:
Sunday, May 14, 2017 10:07 AM
Shea, Valois
Permits
Dear Ms. Shea:
I would like to add some last minute observations regarding an EPA's decision about water safety in the Dewey/Burdock mining area.
Comments by those few people who expressed their support of the mining and disposal permits require enlightenment. Comments
about the need for uranium for our own energy matrix are incorrect based on the reality that the US has 200 years of U308 on hand for
any of its uses and needs none now or in the foreseeable future. Also, Germany, leading the way, has changed to alternative energy
sources for 100% of its energy and will no longer need nuclear fuel, and California is closing its nuclear power plants, and the
Fukushima radiation is traveling north to the coast of Russia, the Aleutians, south along coastal British Columbia and on down to
California and Baja . All this and. more it painfully obvious that the U308 from this endeavor is a failed endeavor. With the possible
exception of the interest that China may have in using nuclear power for the short term while it changes over to solar and wind and
water, there is no market for the yellow cake in the US and elsewhere. The price of yellow cake is so low as to preclude any profit from
being made. It costs about $65 per pound to produce,, but the market is paying no more than about $25 per pound. In addition,
Power/Tech stock is now, and has been for several years, a penny stock meaning that investors know of the lack of viability of this
company. Existing investors have seen their investment drop precipitously.
One can easily see that there is no market and no money. Reason enough to deny the final permits.
There was mention of the NRC not finding any reason to deny the mining, meaning that the operation will be safe and non-
polluting. This is true depending on how one defines "safe". The NRC, and states where In Situ mining is active or ended, have
received complaints by the mining companies that they cannot meet the clean up requirements set by the NRC and the states and
asking these entities to lower the required standards of clean up, which those entities have allowed. Power/Tech along with the State
of South Dakota, the NRC and the EPA know that the clean up of the radioactive waste created by this mining is impossible and
therefore has no intention of trying to do any clean up beyond getting the toxins "As Low As Reasonably Achievable, or ALARA. With
this level of cleanup, the NRC can dismiss the danger of not being able to clean up the poisons and declare that the operation meets
all requirements. It is common knowledge that there has been no ISL return to baseline by any mining companies. Each one has been
and is being contaminated. One can see that there is no safe level of contamination. Reason enough to deny the final permits beyond
repair.
There are four main aquifers in the southern Hills and all of them are at risk of contamination by radioactive nuclides. This will come in
the form of deep injection wells and transmissivity of the waters in the aquifers.PowerTech denies any risk of contamination despite the
reality of all other ISL mining operatoins. The EPA has been denied access to the mining area which precludes being able to actually
inspect the site which precludes EPA's actual approval for obvious reasons. PowerTech has refused to reveal the constituents of the
Lixivient or the actual cleaning process of the Lixivient. The EPA cannot possibly approve this mining and water contamination
because of EPA ignorance of PowerTech operation. This is more than enough reason to deny the final permits.
The proponents suggest tyhat the opposers lack intelligence, lack scientific standing and approach this issues with an over abundance
of emotion. This is misdirection at it's best. Professor Stone of the SDSM &T is a scientist and teacher of impecable credentials has
studied this area extensively is quite clear as to the possible dangers of this mining operation. Professor LaGarry from Chadron State
College has studied this area as well and has the same conclusions. Ms. Linsey McLean is a highly qualified chemist who has testified
before you and her background, studies and knowlege of chemistry and chemical effects of mining Uranium is an expert witness and is
well known in many areas of the country. These scientists are not on a payroll and answer only to scientific truth rather than a
paycheck or a promise of future gains. PowrTech representatives on the other hand, have little to no experience in ISL mining, have
used intimidation techniques and physical threats to browbeat mining opponents. They have continuously erred in filing the permit
applications due to their ignorance of the mining process and have had to be hand led through the process. I don't blame the Lakota
for being emotional, however, because their water from the Cheyenne River and their wells is already contaminated as are the Beaver
Creek, Pass Creek, the Wild Horse Sanctuary and Angostora Reservoir. Because of all of this and the danger of the contamination of
Igloo, (Sarin gas and high levels of radiation in the whole are,) the EPA should seek a status of SUPERFUND rather than authorize
additional mining on top of the existing poisons. Please remember that the EPA's reason for existence is to protect the environment
not serve the interests of a corporation whose purpose is to violate uour protection. These are major reasons to deny these permits.
It is my understanding that monies for the NRC budget and the EPA budget are derived from the very operations that they are
supposed to oversee which supports the idea that the EPA and NRC actually work for the mining companies and not the public. I
noticed at the recent hearings that the EPA provided handouts explaining the ISL process but had little to say about the dangers, the
leaks, the incursions or the contamination of aquifers. Your presentations represented only half the truth. Yet another reason to deny
thes permits.
1
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I want to thank you for your efforts in presenting these venues for public input. I leave you with a question. Would you want to allow
known contamination into your water supply?
Sincerely yours,
-------
Shea, Valois
From:
Sent: Sunday, May 14, 2017 10:23 AM
To: Shea, Valois
Subject: Fw: REPORT ON EPA PUBLIC COMMENT HEARINGS
Dear Ms. Shea:
I forward this to make sure you realize the size of the opposition. The
voices of the proponents are few (7%)in comparison to the opponents
(93%). This has been true of every hearing I have attended going back to
2010 or so. in fact, unofficial polls have indicated that this ration
holds steady across the state.
Sincerely,
Show original message
On Friday, May 12, 2017 8:26 PM, wrote:
Greetings,
212 people spoke out at the public comment hearings held by the EPA to gather input on the
plan to mine uranium and dispose of mining waste in our aquifers. 197 of those people spoke
against mining and waste disposal (93%).
Now if only the EPA will do what people want and DENY the permits!
Wopila to native people who braved a bad situation in Edgemont last night, especially the
children.
And to all who worked to get public input, fed people, set up and took down tables, raised
awareness, raised money, had good conversations with new allies, and all that goes into a
project like this - GOOD JOB!
More discussion on how things went and a chance for your input at the CWA meeting
tomorrow (Saturday) morning at 9 am at the Rapid City Public Library upstairs.
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Update your Email Preferences or Unsubscribe
-------
Shea, Valois
From:
Sent:
To:
Subject:
Wednesday, May 17, 2017 2:31 PM
Shea, Valois
The Nuclear power no envisioned by PowerTech
Dear Ms. Shea
This article on NPR internet news should be a wakeup call for all those who support
uranium mining and nuclear power.
Thank you for your attention,
PS: The Hot Springs city council passed a resolution against PT and its excessive
use of water. The Conservation District did as well. The County Commissioners,
with one or two recusals because of ownership of PT stock and one or two not
voting at all because they were "not scientists" and had not even tried to listen to the
evidence on both sides, did not even entertain a vote.
Struggling Nuclear Industry Lobbies State
Governments For Help
3:01 Just like coal companies, America's nuclear power industry is having a tough time.
It faces slowing demand for electricity, and competition from cheaper natural gas and renewables.
And now, touting itself as a form of clean energy, the nuclear industry is lobbying state legislatures
with a controversial pitch for help.
"Nobody's in the mood for a bailout," says anti-nuclear activist Eric Epstein, as he considers where to
put up a poster in the Amtrak station in Harrisburg, Pa. It has the iconic image of Uncle Sam pointing
at the viewer, and saying, "I want you to stop the bailout of nuclear power in Pennsylvania."
ENERGY
Unable ipc s Nuc •' 1 ¦" •• Jne ~ .
Epstein has been a nuclear watchdog since 1979, when one of the reactors at the nearby Three Mile
Island plant partially melted down, bringing the industry's growth in the U.S. to a standstill. Four
1
-------
decades later, Epstein says nuclear power is just too expensive, and he doesn't want Ms state to do
what New York and Illinois already have.
Both states recently agreed to give billions in subsidies to the nuclear industry by essentially
broadening the definition of clean power. Supporters say the move will help combat climate change,
since nuclear plants don't emit carbon.
"The system we have today is designed around 'How do I deliver the cheapest megawatt-hour of
electricity in the next hour?' says John Kotek of the Nuclear Energy Institute, "without reflection of
the environmental impacts, for example or the importance of fuel-supply diversity, or reliability."
Around the country, five nuclear plants have retired in the past five years, and another five are
scheduled to close within a decade. In Pennsylvania, the Three Mile Island plant — which still has one
functioning reactor — is having trouble selling its power because it's more expensive than other
sources, like natural gas.
ENERGY
> • . Mile Island's Meltdown
But the bailouts are facing opposition from those competing power producers, especially the booming
natural gas industry.
"We are not anti-nuclear," says Stephanie Wissman, head of the Pennsylvania division of the
American Petroleum Institute. Her group is part of a new coalition opposing nuclear subsidies, a
coalition that includes gas trade groups, manufacturers, and the AARP. They argue the subsidies are
unfair, and will lead to higher energy bills.
Wissman says nuclear plants are "an important part of the energy mix. However, they've got to play
by the same rules as every other energy source."
The debate has put environmental groups in a tough spot, and left them divided. Climate change is a
big priority for many of them, and they've traditionally supported subsidies for renewables. But
Jackson Morris, of the Natural Resources Defense Council, says nuclear power is neither clean nor
renewable.
EJ |
Tfr - - ' '.ommercial illicit ctors licensed to operate. Link to a Ml list,
U.S. Nuclear Regulatory Commission
"We do recognize that it does have low-carbon attributes," he says. "But it's by no means on the same
playing field as truly renewable resources, like wind, solar, and energy efficiency."
NRDC has been willing to go along with some nuclear bailouts, but only when they also included more
support for renewables.
2
-------
The nuclear industry is ramping up lobbying efforts in several states, including Ohio. There, a group
of scientists, business and community leaders are appealing to Amazon to back the subsidies, given its
support for renewable energy. In a letter to owner Jeff Bezos, they write: "If Ohio's nuclear plants are
allowed to close they will be replaced overwhelmingly by coal and other fossil fuels."
But in New York, a group of opponents are challenging the subsidies to nuclear plants, saying they have
"the potential to unravel U.S. power markets altogether."
Marie Cusick reports for Statelmpact Pennsylvania. NPR's Jennifer Ludden contributed to this report.
• Download
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May 16, 20174:30 PM ET
Heard on gs Considered
-------
Shea, Valois
From:
Sent:
To:
Subject:
Wednesday, May 17, 2017 5:28 PM
Shea, Valois
Fw: Fwd: Featured in Sunday's Paper - It's Now or Never!
On Sunday, May 7, 2017 3:50 PM,
¦wrote:
I hope I am not over-loading you.
Thanks for for your attention.
SubjectrFeatured in Sunday's Paper - It's Now or Never!
Date:Sun, 7 May 2017 21:36:04 +0000
To:
Dear
This is it. Years ago, it became clear that if we are to stop Powertech/Azarga Uranium from polluting Black
Hills water, we need heavier hitting social media advertising than ever before.
l
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0
Las! week, we released a video ad on Facebook explaining how the company wants to get paid by other
companies to haul in hazardous waste, from other states, and possibly even other countries, to inject it straight
into our Minnelusa aquifer - which naturally intermingles with all surrounding aquifers including the Madison
(where the majority of us get our drinking water).
They applied for 8 hazardous waste injection wells because they want to start pumping and trucking in mining
waste before they even start mining.
Our video has received 9,000 views, and was even featured in the Rapid Citv Journal this morning. However, our
projections show that we need a lot more people to see it before the EPA hearing tomorrow - if we are to inspire
enough people to attend.
Contribute Now
Pushing this video into Facebook news feeds requires your contribution and sharing. Every dollar
donated to our organization between now and Tuesday will go directly into making this video as
unavoidable as possible to the right people within a 40 mile radius of Hot Springs and Rapid City.
Share our video with everyone you know! Time is of the essence!
Thank you for being part of the most important grass roots movement in South Dakota! Please attend an EPA
hearing and/or submit a written testimony about how dangerous this toxic waste project really is. Of course, it is
2
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best to testify in person, but you can submit your testimony via email at: shea.valois@eDa.aov or you can drop it
off in person at either EPA hearing.
Everyone needs to submit testimony! It's either now or never!
Donations are not yet tax deductible as we are awaiting 501 c3 approval.
Paid for and Authorized by the
Council for Responsible Mining Political Action Committee
840 Husker Place
Rapid City, SD 57701
knowminina.org
Do you want off our email list? opt-out here.
ERED BY PHPLIST
3
-------
Shea, Valois
From:
Sent:
To:
Subject:
Wednesday, May 17, 2017 5:35 PM
Shea, Valois
PowerTech
Dear Ms. Shea:
I have sent this reference information for you interest. It is a very
long packet of information describing the types of serious mistakes those
who are opposed to the mining and abuse of water supplies are concerned
about.
Thanks you for your interest.
-------
Shea, Valois
From:
Sent:
To:
Subject:
Monday, March 13, 2017 7:33 PM
Shea, Valois
Uranium injection activities
Hello,
I am writing to you as a believer in the epas mission BEFORE your new boss ever stepped in the building. And
that is to provide quality control on the environment and to protect us, the citizens of this country from
corporations and their profits over my health and neighbors well being.
It doesn't take a rocket scientist to understand the implications of what is being sought after. Your job is to
preserve the land for generations to come. Including the natural inhabitants of a given area. Human, or
wildlife. We are all inhabitants of this earth and we are demanding that obvious dangers are unavoidable and
cannot be maintained by humans should something go awry. And save the retort about the safe guards in
place. We have seen time and time again that these "safeguards" are faulty by design or corners are cut to
save time and money.
Do not allow this to go through. Unless you all are willing to drink the potentially at risk water that is subject to
contamination by this would be effort. It reminds me of a scene from the Erin brokovich film where the folks
from PG&E were given the water they sweared was not contaminated in mediation to drink but once that little
detail was mentioned, nobody wanted to touch let alone drink the water.
Profits are not to be placed above people. Period. Push these companies to abide by new regulations and hold
them accountable for damaging our country, our welfare and overall quality of life.
- A concerned American citizen
Sent from my HTC on T-Mobile 4G LTE
l
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Shea, Valois
From:
Sent:
To:
Subject:
Tuesday, May 02, 2017 2:29 PM
Shea, Valois
FW: EPA Region 8 Underground Injection Control Program-Permits for Proposed
Dewey-Burdock In-Situ Recovery Site
From:
Sent: Tuesday, May 2, 2017 9:19 AM
To: 'Shea, Valois'
Subject: RE: EPA Region 8 Underground Injection Control Program-Permits for Proposed Dewey-Burdock In-Situ
Recovery Site
Thank you Valois and I'm sorry that I missed your call.
I would very much like to tell you why I'm interested in this area , but first I would like you to know that I'm not running
for office, nor do I want to pull a Erin Brockovich...take on a big corporation ...win ...and then have a movie made about
me. I just want to help. The Dewey_Burdock in-situ recovery site is here, and even if God came down and shut the
operation down...we would still have to put everything somewhere else. I would like to learn as much about the history
and the current conditions as I can to see if there is anything that I can do to help. If you know of a good archive.Jf you
know of a good contact, I would appreciate getting them . As far as you are concerned, what needs to be done there ?
Thank you very much
1
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From:
Sent: Monday, May 01, 2017 2:51 PM
To: Shea, Valois
Subject: EPA Region 8 Underground Injection Control Program-Permits for Proposed Dewey-Burdock In-Situ Recovery
Site
Valois Shea,
This email is in response to the notice received for comments on the EPA Region 8 Underground Injection Control
Program-Permits for Proposed Dewey-Burdock In-Situ Recovery Site.
I am requesting proper 106 consultation. We are currently reviewing all documents that are available online.
If you have any questions, please contact me.
Thank you,
2
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Shea, Valois
Sent: Saturday, March 11, 2017 7:07 PM
To: Shea, Valois
Subject: No TO FRACKING FOR URANIUM OR ANYTHING ELSE!!! from Geralynn Barner
Sir or Madam,
USGS FINALLY ADMITS THAT FRACKING
CAUSES EARTHQUAKES
Posted by Mar 2,2017 I
NO, I SAY A THOUSAND TIMES NO! NO FRACKING TYPE ACTIVITY!
PERIOD!
Underground Injection Control
USGS FINALLY ADMITS THAT FRACKING
CAUSES EARTHQUAKES
Posted by 1 Mar 2,20171 Powertech (USA) Inc., for injection activities related to a
proposed uranium recovery project in the southern Black Hills region in Custer and Fall River
Counties of South Dakota. NOT- BIGLY!!
No permits, exceptions whatever! Water is life. I was alive during the time of the Times Beach
Dioxin pollution, EXXON MOBIL Valdez and Deep Horizon. I also am a student of the
problem with Chevron extracting oil, Etc in the previously pristine Ecuadorian Forest 30 years
ago and leaving those poor natives with a mess from that process. The natives of had an
ongoing legal dispute to get remedies for 25 years!!! Please stop insulting our intelligence!!
I am a retired RN I have a BSN from major University and I practiced in Healthcare
Management for 30 years. Don't reinvent the wheel. Healthcare has proven that
PREVENTIONis a million times better than trying to treat the disease once you get it.
Don't let these big companies make profit by destroying our public resources such as water in
the aquifers and above ground on the land and in the water and the air.
What don't you get? Your grandchildren and great-grandchildren are going to be around
during this time in the future and they'll be the ones having to deal with this if we don't stop it
before it starts.
You cannot eat, drink and breathe CASH© dram.
Do you not remember the rivers being on fire back in the sixties and seventies and the Erie
Lake almost being dead from pollution? REMEMBER SMOG?????
i
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I belong to the Intelligentsia. The half life of uranium is 4.5 billion years! You cannot bribe us with short-term
job security!!!
The white men from Europe have already stolen the whole of America from the original Aborigines who lived
here and almost committed genocide on their population. Now you want to go and commit more pollution and
ravage their land so it's uninhabitable forever. Have you no conscience?? Even considering this proposal is
absurd!
Sent from my Verizon, Samsung Galaxy smartphone
2
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Shea, Valois
From:
Sent:
To:
Subject:
Saturday, March 18, 2017 7:46 PM
Shea, Valois
Fw: Fw: New Hazardous Waste Dump in the Black Hills?
Valois,
I got this email and it says Powertech/Azarga is applying for 8 injection wells at the Dewey-Burdock
site in South Dakota. It also says that the company can pull "in mining wastes from other regional
mines and/or sell those waste disposal rights to another company later on."
Are these things true??
Subject: New Hazardous Waste Dump in the Black Hills?
Dear^B
You are receiving this email because you have shown interest in fighting Powertech /Azarga
Uranium in the Black Hills. You also have friends who are connected to our common efforts.
Right now, we need to keep this Chinese Corporation from installing up to8 Deep Water
Hazardous Waste Injection Wells'm the Black Hills.
-------
These wells are claimed to be a component of a larger uranium mining project which many outstanding
local volunteers and organizations have been fighting for many years. Today, things are really coming to a
head.
Because so many sensible, dedicated folks have fought so long and hard to stop Powertech /Azarga, today,
our combined success and very low uranium prices on the world market has made it uncertain if the
company could ever begin mining uranium in the Black Hills. However^ZVOW they are trying to
ram. through approval on hazardous waste deposition wells so if they end up unable to mine in
Edgemont, they can at least make a profit by pulling in mining wastes from other regional mines and/or sell
those waste disposal rights to another company later on.
The EP ^Environmental Protection Agency) is Holding Local Hearings in late
April and May to receive public opinion - on how residents of the Black Hills area feel about companies
hauling in hazardous waste from mining sites outside of South Dakota, and injecting it into an aquifer that
so many people have grown to depend on.
Bottom Line:
Our organization is going to runads on social media, radio and even local TV- to publicize
the need for local residents to attend one or more hearings - just long enough to express your grave
concerns for your Black Hills water. High attendance at the hearings will boost local leverage with the EPA
and complement the total effort in the most effective way.
Please read our full Position Statement and Share it with everyone you know - in every way that you can.
Thank you for being part of the most important grass roots movement in South Dakota!
Donations are not yet tax deductible as we are awaiting 501 c3 approval.
2
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Paid for and Authorized by the
Council for Responsible Mining Political Action Committee
840 Husker Place
3
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June 19, 2017
Vaiois Shea
U.S. Environmental Protection Agency, Region 8
Mail Code 8WP-SUI
1595 Wynkoop Street
Denver, CO. 80202-1129
Sent via e-mail to Shea.valois@epa.gov
Dear Ms. Shea:
Thank you for making the trip to Rapid City in May to speak to concerned citizens. What I learned from
your presentation, comments made by Mr. Douglas Winter, EPA staff person, and comments of the
members of the public make me even more concerned about the proposed ISL uranium mine in Custer
and Fall River Counties in South Dakota.
At the beginning of the first hearing in Rapid City, I chatted with Mr. Winter about the proposed mine.
While he was explaining the project he said since the Minnelusa aquifer is not used for drinking water,
there are no concerns about waste injection into the Minnelusa,
Your presentation gave me the impression that the EPA thinks that the Minnelusa aquifer is not used for
drinking water.
As i mentioned in my spoken testimony in Rapid City, the Minnelusa aquifer is a drinking water source
for many people according to our state Department of Environment and Natural Resources. I recall
hearing one member of the public standing at the podium and saying that said her grandson is drinking
Minnelusa water.
It is appaiiing to realize that EPA staff members are unaware of the indisputable fact that the Minnelusa
aquifer is indeed a drinking water source for many South Dakotans.
This part of South Dakota is particularly dry. How dry? Cacti, sage and yucca thrive in our sunny, dry
climate. We cannot afford to risk contamination of the Minnelusa aquifer. Please do not issue any
further permits to Powertech/Azarga for any portion of their proposed project, including permission for
other companies to inject their waste into Powertech/Azarga's proposed injection wefls.
Thank you for the opportunity to comment.
-------
Shea, Valois
Sent: Monday, March 13, 2017 5:02 AM
To: Shea, Valois
Subject: Protect the aquifer!
Please don't allow uranium waste to be injected into the aquifer. Don't we have enough environmental problems
already? Isn't it bad enough that Scott Pruitt is now head of the EPA?
-------
Shea, Valois
Sent: Monday, May 15, 2017 10:59 AM
To:
Subject: NO to Uranium mining at Dewy Burdock
Please add my voice to those opposing this project. Please think of our long term environmental and public
health. Do not approve this project.
• Old uranium mines in the Dewey-Burdock area should be fully reclaimed before new mining is permitted.
• Adequate oversight of the quality of liquid wastes pumped into the Minnelusa Formation through the proposed
deep disposal wells will be impossible, and our groundwater is likely to be contaminated.
• A full survey of cultural and historical sites is needed before mining or deep disposal is allowed. Cultural and
historical sites must be protected.
• The proposed mine and deep disposal wells are in an area that is documented to have faults, fractures, breccia
pipes, and over 7000 old boreholes that have not been properly plugged. It will be impossible to contain mining
fluids or waste liquids, and contamination of our groundwater is very likely.
• The history of uranium mining indicates that uranium mining cannot be done without creating and leaving
contamination. This project should be stopped until it can be proved to be safe, rather than relying on imperfect
protection and clean-up processes.
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Shea, Valois
From:
Sent:
To:
Subject:
Monday, June 19, 2017 9:41 PM
Shea, Valois
Save Sacred Black Hills - NO Uranium Mining in Treaty Territory
Dear Ms Valois,
I am writing as a concerned citizen to urge you to deny any and all permits relating to in-situ recovery of
uranium within the southern Black Hills region of Custer and Fall River counties.
If passed, this invasive and potentially toxic mining project has the potential to permanently contaminate the
aquifer. With massive cuts to EPA funding, I'm terrified by the possible repercussions one small error could
have on this very important water supply. As a scientist yourself, I'm certain you know much more about this
than I do.
Not to mention, the Black Hills are sacred ground to the Lakota people. After everything that happened at
Standing Rock, the brutality and the suppression of our fellow people, please help our country learn from past
mistakes.
These short-term risks our country is taking with the environment are not worth the detrimental effects they will
have for decades.
I know you pursued your career to make a change for the greater good. You have the chance to take a stand
against environmental catastrophe. Please deny the Dewey-Burdock permit.
Thank you,
Concerned citizen, writer, activist
l
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Shea, Valois
From:
Sent:
To:
Subject:
Sunday, March 12, 2017 8:42 PM
Shea, Valois
Comment: uranium mining permit in SD
Good evening:
I am writing to oppose the proposal to allow infection of waste products from uranium mining near underground
aquifers in South Dakota.
This proposal is dangerous and threatens clean drinking water for a large number of people. The benefit from the
proposal is negligible.
Thank you,
l
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Shea, Valois
Sent: Friday, May 19, 2017 11:36 AM
To:
Subject: PROPOSED URANIUM MINING AND STORAGE PLANS ON LAKOTA LANDS
Hello Valois,
My name is and I am writing you to convince you to search for a better more sustainable solution to
this problem.
Since white men began colonizing the US, proud Native Americans have been treated like second rate humans,
killed, rapped, butchered, and drove from their lands. This seems to still be the case. We should be coexisting
with Native Americans not ruling over them. Please find a alternative that does not put FRESH WATER and
HUMAN LIFE in harm's way.
In closing, if you can't find a place to put this uranium, then we as a society should not be using uranium AT
ALL. Please remember that human life and our water sources are in your hands.
Best Regards
-------
Shea, Valois
Sent: Tuesday, March 14, 2017 11:20 AM
To:
Subject: Uranium in Aquifer
I oppose the EPA proposal that would allow for depositing uranium waste in drinking water. It is dangerous.
Sent from my iPhone
l
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Shea, Valois
Sent: Thursday, May 18, 2017 3:33 PM
To:
Subject: In Regards to the Dewey-Burdock Uranium Project
Dear Shea,
Thank you for the opportunity to exercise my freedom of speech.
Please take into consideration my concerns regarding the Dewey-Burdock Uranium Project that is currently
under question in Black Hills (South Dakota).
It has come to my attention that this project will entail drilling into locations that are sacred to the Sioux people.
Since 2015, the Sioux people have been voicing their concerns about the Uranium Project and for good reason!
Azarga Uranium states multiple times throughout their official report that "potential impacts" are "small". It
took thousands of years for these natural landmarks to form and their structural integrity will be compromised
by these intrusive drilling methods. Although the structures will still exist and there is a high chance that
everything will work out as "planned" it doesn't necessarily mean that we should go through with the project.
Just because one can doesn't mean that one should. Furthermore, injecting radioactive materials into the earth
near a source of clean water leaves room for potential contamination. Clean water is a resource that should not
be taken for granted.
It is not only a matter of damaging lands that can't be replaced. We must also take into consideration the
negative effects that the project can have on the surrounding populations. There are several risks listed in the
official report, two of which stand out to me. The first is stated as follows:
Because there will have been no well field scale pilot testing completed prior to construction of a full
production facility, there is a risk that the total resource recovered, presently projected based on laboratory
studies, may be overestimated. (133).
It is not worth risking our health and earth for something that might see results. If they are going to compromise
sacred lands and increase the chance for health risks of individuals they should make sure their output is going
to be worth it.
Second, "accidents" and "product spillage" was also a concern. Accidents happen, and we cannot have our lands
polluted with toxic waste. Especially lands that are visited and honored regularly. Nuclear waste has the ability
to cause major damage to the human body resulting in death.
It is now that we must come together and work towards creating a better world that relies on alternative forms
of energy. There are alternatives to uranium that are safer and just as profitable.
We need to protect our resources not only for their cultural and historical relevance but out of respect for what a
gift it is to be alive and for our future generations.
Thank you again for your time and please feel free to contact me if you have any questions!
l
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Shea, Valois
From:
Sent:
To:
Subject:
Sunday, March 12, 2017 8:50 PM
Shea, Valois
Disposal of uranium mining waste in SD aquifer
Hello:
I just wanted to express my opinion on the above subject.
I think it would be a horrible idea with an adverse impact on the ground water. I also believe it would be detrimental to
the environment of Black Hills.
Please do not permit this and thank you for being interested in the public's opinion.
Best regards,
l
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Shea, Valois
From:
Sent:
To:
Subject:
Wednesday, March 15, 2017 12:32 AM
Shea, Valois
UIC
Please do not permit injection of uranium recovery waste.
l
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Shea, Valois
Sent: Monday, June 19, 2017 5:29 PM
To: Shea, Valois
Subject: Proposed Dewey-Burdock Uranium In-Situ Recovery Site near Edgemont, SD
I am opposed to this project.
-------
Shea, Valois
Sent:
To: Shea, Valois
Subject: Fw: EPA draft permits to Powertech, a division of Azarga Uranium Corporation of
Canada
Forwarded Message
From:
To: "shea.valois@epa.gov"
Sent: Wednesday, May 17, 2017, 3:20:39 PM CDT
Subject: EPA draft permits to Powertech, a division of Azarga Uranium Corporation of
Canada
"The Inyan Kara, Minnelusa, and Madison aquifers are the principal sources of ground
water in the northern Black Hills, South Dakota and Wyoming, and Bear Lodge Mountains,
Wyoming. The aquifers are exposed in the Bear Lodge Mountains and the Black Hills and
are about 3,000 to 5,000 ft below the land surface ... The direction of groundwater
movement is from the outcrop area toward central South Dakota." USGS Study,
https://pubs.er.usgs.gov/publication/wri864158
Three public hearings were held, one each in Rapid City, Hot Springs, and Edgemont.
This is a FACT. The USGS advises against going ahead and yet you issue these permits
to endanger the public. You have been found out. Cease and desist.
Thank you for your attention
> We do not write because we want to;
> we write because we have to.
> > Somerset Maugham
says:
http://en.gravatar.com/helgaleena
http:/ /helgaleena.blogspot.com
https://rainydavreadspubHshing.com/
https://paper.li/f-1322418561
the Healing Line 608-255-0504 USA
-------
Shea, Valois
From:
Sent:
To:
Subject:
Wednesday, May 17, 2017 3:00 PM
Shea, Valois
No uranium waste storage on Lakota land
Dear Valois Shea,
I'm writing to ask that the EPA deny the permits for the proposed Dewey-Burdock Uranium Mine project. This
proposed mining project is likely to contaminate aquifers of the Black Hills and put the health and safety of
those drinking that water at risk. In addition, the mining project is next to the Black Hills, and is within the
boundaries of an area set aside for the tribes of the Great Sioux Nation by treaties signed in 1851 and 1868. The
Black Hills are sacred to the Lakota Nation. These tribes oppose this mining project; it violates their 1851 &
1868 Treaty Rights and they did not give up their water rights or mineral rights to these areas. The EPA must
deny these permits.
Thank you very much for your time.
Take care,
-------
Shea, Valois
From:
Sent:
To:
Subject:
Friday, May 19, 2017 2:22 PM
Shea, Valois
comment on permits for Powertech
Dear Ms. Valois,
Please do not move forward with the granting of permits to Powertech and Azarga Uranium Corporation of
Canada. The Inyan Kara aquifers are too important and the risks are too high. All over the United States fresh
water sources are at risk of contamination and pollution. The purity of our water must be made a top priority.
Yours sincerely,
-------
Shea, Valois
Sent: Sunday, March 12, 2017 8:56 PM
To:
Subject: Uranium injection disposal
I am writing to comment on this proposal. I am a tax paying citizen who works hard as does my husband to
provide a safe living environment for out children to grow. It is not much of a stretch to infer that there are
thousands of others just like us in the area where you propose to inject radioactive waste near the fresh water
aquifers. Yes, I know the mines are required to treat the waste & continue to monitor it after its disposal, but
that is absolutely unacceptable. Absolutely, 100% UNACCEPTABLE. The material in question will certainly
impact the groundwater as well as all the living things in the immediate area. The proponents of this action love
nowhere around such toxins & frankly do not care who is affected... especially since the residents are Indians,
poor, & sorely disenfranchised, & poorly educated for the most part. This proposal is a disgrace to the country
& evidences a deep disregard for the citizens in general, not just the Black Hills residents.
Sincerely,
-------
Shea, Valois
From:
Sent:
To:
Subject:
Thursday, March 16, 2017 6:10 AM
Shea, Valois
Underground Injection Control (UIC) Draft Area Permits
Dear Ms. Shea,
Please accept this communication as a formal comment regarding the proposed two Underground Injection Control (UIC) Draft
Area Permits and one associated proposed aquifer exemption decision for the Dewey-Burdock uranium in-situ
recovery (ISR) site located near Edgemont, Sooth Dakota, under the authority of the Safe Drinking Water Act and UIC
program regulations.
I urge the EPA to deny both of these permits. Among other hazards, radon emissions, toxic heavy metals and other pollutants,
including chloride, sulfate, sodium, radium, arsenic and iron, are in ISR wastewater ponds. Accidents and leaks in this kind of
operation are inevitable, raising concerns about runoff into the Cheyenne River and Angostura Reservoir. As you are aware, the
most serious radiation release in the US came from a tailings pond spill at a uranium mine in New Mexico.
We can live without uranium but not without clean water and soil.
Best regards,
1
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Shea, Valois
Sent: Wednesday, May 24, 2017 6:37 AM
To:
Subject: Underground Injection Control (UIC) Draft Area Permits
Dear Ms. Shea,
Please accept this communication as a formal comment regarding the proposed two Underground Injection
Control (UIC) Draft Area Permits and one associated proposed aquifer exemption decision for the Dewey-
Burdock uranium in-situ recovery (ISR) site located near Edgemont, South Dakota, under the authority of the
Safe Drinking Water Act and UIC program regulations.
I urge the EPA to deny both of these permits. Among other hazards, radon emissions, toxic heavy metals and
other pollutants, including chloride, sulfate, sodium, radium, arsenic and iron, are in ISR wastewater ponds.
Accidents and leaks in this kind of operation are inevitable, raising concerns about runoff into the Cheyenne
River and Angostura Reservoir. As you are aware, the most serious radiation release in the US came from a
tailings pond spill at a uranium mine in New Mexico.
We can live without more uranium but not without clean water and soil.
Best regards,
-------
Shea, Valois
From:
Sent:
To:
Subject:
Friday, April 21, 2017 5:26 PM
No Uranium Mining in Black Hills
NO URANIUM IN TREATY TERRITORY
Prottct ill** "wtl privtin* Aciwrferi in
world, OUR HONE IN UNCI MAMA - THE
BLACK HILLS AQUIFERS
SAY NO TO THE DEWEY BURDOCK
URANIUM AQUIFER MINING
4 WAYS TO SUBMIT PUBLIC COMMENT:
ENDS MAY 19,
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-MARCH RALLY FEED TBA
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•MARCH RALLY FEED TBA
67 PASSENGER CARAVAN FROM PINE RIDGE TO RAPID CITY EACH
DAY OF HEARING IS AVAILABLE,
7am Depart -9am Return at Billy Mill* Hall Mm Rid0o, SD
PLEASE COME JOIN US MITAKYEPI
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Thanks
Sent from my iPhone
1
-------
Shea, Valois
From:
Sent:
To:
Subject:
Friday, May 19, 2017 4:52 AM
Shea, Valois
Uranium mining by PowerTech
Dear Ms. Valois,
I am writing to express my concern about allowing PowerTech to drill for uranium mines in the Black Hills
area. These mines could put the aquifers in the area at extreme risk for the entire region.
We need to do everything possible to protect our waterways for the protection of our citizens.
Please reconsider this permit.
Thank you
-------
Shea, Valois
From:
Sent:
To:
Subject:
Monday, March 13, 2017 3:17 PM
Shea, Valois
Uranium mining
NO NO NO, it is not OK to mine uranium. Do your job EPA and start protecting people and the environment. It
is treason to put corporation profits ahead of the job you are supposed to be doing.
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Shea, Valois
Sent: Tuesday, March 14, 2017 9:58 AM
To:
Subject: Comments on uranium mining
Hello,
I am writing to express my concern about the proposed uranium mining in South Dakota.
I am very much AGAINST this idea and urge you not to proceed! This is very dangerous for our environment.
Thank you,
-------
Shea, Valois
From:
Sent:
To:
Subject:
Tuesday, May 16, 2017 4:05 PM
Shea, Valois
Powertech for uranium mining
These Lands belong to the Native Tribes, they are Sacred and/or Treaty Lands. This proposal will deface and
pollute and contaminate the land. Why is this necessary? We need clean water & land more than we need uranium.
After doing some research, most of the uses are for military situations. The half-life is 4.5 BILLION years-really, you
want to pollute/contaminate the land & water for the next 4.5 billion years? The world has some really innovative
scientists who, I am sure, can come up with better ideas which won't destroy our Blue Planet. Next, you want to
force the ugly waste back into the earth where it can devastate the aquifers-boy, you are just full of great ideas.
Would you take that water back to your family & friends to drink or wash in or swim in or water your plants in? If you
dont want this kind of stuff for your neighborhood, WHY, do you think it is a good idea for others?
Please re-think this, it is NOT good for the land or people.
In serious doubt,
-------
Shea, Valois
Sent: Sunday, March 12, 2017 8:33 PM
To: Shea, Valois
Subject: Nuclear waste
Why not just force feed that waste to the people. Cut out the middle man as it were.
l
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Shea, Valois
Sent: Thursday, May 18, 2017 9:44 PM
To: Shea, Valois
Subject: Black hills uranium mining
Please please to whom this may concern the permit for mining uranium in the black hills must be denied. We can not
take chances with our most precious resource water. Water is life and We can not allow the future of this most precious
resource to be put at risk. If u have to make exceptions to clean water rules to allow a foreign company to dump poison
into this finite resource that tells u right there that it is not a goood idea. I don't under stand how the tribe can b water
protectors only when politics allow. This mining and poison disposal can not b allowed to go forward please use
common sense in this matter and protect out drinking water from being ruined for profit of greedy Hippocrates.
Piedmont South Dakota
Tax payer
Land owner
Black hills resident
Sent from my iPhone
l
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May 20, 2017
Ms. Valois Shea
U.S. EPA Region 8
Mail Code: 8WP-SUI
1595 Wynkoop St.
Denver, CO 80202-1129
Fax: 303-312-6741
Email: shea.valois@epa.eov
Re: Powertech/Azarga Uranium Corp, Dewey Burdock
Comment for the Class III and Class V Injection Well
Permits and the Ivyan Kara aquifer exemption.
Dear Ms. Shea:
I am a retired U. S. Naval Captain (06) who served in Naval Intelligence and worked in concert
with the Central Intelligence Agency during the Desert Shield/Desert Storm War with Iraq. I
headed up a unit which tracked Saddam Hussein's chemical warfare capabilities and interdicted
technology and critical materials to keep Hussein from deploying his arsenal of war gasses on
coalition troops. I hold graduate degrees in Biochemistry and Health Care Administration. I am
qualified and considered an expert in chemical warfare weapons.
I have long been concerned about the Black Hills Army Depot (BHAD) which is a 21,000-acre-
site, just south of the Dewey Burdock area where Azarga wants to have an in situ leach uranium
mining operation and a huge waste disposal program using underground injection wells. They
wish to dispose of radioactive and very toxic waste from other uranium mining sites and oil and
gas fracking sites.
The BHAD which operated from 1941 to 1968 was the world's largest chemical warfare agent
storage site, handling such lethal agents as sarin, soman, toban, GB, VX, German top secret
chemicals recovered after WWII, mustard gas, Lewisite, and phosgene and others. The US
chemicals were brought to the BHAD in preparation for WWII by the thousands of tons. Some
were in canisters and others were in the form of rockets or other delivery systems. These
agents are extremely lethal, and are gaseous at temperatures above 55 F.
These agents are soluble in water and oil and cannot be neutralized in their present storage
configuration at the BHAD. Many were dumped in over 200 miles of trenches or stored
1
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underground. Most are now unstable and some have explosives attached, which are
decomposing and have a great tendency to auto ignite. They are too dangerous to move.
Some agents are percolating down through the shale that covers the site, and most are sitting
in cave structures under the depot. The Wind Cave structure extends under the Dewey
Burdock area and under the BHAD.
Any significant disturbance to the underground area including the Dewey Burdock area has a
great potential to release large quantities of lethal chemical warfare agents into the air and
local creeks. There would be no way to control these releases or minimize their effects. A
toxic and lethal cloud could spread from the BHAD killing every living thing within its path.
The drilling of 4000 wells to support the uranium mining operation would create tremendous
geological stresses. Azarga has admitted that they will inject water and C02 under pressure
along with lixiviants (as yet unidentified) designed to dissolve the underground rock strata
containing the uranium. Water and C02 create the highly caustic carbonic acid. They then
propose to pump the dissolved uranium several miles under pressure to a processing plant
where they will leach out some of the uranium. The resulting toxic sludge, which will still be
highly radioactive and laden with heavy metals such as arsenic, the carbonic acid, the lixiviants
and the dissolved rock, will then be forced back into the well fields, again under pressure.
This process will create a plume of pressurized toxic dissolved rock which will spread out from
the well field area, contaminating everything in its path, destroying valuable water aquifers,
and eventually reaching the BHAD. To date, there has never been an in situ leach uranium
mining operation which has not destroyed underground water. DESPITE SERIOUS ATTEMPTS
TO CONTROL THE PLUMES, NO SITE HAS BEEN TOTALLY CONTROLLED TO DATE.
It is my conclusion, based on available documentation, that these plumes will adversely affect
and destabilize the chemical warfare agents below the BHAD. Thus, there is the potential for
setting off a disaster of unprecedented magnitude.
There is no way to control the chemical warfare agents under the BHAD. We do know that the
Wind Cave structure is huge and contains 300 foot deep caverns in some places. The water
aquifers are mingling with the Madison aquifer in the Wind Cave structure. Pressurizing these
wells could cause these chemicals to move, dissolved in the large amounts of water already
underground in the area.
Azarga also proposes to dump radioactive toxic waste from other areas into the Class V wells
also under pressure, adding to the problem. They have now requested a water permit from the
state of South Dakota for 15,000 gallons per minute, indefinitely.
I understand that Azarga has increased their water permit request from 9,000 to 15,000 gallons
per minute to accommodate the huge amount of toxic waste and they intend to haul in from
2
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out of area locations and dump into the well sites. These actions would result in contamination
of the aquifers.
Indeed, they also want a permanent exemption for the Inyan Kara aquifer from the Safe
Drinking Water Act. This aquifer is a drinking water, household water use, and livestock water
source in the immediate area. This should not be allowed.
By this letter, I wish to strongly advise against permitting any part of this permit application.
We can only speculate about the actual status of the chemical warfare agents underground in
the BHAD. We know that these agents if disturbed will create a hideous release of toxic
chemicals from weapons of mass destruction.
I am also aware that the Russians through Uranium One and the Chinese through the Azarga
connections to Hong Kong own a substantial part of Azarga Uranium Corp. Neither of these
nations are considered allies of the United States.
The operation of this project will cause hundreds of trucks and truck convoys, carrying
potentially lethal cargoes to move through the Black Hills and the Edgemont/Hot Springs area.
These trucks, if a wreck occurs could cause a "dirty bomb" type of accident, in which radio-
active material would be spread throughout the area. It would be impossible for local law
enforcement to monitor these trucks or effectively keep their cargo (yellow cake) from heading
north toward the porous Canadian Border.
Uranium One has a financial interest in Azarga's Dewey Burdock Project, which is least 30%.
The Russian mining company, Uranium One which is owned by Vladimir Putin, now has at least
20% and some say 50% of the uranium mining leases in the United States. Thus, if permitted,
Azarga will be in a legal position to mine uranium in the United States, and ship it to its trading
partners, including Iran, Syria, and a host of other bad actors. China has been trading heavily
with North Korea, which has stated its desire to build nuclear weapons, capable of attacking US-
Asian allies, and the United States.
THE ACTUAL OWNERSHIP OF POWERTECH/AZARGA IS INIMICAL AND SHOULD PRECLUDE THIS
COMPANY FROM BEING GIVEN ANY PERMITS AT ALL BY THE UNITED STATES GOVERNMENT.
I trust you will consider this letter carefully and deny all permit requests. Please call me at^J
if you have further questions.
Sincerely,
3
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Shea, Valois
From:
Sent:
To:
Subject:
Sunday, March 12, 2017 8:27 PM
Shea, Valois
Inyan Kara Group aquifer injection wells
I strongly oppose the proposition to allow injection of "process waste fluids" into the Inyan Kara Group aquifer. I am not
confident in the safety of such an action under ideal circumstances. Our current administration's lack of interest in
environmental issues only deepens those concerns.
I am not comfortable with this action. The presence of monitoring is an admission that contamination can take place. If
such contamination occurred, it would not be possible to thoroughly remove it. The aquifer would be tainted.
Drinking water is one of our most valuable resources.There are already too many dangers facing our current sources.
Deliberately and consciously endangering these resources any further is simply ludicrous. The dangers are too real and
too costly. This cannot be allowed to happen.
Sincerely,
-------
March 25, 2017
Valois Shea
U.S. EPA Region 8
1595 Wynkoop Street
Denver, Colorado 80202-1129
Docket No. 40-9075
RE: the Dewey-Burdock Class III and Class V Injection Well Draft Area Permits
Dear Ms./Mrs. Shea,
My name is and below you can find my comments on the Dewey-
Burdock Class III and Class V Injection Well Draft Area Permits. On paper, the Dewey
Burdock project seems like a reasonable idea that could create potential benefits for
particular groups of individuals, but not the common good. This Dewey-Burdock project
is a multi-faceted issue that can threaten the environment and groundwater, take control
of tribally significant lands, and create an unnecessary potential for an accident.
The EPA should not move forward with the Underground Injection Control
permits and exemptions for the Dewey-Burdock site. The potential costs and
consequences that could arise from this project are simply not worth the benefits it claims
to produce. It seems that groundwater continues to pop up as a reoccurring theme that can
be found at the center of many environmental conflicts these days. Especially, as climate
change continues to advance and makes issues such as drought more prominent; water
(particularly potable groundwater) has become a valuable resource that shouldn't be
compromised. Surface water continues to be polluted, rain is becoming more infrequent
and unreliable as a source of drinking water (particularly in arid regions), and this has
created a further need for these groundwater sources and reserves.
-------
Native Americans have been consistently exploited in our nation and have had
sacred lands taken from them to allow for the extraction of resources too many times. The
Dewey-Burdock project would continue and encourage this trend, whether it is
intentional or not. Uranium mining and the technologies associated with this process also
create a danger and risks for an accident or mistake to be made along the way. A lot can
go wrong, particularly when injecting wastewater from uranium mining back down into
aquifers. There are preventative measures put into place to avoid and deal with accidents,
but when it comes down to it, there is no way to guarantee safety.
There are issues that arise when evaluating the safety and potential consequences
of tampering with uranium, especially within/close to these aquifers. One major concern
is that these deep injection wells are supposed to place this wastewater into the Minnelusa
Formation where it will hopefully continue to remain and prevent any harm, but the
threat is still there (EPAa, 2016). The water isn't guaranteed to stay within the Minnelusa
Formation as the USGS has identified that, "Fracturing from folding and brecciation
near the outcrop may have increased the permeability of the lower part of the
Minnelusa a considerable, but unknown, amount" (Kyllonen, D. P., & Peter, K. D.,
1987). This is obviously concerning to know that this wastewater may not remain within
the Minnelusa Formation and permeate through, especially considering how many other
aquifers are in the surrounding areas. It even states on EPA's UIC website that, "This
disposal can pose a threat to ground water quality if not managed properly," and "The
different types of Class V wells pose various threats" (EPAa, 2016). While precautionary
measures can be taken, there is absolutely no guarantee that Powertech will be able to
properly manage and avoid potential accidents/threats from occurring.
-------
In regards to legal discrepancies, there seems to be many that are associated with
this project. The fact that an exemption from the Safe Water Drinking Act is needed to
proceed with this uranium extraction says a lot in itself (EPA, 2016). This Safe Drinking
Water Act was enacted to protect our nation's potable water sources, and therefore,
should continue to do this instead of allowing exemptions that compromise the safety of
the water within these aquifers.
When considering the wellbeing and interests of Native American tribes, the
Dewey-Burdock project oversteps onto the rights and important lands that these tribes
cherish. There are still plenty of agreements that must, but may not be reached with these
tribes and as the Nuclear Regulatory Commission states, "The NRC identified 23 Native
American tribes that attach historical, cultural, and religious significance to sites within
the Dewey-Burdock ISR Project area" (NRC, 2014). Twenty-three is a very large number
and they should all have a voice that is heard and acknowledged by our democratic
system to prevent this project from occurring. The value of historic land and loss of
culture cannot be made up with money.
The Dewey-Burdock project is not a reasonable investment to move forward with
because of all the different issues and threats that it creates. Red flags continued to appear
the further I researched these plans to allow ISL uranium mining, and the implications
that would arise as a result. Groundwater is a resource that should be conserved instead of
wasted to allow for mining and the storage of the wastewater afterwards. Significant
Native American lands should be respected and left alone especially when the
degradation of it is a certain consequence. Lastly, accidents happen all the time and there
is no precaution that can exempt this project from failures and the detrimental
-------
consequences that would be afflicted. The cons discreetly but surely arise in regards to
this project, and it seems like an obvious decision to abandon this project and not allow
the permits & exemptions that are needed to progress.
Contact info:
Cordially,
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Works Cited
EPA (2017). Class III Injection Wells for Solution Mining. (2016, November 07).
Retrieved March 27, 2017, from https://www.epa. gov/uic/class-iii-iniection-wells-
solution-mining
EPAa (2017). Class V Wells for Injection of Non-Hazardous Fluids into or Above
Underground Sources of Drinking Water. (2016, October 31). Retrieved March 28, 2017,
from https://www.epa.gov/uic/class-v-wells-iniection-non-hazardous-fluids-or-above-
under ground-sources-drinking-water
NRC (2014). Environmental impact statement for the Dewey-Burdock Project in Custer
and Fall River Counties, South Dakota: supplement to the generic environmental impact
statement for in-situ leach uranium milling facilities, final report. Washington, D.C.:
United States Nuclear Regulatory Commission, Office of Federal and State Materials and
Environmental Management Programs. Retrieved March 28, 2017 from
https ://www.nrc. gov/reading-rm/doc-collections/nure gs/staff/ sr 1910/s4/v 1 /
Kyllonen, D. P., & Peter, K. D. (1987). Geohydrology and water quality of the Inyan
Kara, Minnelusa, and Madison aquifers of the northern Black Hills, South Dakota and
Wyoming, and Bear Lodge Mountains, Wyoming (pp. 1-58) (United States, U.S.
Geological Survey, Department of Interior). Rapid City, SD: Dept. of the Interior, U.S.
Geological Survey.
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Shea, Valois
Sent: Tuesday, June 13, 2017 1:41 PM
To: Shea, Valois
Subject: PUBLIC HEARINGS - Protect Water for Future Generations.
https://bhcleanwateralliance.org/public-hearings/
Proposed
Sent from my iPhone
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Shea, Valois
Sent: Sunday, June 18, 2017 11:34 AM
To: Shea, Valois
Subject: Dewey-Burdock Permits
Please deny exemptions and permits to Powertech Inc. for uranium mining in Custer County.
1. The Inyan Kara aquifers hold viable drinking water. While not pristine, the water is usable as is. A local rancher was
using the water for his livestock until Powertech bought him off and closed his well so they could meet the requirement
that no one was using the aquifer. We need to protect all viable drinkable water.
2. Powertech is an unproven foreign company that has no vested interest in keeping the area safe. The uranium
produced will be sold to foreign markets, the jobs created will be minimal and mostly short term. This mine will not
benefit the US or it residents and can only harm our environment.
3. There is nothing in the permits that prevents Powertech from selling "space" in the injection wells to other companies
for waste disposal of toxic materials. Since the price of uranium is so low, is this their prime objective and who regulates
what may be disposed?
4. The "best guess" is that the aquifer won't leak but there is no proof I With possible gas/oil exploration in the area,
there is the possibility of future fracking which could lead to earthquakes/fissures. The Madison aquifer which lies below
Inyan Kara is the source of water for residents in multiple states. This aquifer should NEVER be put at risk.
5. Because of the rural nature of this project, you will not receive thousands of protests but please consider the
percentage of people from the area who are against this. If this were to take place outside of Denver, you would receive
thousands of emails but 50 people from the area could be 90% of the area population!
Please remember that it is the EPAs responsibility to protect our environment, not to issue exemptions (no matter what
the political climate is). You are the last hope for area residents to keep as much viable drinking water as possible for
themselves and their livestock, and more importantly, for future generations. Please don't risk contamination for the
benefit of a foreign company with no proven record and no benefit to the citizens of the US.
Please deny the permits and exemptions and PROTECT OUR ENVIRONMENT!
Sent from my iPad
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Shea, Valois
Sent: Sunday, June 18, 2017 11:42 AM
To:
Subject: Thanks for the reminder!
Thank you for the reminder of the Dewey-Burdock comment period. I sent my comments to your email because the
other contact sites seemed to route it through D.C. Hope that is okay.
Thank you for your work in protecting our environment! I'm not a "tree hugger" as my husband would say, but I believe
strongly in the protection of our planet. It's the only one we have! Keep up the good work regardless of the political
scene. You are doing important work!
Thanks!
Sent from my iPad
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Shea, Valois
From:
Sent:
To:
Subject:
Wednesday, March 15, 2017 7:58 AM
Shea, Valois
Permission request to contaminate aquifer?
EPA:
I am appalled that anyone would think this is a good idea. I am almost speechless that it would be considered by
the EPA. Please do not foul any aquifers. I would go so far as to BEG you to reject this idea. Aren't we
supposed to be protecting this planet? Isn't this, in fact, our only home? Do not permit this disastrous proposal.
Respectfully submitted,
"(Denver, Colo. - March 6, 2017) EPA has issued two draft Underground Injection Control
(UIC) Area Permits to Powertech (USA) Inc., for injection activities related to a proposed
uranium recovery project in the southern Black Hills region in Custer and Fall River Counties
of South Dakota. EPA will conduct information sessions combined with public hearings on
April 27th and on May 8 through May 11 at the times and locations detailed below. EPA will
accept public comments on the draft permits and a proposed aquifer exemption associated
with the project through May 19, 2017.
The draft permits issued today include a UIC 'Class III' Area Permit for injection wells for the
in-situ recovery (ISR) of uranium in the Inyan Kara Group aquifers and a UIC 'Class V' Area
Permit for deep injection wells that would be used to dispose of ISR process waste fluids into
the Minnelusa Formation below the Inyan Kara after treatment. Under the terms of the draft
permits, waste injected under the Class V permit must be treated prior to being injected and
must meet all radioactive waste and hazardous waste standards. Monitoring of the
underground sources of drinking water surrounding the Class III injection wellfields will take
place before, during and after ISR operations to ensure the underground sources of drinking
water are protected.
EPA is also proposing an aquifer exemption approval in connection with the draft UIC Class
III Area Permit. Specifically, this approval would exempt the uranium-bearing portions of the
Inyan Kara Group aquifers from protection under the Safe Drinking Water Act. Such an
exemption must be in place before ISR activities within these aquifers can occur.
Under its obligation to comply with the National Historic Preservation Act and under EPA's
Tribal Policy on Consultation and Coordination with Indian Tribes, EPA has been consulting
and coordinating with several interested Tribes to identify the potential effects of the proposed
project on traditional cultural places, historic and sacred sites. EPA will continue to consult
and coordinate with Tribes as necessary throughout the public comment period concerning
these proposed permitting actions.
The public is encouraged to provide comment on these draft permits and the aquifer
exemption by midnight mountain time, May 19, 2017. EPA's final permit decision will be
based on an evaluation of comments received and a determination of whether underground
i
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sources of drinking water are protected. The draft permits can be found at the EPA Region 8
UIC Program website: https://www.epa.gov/uic/yic-eDa-reQion-8
How to Comment: Written comments must be received by email, fax or mail sent to:
Valois Shea (shea.valois@epa.gov); Fax: 303-312-6741"
ixi
norsetter.com
2
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Shea, Valois
From:
Sent:
To:
Cc:
Subject:
I oppose the Dewey Burdock Uranium acquirer mining. I do not want Uranium mining in treaty territory acquirers in the
Black Hills. I do not want class 5 or class 3 wells in the Black Hills. I say no to any permits for uranium mining in the Black
Hills.
In addition I want all of the old mines in the Black Hills cleaned up before any further permits are considered. I also want
tribally defined consultation as well as full tribally approved archeological and cultural surveys done. Finally I want
Lakota translators/transcriptionists at all hearings.
Sent from my iPhone
Friday, May 19, 2017 2:33 PM
Shea, Valois
Jayme Huff
No to Dewey Burdock Uranium acquirer mining
1
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Intro: My name is 17 year resident, raising kids in the black hills. I own
property along the Cheyenne River, I have animals that drink from it, I have an Inyan
Kara domestic well that supplies household water and drinking water for livestock. I haul
my family's drinking water from a minnelusa well, (see attached well log data from
Ferguson well adjacent to Belitz 320 ft well. Belitz well log is missing) (note flowing cave
in Ferguson well).
Yes, I understand the interest a mining company would have in ISL at the Dewey /
Burdock location . I do, however, feel that my water and the water of my community
could be irreversibly harmed. Besides inadequate standards for settling pond waste that
could potentially contaminate the river and the much utilized Angostura Reservoir, today
we are talking about Aquifers. The Inyan Kara and Minnelusa.
UIC (Underground Injection Control) Class III Area Permit for Inyan Kara Group
Aquifers.
These proposed mining activities pose a risk to my Inyan Kara water by undetected or
late detected excursions as I am down gradient from the mining activity.
UIC Class V area Permit for deep injection wells that would be used
to dispose of in situ mining waste fluids into the Minnelusa
Formation.
The Minnelusa aquifer is a high quality and well utilized aquifer in the southern black
hills. In addition to the domestic Minnelusa well that we haul drinking water from, this
aquifer sits approximately 1000 ft below my property making it a potential drinking water
source for my family and livestock for generations to come. According to "Atlas of Water
Resources of the Black Hills", the Minnelusa Aquifer flows from the proposed ISL site to
my property. The contaminates injected are likely to pollute this potential drinking water
source sometime in the future.
When I spoke with 4 Hydrologists at the USGS on March 29th 2017, I learned the
following. Yes, the flow model (Fig. 114, pg.103 Atlas of Water Resources of the Black
Hills) does indicate the Minnelusa flowing from Dewey / Burdock to the south east.
However, you can not just look at this model. The water in these aquifers, can be really
hard to track their flow. In cave environments such as the Minnelusa , underground
water almost flows like a river. There are local and regional impacts on the flow systems
that are not indicated on Fig. 114.
According to a National Water Data Base, there are a minimum of 125 wells drilled into
the Minnelusa Aquifer in Fall River County. I believe there are more. My Families Well
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was drilled approximately 20 years ago and there is no record of it in the current State
DENR Well log data site. Speaking with a DENR employee May 9th,2017, I was told that
many well logs were not submitted especially those during or before the 1980's.
We know that the Minnelusa and the Madison (a highly utilized and extremely important
aquifer) mix.
The USGS Atlas of Water Resources of the Black Hills, Pg 109 Table 13 indicates
Cascade Springs is mostly Madison with dissolved Minnelusa minerals. Cascade
Springs is also a utilized drinking water source, Cascade falls is a highly visited
swimming area attraction, and the 1880 irrigation system from this source provides
water for over 1000 acres of hay, fruit and vegetable production and livestock watering
ponds for area land owners including my own pond, hay fields, and apple orchard.
The Minnelusa Formation is overlain by the Opeche Shale, which separates the
Minnelusa aquifer from the Minnekahta aquifer. The Minnelusa aquifer often is
hydraulically separated from the underlying Madison aquifer by shales in the lower
portion of the Minnelusa Formation. However, in many areas the Minnelusa aquifer
is in hydraulic connection with the Madison aquifer.
fhttps://pubs.usas.aov/ha/ha745c/ha745cIntro.html
Potentiometric Surface of the Minnelusa Aquifer in the Black Hills Area, South
Dakota
By Michael L. Strobel and Joel M. Galloway, U.S. Geological Survey; and Ghaith
R. Hamade and Gregory J. Jarrell, South Dakota School of Mines and Technology
U.S. GEOLOGICAL SURVEY
Hydrologic Investigations Atlas HA-745-C
Prepared in cooperation with the
South Dakota Department of Environment and Natural Resources
and the West Dakota Water Development District)
Information on Deep Well injection in North Dakota
State geologist Ed Murphy says injection wells are required to be drilled into the Dakota Group
zone, a layer about 5,000 feet down where the Inyan Kara sandstone formation provides a
porous container for the liquid.
(LAUREN DONOVAN Bismarck Tribune Mar 31,2016)
Other requirements for the permitting process:
• SWD's over shallow aquifers require a geotechnical analysis by a qualified,
independent contractor before a proposed location will be considered. This is to
determine the suitability of the shallow subsurface geology to protect the
shallow aquifer.
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• Injection must be into a formation with an upper and lower confining zone to
prevent migration of fluids into other formations or fresh water zones. In North
Dakota, the disposal zone is typically one half mile to one mile below the
surface, into the Dakota Group.
rhttps://www.dmr.nd.Qov/oilaas/underaroundfaq.asp#mrlQ^
Because of this scientific data, I believe the EPA should not even consider
permitting a UIC Class V area Permit for deep injection wells that would be
used to dispose of in situ mining waste fluids into the Minnelusa Formation.
The Minnelusa is too shallow, it is unconfined, it is known to mix with a very
important aquifer, and is itself is an important and currently used aquifer.
Thank you for protecting our water,
Sincerely
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Shea, Valois
From:
Sent:
To:
Subject:
Tuesday, March 14, 2017 12:00 PM
Shea, Valois
U.S. EPA Region 8 Mail Code: 8WP-SUI
The long term ( permanent) disadvantages of this proposal far outweigh the limited short term advantages. Please
consider the future safety of Americans and our water supply before bowing down to mining companies.
The disadvantages of the in-situ leaching technology are:
the risk of spreading of leaching liquid outside of the uranium deposit,
involving subsequent groundwater contamination,
the unpredictable impact of the leaching liquid on the rock of the deposit,
the impossibility of restoring natural groundwater conditions after completion of the leaching operations.
Impacts of Uranium In-Situ Leaching
http://www.wise-uranium.org/uisl.html
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Shea, Valois
From:
Sent:
To:
Subject:
Monday, March 13, 2017 9:04 AM
Shea, Valois
Fwd: Underground Injection Control (UIC) Area Permit
Ms. Shea,
I am taking the time to voice my opinion that underground injection should NOT be allowed. Water is precious and the
continuing pollution of our aquifers by corporations is criminal. This practice affects all of us and we have a right to be
protected from harmful acts of a few. Please deny this practice, protect water because none of us can survive without it!
Thank you,
l
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Shea, Valois
Sent: Tuesday, May 09, 2017 12:53 PM
To:
Subject: aquifer exemption for uranium mining project in southwestern South Dakota
Ms. Shea,
I am writing to comment on the uranium mining project in Edgemont, South Dakota. I am opposed to the
project for a number of reasons.
You were quoted in the Black Hills Pioneer as stating, "The best permit in the world isn't a guarantee that
nothing will happen," she said. "But there will be extra monitoring and remediation so if anything did happen,
we would catch it early and fix it."
I find this a troubling statement especially given the current political climate where science is being dismissed
in the interest of monetary gain. I by no means wish to question you personally as a scientist, but I feel that
there would be a lot of plausible deniability from Powertech should something go wrong with this project and
do not have confidence in the EPA as it currently exists that it would sufficiently enforce remediation should
something happen.
The EPA website also claims the following: "EPA is also proposing an aquifer exemption approval in
connection with the draft UIC Class IE Area Permit. Specifically, this approval would exempt the uranium-
bearing portions of the Inyan Kara Group aquifers from protection under the Safe Drinking Water Act. Such an
exemption must be in place before ISR activities within these aquifers can occur."
Why is an exemption required if nothing will happen that will affect the drinking water in this area. This seems
like a CYA move on the part of the EPA.
Finally, although I do not live in the Edgemont area, I am a resident of the Black Hills and my business is
dependent on clean water. I have heard (and acknowledge that I may be mistaken) that should the permits be
granted for this project that Powertech would like to expand its operations to other areas of the Black Hills. If
this is the case I would have a great concern over how this could affect my livelihood should something happen
to contaminate the groundwater in my area.
Thank you for incorporating my comments into the public record.
l
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Shea, Valois
From:
Sent:
To:
Subject:
Wednesday, March 15, 2017 9:18 AM
Shea, Valois
FW: Uranium injection into S.D. aquifer
From
Sent: Wednesday, March 15, 2017 8:36 AM
To:
Subject: Uranium injection into S.D. aquifer
I am adding my voice to state that the above subject is unconscionable! No, to permits to inject Uranium into
aquifers. Water for the future but be kept safe!
Si, se puede! jeso es!
'The Wind is Rising, we must strive to live" Jean Paul Valery and Miazaki
1
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Shea, Valois
From:
Sent:
To:
Subject:
Tuesday, March 14, 2017 1:42 AM
Shea, Valois
Inyan Kara Group aquifers
>
Please do not exempt anyone from regulations prohibiting the injection of uranium et al into the aquifers.
The mining company should still be subject to the regulations in place meant to protect the water. Do your job,
please (directed at the agency, not you specifically) You are the EPA for Pete's sake!
Thank you for the opportunity to comment.
Respectfully
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Shea, Valois
From:
Sent:
To:
Subject:
Monday, May 15, 2017 9:39 AM
Shea, Valois
Permits for Dewey-Burdock Uranium Mine
EPA,
I am writing to comment on the Underground Injection Control Program's Draft Permits for the Proposed Dewey-
Burdock Uranium Mine and Deep Disposal Wells.
The proposed mine and deep disposal wells are in an area that is documented to have faults, fractures, breccia pipes,
and over 7000 old boreholes that have not been properly plugged. It will be impossible to contain mining fluids or waste
liquids, and contamination of groundwater resources is very likely.
I am also concerned that adequate oversight of the quality of liquid wastes pumped into the Minnelusa Formation
through the proposed deep disposal wells will be inadequate, and groundwater is likely to be contaminated.
A full survey of cultural and historical sites is needed before mining or deep disposal is allowed. Cultural and historical
sites must be protected.
The history of uranium mining indicates that uranium mining cannot be done without creating and leaving
contamination. Groundwater has never been returned to its original condition at any In-Situ leach uranium mine in the
U.S. These permits must not be issued until it can be demonstrated that groundwater resources will be protected.
l
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Shea, Valois
From:
Sent:
To:
Subject:
Monday, May 15, 2017 12:08 PM
Shea, Valois
COMMENT: NO Uranium Mining in the Black Hills
Good afternoon,
I am writing this email as a US citizen and tax payer who is against the Dewey Burdock mining project in The
Black Hills.
I continue to be disgusted by the EPA's leadership and decision making concerning the environment. The
Black Hills are scared to the Lakota people and they should not be subjected
to the sickening greed that has harmed these First Americans in unimaginable ways.
Please respond to this email confirming that no mining will take place.
I thank you for your time.
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Shea, Valois
From:
Sent:
To:
Subject:
Monday, June 19, 2017 11:43 AM
Shea, Valois
Opposition to Dewey Burdock Uranium Aquifer Mining
I am writing with my public comment.
RE: Dewey Burdock Uranium Aquifer Mining, specifically permits in the area of the Inyan Kara group
of aquifers (in the Black Hills of Custer & Fall River counties) for uranium mining using deep-injection
wells.
We cannot put water - an essential resource - at such risk.
My key points:
• The Unci Maka are some of the most pristine aquifers in the world. Crazy Horse told his people he
wanted them to remember him whenever they saw the Black Hills. This is sacred land. Visitors to this
area come for contemplation, rejuvenation, and inspiration. I believe strongly in the value of our natural
environment. These treasures must be protected as unique and important to our history, the people who
live in the Black Hills, travelers to the area, the larger environment, and the people of the world.
• The proposal to exempt the project from the Safe Drinking Water Act is unacceptable. The EPA's duty
is to improve, not endanger, drinking water access (especially on tribal lands).
• This area already experiences severe weather, and the weather is likely to be much more extreme going
forward due to climate change. The proposal does not address what are likely to be seriously dangerous
weather conditions.
• Because the EPA's funding has been reduced, our government's ability to monitor the project is limited.
If standards are not met, the consequences are dire. Powertech failed to report that it possessed
thousands of records of drilling the Tennessee Valley Authority, and then only released 34 of 6,000
borehole logs. Back in 2015, Dr. LaGarry reviewed half of the newly disclosed drilling logs and found
the existence of faults in the area and that many boreholes were not properly plugged (which makes the
area unsuitable for in situ leach mining because the project won't be able to control the highly toxic and
carcinogenic mining fluids. For years, the industry has demonstrated that they will not be proactive and
will require monitoring.
• The National Historic Preservation Act requires tribal consultation. The current administration does not
respect America's indigenous people and the agreements we have with them. I have no faith that this
administration will adhere to the law, democratic principles, or human decency in their handling of the
Tribe's concerns.
• Contamination, if it happened, would be radioactive and effectively permanent. This is a serious
consequence.
Based on these concerns, I strongly oppose this proposal.
l
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Thank you for taking my comments.
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Shea, Valois
Sent: Monday, June 19, 2017 11:57 AM
To: Shea, Valois
Subject: Uranium mining in the Black Hills- public comment
Please do not further destroy the environment or erode the spiritual foundation of native peoples by mining in the
sacred Black Hills.
Uranium is dangerous, furthermore, and should be left in the ground.
Thank you,
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Shea, Valois
From:
Sent:
To:
Subject:
Monday, March 13, 2017 11:02 AM
Shea, Valois
Underground Injection Control (UIC) Area Permits to Powertech
Concerning the potential proposal of permits for uranium injection control into an aquifer, the US and the EPA
should be PREVENTING this level of environmental damage to not only our drinking water, but the entire
ecosystem. I would like to vehemently voice my opposition to this proposed draft permit. INj, but the water and
other natural resources this area provides. It's irresponsible to knowingly allow this level of damage to occur,
but it also goes against the very name of the EPA. How can you 'protect' an environment when you're proposing
a permit that allows for disposing of waste fluids in the process of uranium mining.
It's astonishing to me that this permit has even pushed to draft stage. As an agency that is supposed to work for
the people, for the environment and for the protection of natural resources, this flies in the face of all three.
I strongly urge the outright rejection of this proposed draft, as it could threaten human life and wildlife for
potentially many decades to come. It's astonishing to me that the EPA has failed the American public this
quickly.
Desperately,
l
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Shea, Valois
From:
Sent:
To:
Subject:
Tuesday, May 23, 2017 5:59 AM
Shea, Valois
Proposed Dewey-Burdock Injection Wells
Dear Valois Shea:
I am writing to express my strong opposition to Azarga Uranium's permit application for two Underground
Injection Control wells in the Black Hills.
Before I retired as editor of South Dakota Magazine and contributing editor of Nebraska Life, I wrote in-depth
investigative stories about the history of the insitu uranium mining project at Crawford, NE, the continuing
threat from unreclaimed mines throughout the Black Hills and the current issues involving the proposed Dewey-
Burdock project.
There are many reasons to reject the Azarga permit request. First, the threat posed by injecting waste into
aquifers (the out of sight, out of mind approach to a difficult problem) is unacceptable. There is no good reason
to pollute deep aquifers just because they are not currently used by man, and there is no way to assure that vital
aquifers would not be polluted.
Second, there is nothing besides a few low-paying, short term jobs in this for South Dakota, but great threats to
our two largest industries, agriculture and tourism.
Third, Azarga is a foreign-owned entity that hopes to exploit our resources for their short-term profit, but which
will have no loyalty or long-term commitment to the region.
Fourth, No further exploitation of uranium should proceed in South Dakota until the messes left by past mining
are cleaned up—which realistically is not likely to ever happen.
Fifth, the long history of companies (mostly foreign companies) exploiting our resources, then declaring
bankruptcy and walking away from their messes should tell us that this cycle is likely to be repeated if Azarga is
allowed to proceed.
In summary, there is no good reason to approve this permit, and many valid and critical reasons to say no.
Please reject Azarga's permit request.
Sincerely yours,
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Shea, Valois
From:
Sent:
To:
Subject:
Saturday, May 20, 2017 2:04 AM
Shea, Valois
public comment on uranium mining in southwestern South Dakota
Valois Shea,
If there is a risk of contaminating underground drinking water, even if it is a minimal one, I
think it is too BIG of a risk to take. Is there anyway the waste can be taken where there is no
drinking water to contaminate? Consider trucks or pipelines like the one used to move oil
across our country. Our natural resources are being depleted and if there is a contamination
of drinking water, that would be a bad thing. I was unable to make it to the hearing in
Valentine, but I would have liked to go and learn more about this process and issue. It is a
good idea, even with the risk involved, right up until the point when something precious and
irreplaceable is damaged or lost. It is at the point (and sometimes not until that point), the
point of no return, that it becomes very clear that it was a mistake.
There are so many EPA regulations that I do not understand, that are made in order
to "protect the environment". How is possibly contaminating such a valuable resource as
fresh drinking water any less offensive than "damaging a wetland", when someone simply
wants to clean out a ditch that runs through their property so it can drain more
efficiently? How is contaminated drinking water any less offensive than the idea of adding
pollutants to our air by building an oil refinery closer to the Canadian border, rather than
spending all the money, time, and resources to ship the product by truck or pipeline across
the country to an already running refinery?
Thank you for accepting comments other than at the hearings that you had set up. It is
good to have the hearings and have that resource available, but sometimes the meeting times
and places make it hard for those concerned and potentially affected, who are employed, to
attend. Thanks again for your time.
Sincerely,
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Shea, Valois
From:
Sent:
To:
Subject:
Monday, June 19, 2017 5:21 PM
Shea, Valois
Black Hills
Hello Shea,
Please refrain from proceeding with the plans outlined for permits and exemptions for the Black Hills uranium
project. I believe that the integrity of the sacred grounds and the safety of the surrounding area are in jeopardy
and believe that preservation of the Black Hills is a priority for South Dakota.
I appreciate your consideration and concern to this matter.
Cheers,
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April 26, 2017
U.S. EPA Region 8
Mail Code: 8WP-SUI
1595 Wynkoop Street
Denver, Colorado 80202-1129
Dear Valois Shea,
Attached for your review, please find comments on the EPA Region 8 UIC
Program is issuing two Draft UIC Area Permits to Powertech (USA) Inc., Suite #140,
5575 Denver Technical Center Parkway, Greenwood Village, Colorado 80111, for
injection activities related to uranium recovery.
Many know the Black Hills region of South Dakota as Mount Rushmore, but
these mountains are endangered. Currently, the U.S Environmental Protection Agency
(EPA) has publicized two Underground Injection Control (UIC) Area permits to
company Powertech (EPA, 2017). The two pending permits that will be under review
both endanger the purity of the aquifers in these mountains. The first permit is a UIC
'Class III' which would allow injection wells for the in-situ recover (ISR) of uranium in
the Inyan Kara Group aquafers (EPA, 2017). In order to ensure the safety of drinking
water sources, the aquifer will be monitored of before and after ISR operations (EPA
2017).
The second permit that the EPA is suggested that there would be an exemption for
the aquafer. Meaning that this exemption would exclude uranium-bearing portions of the
Inyan Kara Group aquifers from abided the Safe Drinking Water Act (EPA, 2017). In
order for this any ISR activities to occur this exemption must be in place. The second
permit is a UIC 'Class V' Area Permit for deep injection wells where the dispose of ISR
process waste fluids into the Minnelusa Formations below the Inyan Kara after treatment
(EPA, 2017). In addition, for the 'Class V' permit, the water being injected back into that
aquafer must abided by all radioactive waste and hazardous waste standards set by the
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Clean Water Act (CWA) and National Pollution Discharge Elimination System
(NPDES). These two permits should not be passed due to the dangers associated it with
UIC.
These permits should not be passed because for many years U.S industries have
been under a misconception that underground injections have not been harming the inner
core of the United States, when actually they have had extreme damages from disposes
and allowing these toxins underground. Over the last few decades U.S companies have
injected more than 30 trillion gallons of toxic liquid into the earth (Lustgarten, 2012). The
invisible natural resources of the United States are have now become their "invisible
dumping grounds" (Lustgarten, 2012). The sad part is many companies have gotten away
with toxin disposal for the sheer reason that it has been underground.
If these toxins were being disposed of above ground it would be a whole different
story, or even not allowed at all. A question that policy makers should be asking is if
companies were to inject or dispose of these toxins above the ground what would it look
like? Would people be okay with it like they are okay with underground waste? Prior to a
few years ago environmentalists and scientists didn't realize that deep layers of rock
would not be able to handle these toxins as they thought especially in years to come.
These two proposed permits are not by any means perfect. These two permits
have problems associated with them because of the dangers uranium in water can have.
Most people wouldn't drink bottled water or "purified water" if they knew it contained
uranium or even nitrates. There are already two aquifers in the United States that contain
uranium levels that exceed the U.S EPA maximum containment level (MCL) (Tasch,
2015). These aquifers are supposed to be proving clean water to almost 6 million people,
with 2 million living nearly less than a mile from these aquifers (Tasch, 2015). It has
been proven by the EPA and scientists that drinking high levels of uranium in which
exceed EPA standards can lead to increased risks for cancer, liver damages, and
reproductive complications (Tasch, 2015). These two aquifers are in the High Plains and
Center Valley (Tasch, 2015).
The High Plains aquifer is the largest in the United States spanning in over eight
states but is also very contaminated with uranium (Tash, 2015). The High Plains aquifer
exceeds the EPA's MCL limit for uranium by 89 times, but it is also contaminated with
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nitrate levels that fall at 189 times the EPA's MCL (Tasch, 2015). Then the second
aquifer is in Center Valley where the contamination level is even higher with uranium
concentrations 180 times the MCL and nitrate concentration levels 34 times the MCL
(Tasch, 2015). Science has proven that uranium and nitrate intake for humans as said
above can pose many health problems.
At a legal standpoint looking at both permits purposed they can violate the terms
of the Safe Drinking Water Act, CWA, and various of water acts that are put into place to
ensure quality drinking water. Mainly though, these permits would allow for a loop holes
for the Black Hills region to not have to abided by. If these permits are adopted it can
infect and pose health problems to those living around the aquifers. Sometimes
violations of these acts can be criminalized, or most companies face many heavy fines.
This March, the EPA issued these two draft Underground Injection Control
Permits. These two permits have the ability to change how we consider dumping mining
waste throughout the rest of the current Trump administration, or for far longer than the
next four years. These permits do not only have the potential to further have a negative
impact on health, but also on the limitations of drinking water. A population of concern is
the indigenous people who live near these aquifers. It is important to not allow these
permits to be put into place not only for the safety of drinking water quality but also
because people depend on the natural underground water supply.
Sources
Administrative Record for the Dewey-Burdock Class III and Class V Injection Well Draft
Area Permits. (2017, March 06). Retrieved March 23, 2017, from
https://www.epa.gov/uic/administrative-record-dewev-burdock-class-iii-and-class-v-
ini ection-well-draft-area-permits
Lustgarten, A. (2012, September 19). Injection Wells: The Poison Beneath Us. Retrieved
March 23, 2017, from https://www.propublica.org/article/iniection-wells-the-poison-
beneath-us/single#republish
Safe Drinking Water Act (SDWA). (2017, January 12). Retrieved March 23, 2017, from
https ://www.epa. gov/sdwa
Tasch, B. (2015, August 18). 6 million U.S. residents are drinking uranium-contaminated
water that could increase risk of liver damage. Retrieved March 23, 2017, from
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http://www.businessinsider.com/high-uranium-levels-of-drinking-water-in-the-central-us-
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Shea, Valois
Sent: Tuesday, May 09, 2017 6:17 AM
To: Shea, Valois
Cc: Virginia Stewart
Subject: Powertech in situ mining in SW South Dakota
Dear Valois,
I am writing to express my opposition to the proposed Powertech uranium mining project near Edgemont, South
Dakota. I am out of town and was unable to attend the hearings held in Rapid City at the Ramkota motel on
May 8 and 9 or I would have been there in person to express my opposition.
I live in a subdivision near Blackhawk, South Dakota which depends on the Madison and Deadwood aquifers
for our water supply. Given the history of mining companies in South Dakota leaving a huge mess for state and
federal government to clean up does not inspire my confidence in the Powertech proposal. I don't want to take a
chance on polluting our drinking water for a few bucks in uranium mining.
If the wastewater produced by Powertech's "in situ" process is safe let's have the executives of Powertech drink
a glass of that slop every morning and then I'll be convinced it really is ok for the mine to proceed. Until that
day I am adamantly opposed to allowing Powertech to proceed.
Sincerely yours,
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Shea, Valois
Sent: Monday, March 06, 2017 3:06 PM
To: Shea, Valois
Subject: Public Comment for Dewey-Burdock Injection Wells 8WP-SUI
I can't get on the USGS site to find the geologic maps of the relevant area; however, can you please comment on the
potential for connectedness between the proposed injections into the Minnelusa Formation and the Madison formation
which provides a prolific source of clean drinking water for the nearby City of Gillette.
Thanks,
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Shea, Valois
Sent: Tuesday, March 14, 2017 1:03 PM
To: Shea, Valois
Subject: SD aquifer
Absolutely NO uranium mining waste disposal in aquifer!
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Shea, Valois
From:
Sent:
To:
Subject:
Tuesday, March 14, 2017 8:08 AM
Shea, Valois
uranium
please stop with these bad ideas, that only harm us all.
thank you, I
l
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Shea, Valois
From:
Sent:
To:
Subject:
Monday, June 19, 2017 12:04 PM
Shea, Valois
no uranium in treat territory
I am writing to express my opposition to uranium mining in the Black Hills. We need to protect sacred spaces
and our water and environment. I strongly oppose any mining or other activities that could harm the land or
aquifers.
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Shea, Valois
Sent: Saturday, April 29, 2017 11:55 AM
To: Shea, Valois
Subject: Uranium Hearings RC, SD
Hello Shea,
I volunteered for Dakota Rural Action several years ago on a petition against giving the permit to Powertech
for access to the aquifer for mining. I was at a couple of the hearings back then and was wondering if this time it
will be the same. Will people be able to sign up to speak or is it something that has to be requested for ahead of
time. Please, let me know. Your response is appreciated.
l
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Shea, Valois
Sent: Monday, March 13, 2017 4:42 PM
To: Shea, Valois
Subject: Uranium Dump
No uranium near aquifers, anywhere and certainly not in SD
Sent from my iPhone
1
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Shea, Valois
From:
Sent:
To:
Subject:
Monday, June 19, 2017 9:40 AM
Shea, Valois
No Uranium in treaty territory
Dear Ms Valois,
The EPA is proposing draft permits for in-situ recovery (ISR) of uranium using deep injection wells within the
Inyan Kara group of aquifers (southern Black Hills region of Custer and Fall River counties).
Part of this proposed draft is to exempt the project from the Safe Drinking Water Act. Such an exemption
would have to be in place for ISR activities within the aquifer to take place.
As a retired environmental sciences teacher I must emphatically warn against granting such status for a
number of compelling reasons.
1) Even with regulatory approvals that the aquifer would be 'protected', there are no guarantees that the
process would not contaminate the aquifer. Companies that undertake these operations are known to cut
corners and costs in order to assure their profitability. With EPA's diminished funding I fear there will be little
or no oversight of the process. Any contamination of the aquifer by uranium or its radioactive daughters
should be considered permanent. We cannot take that chance.
2) This region faces extremes in weather now worsened by climate change and such extremes could hamper
the safety and efficacy of the operation. Safe water is a necessity to future generations given the hazards they
will face from rapid and abrupt climate change. We cannot take this chance of contamination for their sake.
3) The EPA is obligated under the National Historic Preservation Act to consult with the Tribes to identify the
potential effects of the project on traditional cultural places, historic, and sacred sites. As you are probably
aware, this current administration is openly dismissive and even hostile towards the interests of
America's indigenous peoples. We cannot expect there will be a good faith reckoning of the Tribe's concerns.
Therefore, for all these concerns, and more, I must register my opposition to the proposal for ISR activities in
the area. Please deny the permit.
Yours,
l
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Shea, Valois
From:
Sent:
To:
Subject:
Monday, June 19, 2017 10:39 AM
Minter, Douglas; Shea, Valois
Receipt of Powertech response on Draft UIC Class III/V draft permits for Dewey-Burdock.
Valois and Doug,
You should have received today a package from us with our entire response. (UPS shows it was delivered at 9:44). I was
hoping you confirm you received everything today. I would be glad to bring down a flash stick today otherwise. Please let me
know and would glad to hand deliver this if needed.
Also,
Just one note. In a few places, there are a few typos on Table 5 labeling this for cumulative effects, which it is not for. Table
5 represents our specific comments on the draft environmental justice document.
Sincerely,
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Shea, Valois
From:
Sent:
To:
Subject:
Tuesday, April 18, 2017 1:48 PM
Shea, Valois
Questions about what happens at Dewey Burdock/Azaraga hearings ... John D. Taylor,
Editor, Hot Springs Star
Follow Up Flag:
Flag Status:
Follow up
Flagged
Valois:
I'm the editor of The Hot Springs Star, a weekly paper in the heart of the Dewey Burdock project - we are the paper of
record for Fall River County—and I'd like to do a preview story for this coming week's edition about what people can
expect to experience at the impending hearings on Azaraga/Powertech's plans for Dewey Burdock.
Could you please answer the questions below? My deadline for a response is Thursday, April 20, at midday. Email is
probably best, since I'm a one-man show here and out of the office frequently. But that doesn't work for you, I'll do my
best to accommodate your schedule.
1. Take a reader through the thumbnail sketch of what happens at these hearings - You go there, various sides
present their information, then there's time for Q&A?
2. What will EPA do with the comments submitted by various people? How much does this enter into EPA's
decision to grant Powertech/Azarga final permits.
3. How will EPA review the comments... transcripts, video footage?
4. Anything else you want to add.... Tips for making sure comments get heard, in particular.
Sincerely yours,
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Shea, Valois
From:
Sent:
To:
Subject:
Tuesday, March 14, 2017 3:18 PM
Shea, Valois
permission to allow Uranium mining waste disposal in SD aquifer
"Specifically, this approval would exempt the uranium-bearing portions of the Inyan Kara
Group aquifers from protection under the Safe Drinking Water Act. Under its obligation to
comply with the National Historic Preservation Act and under EPA's Tribal Policy on
Consultation and Coordination with Indian Tribes, EPA has been consulting and coordinating
with several interested Tribes to identify the potential effects of the proposed project on
traditional cultural places, historic and sacred sites."
- these are your own words in the press release and it should answer the question...NO IT IS NOT GOOD - you
are unleashing the potential for another "Flynt, Michigan" debacle...and being the EPA is lead by someone who
doesn't believe in C02 emissions is actively helping climate change; Plus is planning on cutting 1/4 of the
EPA's budget....NO -1 can't trust the EPA to safely and effectively enforce the restrictions necessary to make
the uranium retrieval safe. Please!!! Leave Native Lands Alone!!! haven't we given them the short end of the
stick enough?!?
Thank you -
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Shea, Valois
From:
To:
Subject:
Shea, Valois
UIC 'Class III' Area Permit/ UIC 'Class V' Area Permit for deep-injection wells in the
Minnelusa Formation
Hello!
I'm responding to the EPA Region 8 draft proposals mentioned in https://www.epa.gov/newsreleases/epa-seeks-public-
comment-draft-permits-and-aquifer-exemption-uranium-mining-project
I was particularly alarmed by the language that "EPA is also proposing an aquifer exemption approval in connection with
the draft UIC Class III Area Permit. Specifically, this approval would exempt the uranium-bearing portions of the Inyan
Kara Group aquifers from protection under the Safe Drinking Water Act. Such an exemption must be in place before ISR
activities within these aquifers can occur."
As a citizen sympathetic to my fellow citizens pursuing such activities as "drinking and otherwise using water without it
increasing the likelihood of cancer and poor health" I highly object to this exemption approval. If the Class III Area Permit
is in an area vulnerable enough to require such review, then such review is a vital part of the process and should not be
simply discarded out of convenience.
Thanks,
l
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Shea, Valois
Sent: Monday, March 13, 2017 10:30 AM
To: Shea, Valois
Subject: UIC Area Permits to Powertech (USA)Inc
Dear Ms. Shea,
Please deny the permits for injection activities related to the proposed uranium recovery project in the southern Black
Hills region in Custer and Fall River Counties of South Dakota. Please do not allow uranium mining waste disposal in the
South Dakota aquifer.
Thank you,
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Shea, Valois
From:
Sent:
To:
Subject:
Wednesday, May 03, 2017 3:54 PM
Shea, Valois
STOP URANIUM MINING IN THE BLACK HILLS
As a 7th generation Oglala Lakota born and raised on the Pine Ridge Indian Reservation, I grew up spending
whole summers in the black hills, it is my home. Although I currently live in so called Denver, CO I consider
the He Sapa and all over South West South Dakota as well as the North Eastern Parr of Wyoming my Ancestral
Home. Stop Mining our Sacred Hills, leave the Uranium in the Ground. When the mother earth dies you
scientists enginers and natural gas / oil field workers will all die a slow painful death. You will watch your
family's and loved ones suffer from lack of clean air and die from poisoned water. This has been explained
many times, there are many individuals who can attest to and bear witness the harmful destructive effects this
uranium mining has had on our land, water, and health. All over the world the extraction of oil natural gases and
minerals is killing our world, killing eco systems and environments that have flourished for centuries upon
centuries. These eco systems are apart of what makes all life possible. Our existence depends are a very very
delicate balance. When mother earth dies there will be no place for the ultra rich to hide. No bunker can
withstand the Natural Powers of the Universe. No doomsday shelter will protect you. As for told by many
spiritual leaders Sha men and your very own bible describes this in revelations. Please the world pleads with
you to stop, stop ! Stop uranium stop big oil, stop natural gas, stop tar sands, stop coal bed methain. Stop coal.
l
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Shea, Valois
From:
Sent:
To:
Subject:
Thursday, May 18, 2017 12:01 PM
Shea, Valois
No Uranium in Treaty Territory
Hello,
I just wanted to submit a comment to say that I urge you to say no to the Dewey Burdock Uranium
Aquifer Mining. Our future generations are depending on us. I urge you to stand up for those who can't
stand up for themselves, folks without access to a computer, car, or phone to submit
comments, especially children.
We need to stand up against this devastation. Uranium mining is not the way to go because Pine Ridge
Reservation Oglala Sioux Tribe is being contaminated via aquifers under our home and down White
River. Crow Butte Uranium is not trying to clean up anything because they are not responsible for any
damages outside their mining area. We need the EPA to do their job, and protect people from
contamination.
Thank you,
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Shea, Valois
From:
Sent:
To:
Subject:
Monday, March 13, 2017 8:37 AM
Shea, Valois
FW: draft permits and aquifer exemption for uranium SD
Public comment.
From:
Sent: Sunday, March 12, 2017 9:39 PM
To:
Subject: draft permits and aquifer exemption for uranium SD
This is without a doubt the worst idea ever! You put scores of thousands of people at risk without clean
drinking water. The contamination of those aquifers will result in another Chernobyl in human loss. Please do
not grant exemptions.
l
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Shea, Valois
From:
Sent:
To:
Subject:
Monday, March 13, 2017 9:10 AM
Shea, Valois
Uranium Mining Project
To whom it may concern,
I read an article that stated the EPA is potentially approving uranium mining waste to be injected into an aquifer which
contains drinking water. This is one of the most absurd things that I've ever
heard. This is a topic that even Commedia dell'arte would think too
odd to even be considered in comedy.
Uranium eventually (over a very long term) degrades into lead. Do you remember what happened with Flint, Ml? I
know that Pruitt is in charge of the EPA now, but have a backbone and say no. Or, make him drink that water after
waste injection.
Seriously, who thinks that this is a good idea? Is it worth it for someone to rape the earth for their own profit?
l
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Shea, Valois
From:
Sent:
To:
Subject:
Tuesday, May 09, 2017 3:15 PM
Shea, Valois
Dewey Burdock Uranium Aquifer Mining
To whom it may concern...
The proposed mining of uranium in treaty territory will do irreversible damage to the aquifers. We all know
this. This will hurt people and hurt the earth. We all know this.
You have the power to protect people and the water. Please act honorably and help the people put an end
to this.
Furthermore this is treaty land. This mining is illegal. Help us stand up for our children's future. Thank you.
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Shea, Valois
Sent: Monday, March 13, 2017 11:48 AM
To: Shea, Valois
Subject: Mining waste
It's hard for me to believe that the EPA would for one moment consider it acceptable to allow uranium mining waste to
be dumped in any aquifer.
If the EPA is not our champion and our protection against pollution of our drinking water, the air we breathe, and the
God given beauty of our natural environment, then what on earth is its function!??!
Please do your job and do NOT allow the dumping of mining waste into the South Dakota aquifer, or any other act of
pollution!
Sent from my iPhone
l
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Shea, Valois
From:
Sent:
To:
Subject:
Monday, June 19, 2017 11:17 PM
Shea, Valois
Dewey Burdock Comment
To Shea Valois,
I am writing to express my concern over the permits and aquifer exemption decision requested by PowerTech
for the Dewey Burdock ISR site. In an area such as the southern Black Hills, with so little drinking water
resources, I feel that granting an aquifer exemption would be a very poor choice on the EPA's part, and not in
the best interest of the area's current & future citizens. Along with the inherent drinking water risks, the
increased risk of earthquakes associated with deep injection wells must also be considered. Deep injection sites
in Oklahoma have exponentially increased the occurrence of earthquakes in that state. It is the responsibility of
the EPA to take into consideration lessons learned from previous situations that have endangered human safety
and apply them to current decisions that are being made.
It is for these reasons that I strongly feel that the EPA should deny the aquifer exemption request along with the
two UIC permits.
Thank you for the opportunity to express my opinion on this matter.
Sincerely,
Hot Springs, SD
l
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April 16, 2017
Valois Shea (shea.valois@epa.eov)
Fax: 303-312-6741
U.S. EPA Region 8
Mail Code: 8WP-SUI
1595 Wynkoop Street
Denver, Colorado 80202-1129
Dear Valois Shea,
I moved to the Black Hills of SD because of clean water, air and a wonderful place to recreate
outdoors. Now a foreign holding company is seeking three EPA permits to pollute the precious
water tables underlying the Black Hills of South Dakota, which is the recharge area for our
streams and lakes, municipal supplies, private wells, and agricultural use in the entire western
state.
I have a problem with this. My house and well are not that far as the aquifer flows AND I do not
want to see the beautiful Black Hills known for the tourism money that the qualities I listed
above to be ruined by a number of dirty and polluting uranium mines.
The proposed min and deep disposal wells are in an area that is documented to have faults,
fractures, breccia pipes, and over 7000 od boreholes that have not been properly plugged. It will
be impossible to contain mining fluid or waste liquids, and contamination of our ground water is
very likely (as it has shown to be in all uranium mines in the USA).
Your agency is the United States Environmental Protection Agency. You are to protect the
American citizen from this kind of pollution. Plus we are dealing with a foreign holding
company and they will not think protection our water is that important. And you do not have the
field personnel to monitor this mine in an adequate manner.
I urge you to not grant the permits for this mine.
Thank you for your time and consideration,
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Shea, Valois
From:
Sent:
To:
Subject:
Sunday, May 14, 2017 11:45 AM
Shea, Valois
Azarga Uranium/Black Hills, South Dakota
To: Valois Shea
As a resident of Rapid City, SD and an American citizen, I implore the EPA to deny Azarga Uranium company
the rights to establish an ISL uranium mine and to build a processing plant in South Dakota. This denial
request is based on many reasons, the foremost being the integrity of all aquifer water supplies in the
area. Clean drinking water should be nothing less than a national security issue that needs utmost protection
and monitoring. No company can guarantee the safety of water supplies after in situ mining has taken place,
and based on that fact alone should be cause enough to stop this project. The fact that Azaga Uranium
company is heavily financed by a Chinese investment fund under investigation by the Chinese government
should red flag the EPA to also investigate the company itself. The transportation of uranium is a whole other
security issue that must be addressed, as are the chemicals used in the extraction process. Also, the EPA
should evaluate the cleanup plans Azarga has in case of any spill, leak and/or contamination.
This project will most heavily impact the indigenous peoples on the Pine Ridge Indian Reservation and their
health and rights should be an utmost priority in the decision making process.
The negative impacts far outweigh any positive ones and clearly highlights the need for this project to be shut
down permanently. Please act in favor of protecting of the health of our nation, its people, wildlife and the
earth.
Respectfully Yours,
l
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Shea, Valois
Sent: Wednesday, May 24, 2017 7:14 AM
To: Shea, Valois
Subject: Deny both permits please
Dear Ms. Shea,
Please accept this communication as a formal comment regarding the proposed two
Underground Injection Control (UIC) Draft Area Permits and one associated proposed
aquifer exemption decision for the Dewey-Burdock uranium in-situ recovery (ISR) site
located near Edgemont, South Dakota, under the authority of the Safe Drinking Water Act
and UIC program regulations.
I urge the EPA to deny both of these permits. Among other hazards, radon emissions,
toxic heavy metals and other pollutants, including chloride, sulfate, sodium, radium,
arsenic and iron, are in ISR wastewater ponds. Accidents and leaks in this kind of
operation are inevitable, raising concerns about runoff into the Cheyenne River and
Angostura Reservoir. As you are aware, the most serious radiation release in the US came
from a tailings pond spill at a uranium mine in New Mexico.
We can live without more uranium but not without clean water and soil.
Best regards,
Please excuse my spelling errors as this was sent from my iPhone
l
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Shea, Valois
Sent: Sunday, March 12, 2017 8:30 PM
To: Shea, Valois
Subject: Public comment on Draft Permits and Aquifer Exemption for Uranium mining project in
Southwestern South Dakota
Please don't dump waste where people get their drinking water. This could hurt our environment or kill
someone and bring about preventable suffering. It's supremely irresponsible and shortsighted. This kind of
treatment of our water and lands makes the United States look barbaric and ignorant.
I don't support these draft permits and exemptions.
l
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Shea, Valois
From:
Sent:
To:
Subject:
Tuesday, March 14, 2017 11:46 AM
Shea, Valois
EPA seeks public comment on draft permits and aquifer exemption for uranium mining
project in southwestern South Dakota
I would like to comment on the draft permit. I believe once an aquifer is impacted by uranium it is near
impossible to clean it up. The idea that as it is in the same area as the uranium-bearing portions will lead to a
legal fight that the permit holder will argue was the same levels prior to any potential release.
The contamination does not Naturally attenuate at any rate that will be successful to not have long term impact
on health and human environment. Further, the type of contaminant is uniformly excluded from insurance
policies that often insure these types of projects. Hence, if there is any release, the company will have to pay for
the clean up and they will likely not have the financial resources to do so.
EPA is also proposing an aquifer exemption approval in connection with the draft UIC Class
III Area Permit. Specifically, this approval would exempt the uranium-bearing portions of the
Inyan Kara Group aquifers from protection under the Safe Drinking Water Act. Such an
exemption must be in place before ISR activities within these aquifers can occur.
Thank you for your consideration and please do not provide the permit with SFDA drinking
water exemptions.
i
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Shea, Valois
Sent: Tuesday, March 14, 2017 5:33 AM
To: Shea, Valois
Subject: I oppose the UIC Area Permits and Safe Drinking Water Act exemption under
consideration for Powertech Inc.
Ms. Shea,
I was distressed to see that the EPA is considering issuing UIC Class III and Class V permits to Powertech, as
well as an aquifer exemption approval. Describing this permission as "ludicrous" doesn't seem sufficient. The
EPA should protect the right of people to have clean drinking water and uphold the legal protections like the
Safe Drinking Water Act put in place to do this. No corporation should be given an exemption to these rules,
and I oppose the granting of these permits and the exemption.
Sincerely,
-------
Shea, Valois
From:
Sent:
To:
Subject:
Saturday, June 17, 2017 11:20 AM
Shea, Valois
Comments on Powertech Underground Injection Control Draft Area Permits, Dewey-
Burdock Uranium In-Situ Recovery Site, Edgemont, SD
Dear Ms. Shea:
From 1992 through 1999,1 was an environmental engineer and eventually the environmental
compliance manager for the largest oil refinery in Minnesota, now known as Flint Hills Resources (formerly
Koch Refining Company). When we took a large gasoline storage tank out of service for routine cleaning in
September 1997, we found a nickel-sized hole in the bottom. Understanding immediately that we'd had a very
large spill, we called the Minnesota Pollution Control Agency (MPCA), our regulating agency, and told them
about the problem.
The MPCA came out, we drilled some exploratory wells, and found there was a large lake of product,
hundreds of thousands of gallons, lying on the water table. After several meetings with regulators, we devised
a plan that the MPCA agreed was the best: we'd drill more wells and pump the product off the water table,
send it through the refining process again and, of course, replace the entire floor of the tank.
The following year, while we were still pumping that gasoline off the water table, the weather was very
dry, and the water table dropped as a result. One afternoon when I was on call, an employee walking his dog
on the shore of the Mississippi River on a Sunday afternoon called the refinery and told us his dog had come
out of a swamp smelling like gasoline. The refinery called me, and I called the MPCA, and we immediately
called a refinery emergency.
The gasoline lying on top of the water table had been fine until the water table dropped. Then, as it
turned out, it had seeped down a fracture in the subterranean bedrock, a crack nobody had known was there,
and emerged in a backwater slough of the river. The regulatory agency had brought its geologists and
hydrologists to all the meetings, and they had investigated the area and concurred with our plan. Our own
hydro-geologists did, too. Fortunately, the spill was caught before that gasoline made it to the river itself, but
it cost the refinery millions of dollars to clean up, and the cost to that slough was that it essentially got
eradicated in the cleanup. If that employee had chosen some other place to walk his dog, we might not have
discovered the spill until it had reached the locks at Hastings, Minnesota, several miles downriver. By then the
damage would have been much more significant.
-------
Let me stress that the refinery did everything right, everything it was supposed to do, in dealing with
the spill. But nobody knew - nobody COULD know - about that fracture in the bedrock.
And neither will Powertech. I'm sure they'll use the very best technology to try to protect our water,
but because we can't see underground, we can't know with certainty how anything will behave in that
environment. Is it worth it to risk Powertech's uranium-laden solution getting into our underground aquifers
(not just the Inyan Kara)—where it will mix, not lie on top—and make that water unusable far into the future?
We in western South Dakota cannot afford to pollute the very water we rely on, not only for agriculture and
animal husbandry, but for life. I hope you agree with me that, no, it's not worth that risk.
I urge you to deny Powertech's permit for uranium mining in the southern Hills. Our water is simply
too precious. Thank you.
2
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Shea, Valois
From:
Sent:
To:
Subject:
Tuesday, March 14, 2017 8:30 PM
Shea, Valois
Uranium waste in our watershed
Regarding the request to place ISR process waste fluids into the Minnelusa Formation below the Inyan Kara after
treatment, please consider this a request to absolutely not allow this type of activity here or anywhere else in the
country.
We know, regardless of the type of process used, that the threat to ground water is not worth the risk. The resulting
contamination may be low level and long lasting. We should not be putting residents at risk and with no option but to
prove some sort of poisoning after years of drinking the water.
Protect us! We need to be able to rely on our ground water!
l
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Shea, Valois
From:
Sent:
To:
Subject:
Monday, June 19, 2017 12:08 PM
Shea, Valois
Black Hills mining
Hello.
I would like to express my strong opinion that the Black Hills should not be used for mining or mining waste
disposal.
This place is a very important cultural site, sacred to many in South Dakota and throughout the U.S. (not just
Lakota people). And it is one of our most beautiful natural resources.
Please keep in mind those of us who would be harmed by this proposal.
Thank you,
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Shea, Valois
From:
Sent:
To:
Subject:
Tuesday, May 16, 2017 2:25 PM
Shea, Valois
Comments on proposed uranium mining and storage plans on Lakota lands
Dear valois Shea;
we are are in smack the midst of a point in history where our decisions
will determine whether the planet survives with humans or not. The amount
of poisons we have saturated the soil, water and air with is already
killing thousands of us daily, whether it be from cancer or the harsh
affects of life threatening ailments induced by everything from household
chemicals to fossil fuel spills and by-products. Now is the time to stop
the madness and embrace the common sense and logic pointing in the
direction of supporting a sustainable environment. Please consider the
majority of American citizens that pay your salary as we insist the EPA
stop leaning "for" corporation's that are continuously determined to
annihilate and poison the water which sustains us all, by their complete
lack of concern for the environment and water, our livesource.
in March of this year the EPA issued two draft permits to Powertech, a
multinational corporation and division of Azarga uranium Corporation of
Canada. Together these permits would allow the drilling of thousands of
wells within 14 different fields. These wells would bore hundreds of feet
into the ground and pierce the inyan Kara system of underground aquifers.
The second of the two permits is to allow the disposal of hazardous waste
materials resulting from uranium mining. Both permits would needlessly
expose the Lakota Oyate to the devastation of uranium mining and continue
America's war against Red Nations' peoples.
Since 1980 we have been depleting more resources from the earth than we
are generating. As of today, the rate of "taking" vs. "replenishing" is at
50%. A path that has us destined for extinction. I am completely against
these permits due to the the obvious risk and detriment to our health,
mental stability and planetary regeneration these permits will allow.
Uranium has only been aggressively used as a source of energy for 60
years, yet look at the continued death of the Pacific ocean as the
Fukushima disaster rages on with no containment is sight. The only
containment for any hazardous substances we've already generated is above
ground retrievable storage will allow for containment without the risk of
breaching the aquifers. To say it's OK to generate more deadly waste that
we have no way of making non-toxic makes no sense.
"The inyan Kara, Minnelusa, and Madison aquifers are the principal sources
of ground water in the northern Black Hills, South Dakota and Wyoming, and
Bear Lodge Mountains, Wyoming. The aquifers are exposed in the Bear Lodge
Mountains and the Black Hills and are about 3,000 to 5,000 ft below the
land surface ... The direction of groundwater movement is from the outcrop
area toward central South Dakota."
Thank you for your courage and ethical decision NOT to approve this
permits.
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Shea, Valois
From:
Sent:
To:
Subject:
Thursday, June 08, 2017 3:47 PM
Shea, Valois
Re: Uranium Mining in the Black Hills
Good day Shea,
My family & I live in beauitful, rural southern Black Hills. We haul water for our home & animals from a
nearby source. We do not want uranium injection wells to contaminate our Madison water aquifer or the lower
Inyan Kara. We would like those abandoned drill sites cleaned up at the expense of those companies
responsible & not tax layers. We are concerned for the health and safety of all living beings, land, air & water
affected by this destructive mining and storage practices. Please help us. Stop uranium mining in the Black
Hills.
Kind regards,
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Shea, Valois
Sent: Sunday, March 12, 2017 8:44 PM
To: Shea, Valois
Subject: Please reject the Powertech permits
Dear Shea,
I've read about the draft Powertech permits, and urge you to stop both. Water safety must beer one of three EPA's
highest priorities. Reject these permits, please.
Sincerely,
Sent from my iPhone
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Shea, Valois
From:
Sent:
To:
Subject:
Wednesday, March 15, 2017 1:06 AM
Shea, Valois
RE: Storage of uranium in aquifer
Mr. Shea,
Thanks for the reply I appreciate it.
I after reading the entirety of the documents, I am just going to restate my comment under a Trump
administration reality has gone on holiday. There is nothing but bad (you, know, long after the fact bad)
to come from this, and it is the duty of the EPA to ensure the environment comes before corporate gains!
Original Message
Subject: RE: Storage of uranium in aquifer
From: "Shea, Valois"
Date: Tue, March 14, 2017 4:41 pm
To:
Thank you for emailing me your comments on the draft UIC Dewey-Burdock permitting actions. I
have added your email to the list of public comments received. I have also added you to my
contact list to keep you informed on future EPA actions related to the site.
Here is the link to the EPA UIC program website that contains all the information in the
Administrative Record, in case you do not already have it:
https://www.epa.gov/uic/administrative-record-dewev-burdock-class-iii-and-class-v-iniection-
well-draft-area-permits
The public comment period is in effect through May 19, 2017, in case you have any additional
comments after reviewing this information.
Thank you!
Valois
Valois Shea
U.S. EPA Region 8
MailCode: 8WP-SUI
1595 Wynkoop Street
Denver, CO 80202-1129
Fax: (303) 312-6741
Email: shea.valois@epa.gov
Original Message
From:
Sent: Sunday, March 12, 2017 8:19 PM
To: Shea, Valois
Subject: Storage of uranium in aquifer
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Are you seriously considering this? I cannot believe the agency designed to protect the
environment is actually asking civilians this question and not going to science...oh wait I forgot
under Trump you can forget reality and be completely stupid!!!
Artist and Photographer
Sent from my iPhone
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Shea, Valois
From:
Sent:
To:
Subject:
Wednesday, May 17, 2017 2:54 PM
Shea, Valois
No Uranium Waste Storage on Lakota Land
Dear Valois Shea,
I'm writing to ask that the EPA deny the permits for the proposed Dewey-Burdock Uranium Mine project. This
proposed mining project is likely to contaminate aquifers of the Black Hills and put the health and safety of
those drinking that water at risk. In addition, the mining project is next to the Black Hills, and is within the
boundaries of an area set aside for the tribes of the Great Sioux Nation by treaties signed in 1851 and 1868. The
Black Hills are sacred to the Lakota Nation. These tribes oppose this mining project; it violates their 1851 &
1868 Treaty Rights and they did not give up their water rights or mineral rights to these areas. The EPA must
deny these permits.
Thank you very much for your time.
All best,
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Shea, Valois
Sent: Sunday, March 12, 2017 8:58 PM
To: Shea, Valois
Subject: Uranium waste
Allowing this into a South Dakota aquifer - or into groundwater anywhere is pure insanity. Poisoning the earth to enrich
extractive industries should be punishable by jail. Think, EPA, think!
Sent from my iPhone
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Shea, Valois
Sent: Wednesday, March 15, 2017 12:06 PM
To: Shea, Valois
Subject: Uranium mining disposal in the Black Hills
I do not know a word that properly expresses how strongly I oppose to this act. Of course, this
act should not be considered okay anywhere but, having relatives in multiple places near the
Black Hills the idea of putting radioactive waste in the ground and therefore ruining the
beautiful, wild Black Hills is sickening. I beg you, please do not let this happen!
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Shea, Valois
Sent: Wednesday, May 17, 2017 8:12 PM
To: Shea, Valois
Subject: Public comment for the proposed EPA actions at the Dewey-Burdock site
Attachments: EPA_PUBLIC.Mayl7.doc; P_TriangleDeweyBurdockBHAD.png; A_cwa_sec404doc.pdf;
B_Beaver Creek Final Fecal Coliform TMDLpdf; C_SoBlackHills.pdf;
D_The_Black_Hills_Hydrology_Study.pdf; E_DeweyBurdock.jpg; F_hwysdakotaDewey.jpg;
G_map_Beaver_Creak_Watershed.pdf;
H_source_of_missouri_river_missouri_basin_map-1200.jpg; I_Dewey Potential
Wellfield.pdf; J_Dewey Wellfield Wide.pdf; K_GPS Drainage Though Dewey Well
Field.png; L_Dewey Wellfield Medium.pdf; M_GPS Cls-up Dewey Well Field.png;
N_Dewey Wellfield Closeup.pdf; 0_GPS Wide Shot DeweyBurdock.png
Proposed Underground Injection Control (UIC) Program actions at the Dewey-Burdock site located near
Edgemont, SD. These actions include two draft UIC permits and a proposed aquifer exemption decision.
PUBLIC INFORMATION SESSIONS AND HEARING
Written Statements
PROPOSED DEWEY-BURDOCK PROJECT ISL MINE NEAR EDGEMONT, SOUTH DAKOTA
ENVIRONMENTAL IMPACT STATEMENT
The SEIS Fails to Consider Connected Actions
PUBLIC COMMENT:
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May 17, 2017
URANIUM MINING EPA HEARINGS
PUBLIC INFORMATION SESSIONS AND HEARING
Written Statements
PROPOSED DEWEY-BURDOCK PROJECT ISL MINE NEAR EDGEMONT,
SOUTH DAKOTA
ENVIRONMENTAL IMPACT STATEMENT
The SEIS Fails to Consider Connected Actions
Public Comment
My concerns regarding the Dewey-Burdock Project are centered around the
problems of artesian flow and, interactions with the Remediation of Buried
Chemical Warfare Materiel located at the Black Hills Army Depot less than 10
miles to the south.
Furthermore, Dewey-Burdock Project experts propose land application areas on
river terraces and deep well injection into aquifers within the project boundaries
under the sanctions of EPA permits to be exempted from the Safe Drinking
Water Act (SDWA 1977 & 1986). Surface water flow in channels is ephemeral
except for perennial Beaver Creek. U.S. Army Corps of Engineers permit
application under Section 404 of the Clean Water Act will be required
before conducting work in jurisdictional wetlands (see Surface Waters and
Wetlands SEIS Section 4.5.1.1). (see Section 404 of the Clean Water Act -
exhibit A_cwa_sec404doc.pdf).
The Dewey-Burdock Project will transmit the applied and/or injected waste
directly into the area of the Beaver Creek Watershed within the Upper
Cheyenne River Watershed of the Cheyenne River to flow eastward throughout
the State of South Dakota and into the Missouri River affecting the entire
Missouri River Basin, (see exhibit G_map Beaver Creek Watershed and exhibit
H_source_of_missouri_river_missouri_basin_map-1200).
Page 1 of 4
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Water Quality
Other areas are dealing with primary and secondary water quality issues refer to
Southern Black Hills Water System Appraisal Report (see exhibit
C_SoBlackHills.pdf).
For example, the town of Edgemont has quality concerns with primary drinking
water standards relative to some category(ies) of radionuclides (e.g., alpha
particles that can result in increased risk of cancer).
Edgemont has shown a test of 17 milligrams per liter (mg/L) on alpha particles,
and the U.S. Environmental Protection Agency (EPA) limit is 15 milligrams per
liter (mg/L).
The problem of artesian flow
Artesian springs act as a "relief valve" for the aquifers and are an important
mechanism in controlling water levels in these aquifers. Springflow of many
large artesian springs changes very slowly in response to long-term climatic
conditions. Artesian springflow could be diminished by large-scale well
withdrawals near springs, thus impacting surface-water resources. Large-scale
development of the aquifers has the potential to influence the balance of the
unique and dynamic "plumbing system" in the Black Hills area that controls
interactions between ground-water levels and artesian springflow (see exhibit
D_The_Black_Hills_Hydrology_Study.pdf).
Artesian flow occurs when there is a hydrologic connection, through faults or
highly permeable strata, between groundwater sources high on the landscape
and the land surface lower down. The weight of water in overlying strata exerts
pressure downward into water within the uranium-bearing strata, which can
then be released as artesian water flow (like a fountain) where the
topographically lower uranium-bearing strata is exposed at the surface, or
where it is punctured by drilling. Artesian flow was observed or predicted by
Powertech in their Dewey-Burdock Project proposal, and was observed directly
at the Black Hills Army Depot less than 10 miles to the south (U.S. Army Corps
of Engineers 1992).
In order for artesian flow to occur at the Black Hills Army Depot, the water
must originate topographically higher in the Black Hills and pass through the
Dewey-Burdock project area boundary. Were this artesian water flow to happen
with oxidant-charged lixiviate, and/or the brackish fossil aquifers, the
Page 2 of 4
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contaminated groundwater would rust any metal-contained ordnance and
release its contents into the environment.
Concluding Remarks
It is very likely that the oxidants used to free the uranium and/or the brackish
fossil aquifers and the connected action of artesian flow as observed by the U.S.
Army Corps of Engineers will also cause the destruction of underground
storage containers i.e. Buried Chemical Warfare Materiel located at the Black
Hills Army Depot less than 10 miles to the south of the Dewey-Burdock Project
area and release their contents into the area's ground and surface waters. This
huge munitions depot handled thousands of tons of chemical warfare agents
such as sarin, soman, toban, GB, and VX, plus mustard, phosgene, and
Lewisite, http://rapidcitviournal.com/news/local/seismic-crews-want-to-test-up-
to-acres-northwest-oiyarticle 2d670e86-f90b-5db4-8bd6-19075034e04e.html
Page 3 of 4
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References
U.S. Army Corps of Engineers. 1992. Preliminary assessment of ordinance contamination at
the former Black Hills Army Depot, South Dakota. Final Archives Search Report (Contract
No. DACA-87-91-D-0037), pp.314
USACE (U.S. Army Corps of Engineers). 1992. "Final Archive Search Report, Preliminary
Assessment of Ordnance Contamination at the Former Black Hills Army Depot, South
Dakota.: ML13053A145. Huntsville, Alabama
USACE (U.S. Army Corps of Engineers). 2012. "Final Work Plan for Black Hills Army
Depot Remedial Investigation and Feasibility Study at Fall River County, South Dakota."
ML13053A152, Huntsville, Alabama
LaGarry, H. E., C. Belile, & H. Gaddie. 2012. Revised lithostratigraphic correlation of the
Arikaree Group from northwestern Nebraska to southwestern South Dakota. Proceedings
of the 122nd Annual Meeting of the Nebraska Academy of Sciences, pp. 92- 93.
U.S.NRC Office of Federal and State Materials and Environmental Management Programs. 2014.
Environmental impact statement for the Dewey-Burdock Project in Custer and Fall River
Counties, South Dakota: Supplement to the Generic Environmental Impact Statement (SEIS) for
In-Situ Leach Uranium Milling Facilities. Final Report Chapters 6 to 11 and Appendices
NUREG-1910 Supplement 4, Vol. 2, Summary of Environmental Impacts Table 9-1 pp 9-5
Surface Waters and Wetlands (SEIS Section 4.5.1.1)
Southern Black Hills Water System Appraisal Report
Rural Water Supply Program Dakotas Area Office, Great Plains Region
Dakotas Area Office
Vaughan Gerlach, Civil Engineer
Great Plains Regional Office
Kip Gjerde, P.E., Civil Engineer Mark Phillips, Geologist Gary Davis, Resource Management Specialist
U.S. Department of the Interior Bureau of Reclamation Bismarck, North Dakota March 2011
Summary of Appraisal Investigation Water Quality Section 2.3.4 pp. 9
The Black Hills Hydrology Study
Janet M. Carter United States Geological Survey
U.S. Department of the Interior
USGS Fact Sheet FS-046-02 June 2002
Fecal Coliform Bacteria Total Maximum Daily Load (TDML) for
Beaver Creek, Fall River County, South Dakota January 2010
Aaron M. Larson SD DENR Water Resource Resource Assistance Program
Introduction Figure 1-1 Beaver Creek Watershed Within the Upper Cheyenne River Watershed pp. 7
SECTION 404 OF THE CLEAN WATER ACT
F.2. Any discharge of dredged or fill material into the navigable waters incidental to any activity
having as its purpose bringing an area of the navigable waters into a use to which it was not
previously subject, where the flow or circulation of navigable waters may be impaired or the
reach of such waters be reduced, shall be required to have a permit under this section.
Page 4 of 4
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Shea, Valois
Sent: Sunday, March 19, 2017 4:06 PM
To: Shea, Valois
Subject: draft UIC Dewey-Burdock permitting
Dear Mr Valois,
I have read the fact sheet for public comment of the two UIC Area Permits to Powertech, for injection wells for uranium
recovery and aquifer exemption, for the disposal of treated ISR process waste fluids into the Minnelsusa Formation.
As expected, the EPA permitting process is very thorough. At this writing, I also find myself very aware of, and thankful
for, this permitting process, and more importantly, that regulatory oversight exists! It is almost secondary to this
thought that I offer my public comment on the permit!
I agree with the additional pump tests in the Burdock Area wellfields targeting the Chilson sandstone, mentioned in
section 3.4.2. Also that the Fuson shale confining zone may have some areas compromised by other holes punched
through it, and the wellfield pump tests will pinpoint any breaches.
Providing adequate well monitoring and maintenance programs for all the wells, including the monitoring wells, will
ensure well operational efficiency and extend the life of the wells throughout the project. Among other water
constituents, high TDS and sulfate levels that exist in the formations, as well as the process water, will tend to clog well
screens and gravel filter packs over time without vigilance. In addition to the required step tests for fracture
determination discussed in section 5.9, routine pump/step tests can be useful for monitoring well efficiencies and the
need to treat the wells before problems occur. The flowing artesian wells present within the area will remain a concern
and should be watched.
It is my sincere hope and desire that the EPA remains intact; that regulations such as these types of permitting processes
and monitoring and remediation regulations, will remain strong and continue to provide oversight of these and other
operations. Without the professionalism and dedication of you and others at the EPA, our air, water, and environmental
quality will suffer to an alarming degree. Thank you for all of your hard work and diligence. This citizen is appreciative of
your efforts.
Sent from my iPad
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Shea, Valois
Sent: Tuesday, March 14, 2017 2:47 PM
To: Shea, Valois
Subject: Aquifer changes
In response to request for public comment regarding dumping into an aquifer, I suggest that the book, "Living
Downstream" be required reading. We cannot return to the days of having our water systems polluted and
damaged for the sake of corporate or personal gain.
I have lived in an area wherethe rivers and water systems were polluted due to chemical dumping from
byproducts of manufacturing and the long term effects remain for decades.
Please do not let this happen, I am sending a resounding no.
Respectfully
Get Outlook for Android
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Shea, Valois
Sent: Monday, May 15, 2017 10:40 AM
To: Shea, Valois
Subject: Stop Dewey-Burdock Uranium Mine
Dear EPA,
I wish to comment on the Underground Injection Control Program's Draft Permits for the Proposed Dewey-Burdock
Uranium Mine and Deep Disposal Wells.
The proposed mine and deep disposal wells are in an area that is documented to have faults, fractures, breccia pipes,
and over 7000 old boreholes that have not been properly plugged. It will be impossible to contain mining fluids or waste
liquids, and contamination of groundwater resources is very likely.
It concerns me that adequate oversight of the quality of liquid wastes pumped into the Minnelusa Formation through
the proposed deep disposal wells will be inadequate, and groundwater is likely to be contaminated.
Further, these permits should not be issued until it can be demonstrated that groundwater resources will be protected.
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Shea, Valois
June 19, 2017 11:38 AM
To: Shea, Valois
Subject: uranium mining must stop
Stop destroying the world. NO uranium mining needed or wanted. You are supposed to protect, not rape, the
Earth.
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Shea, Valois
From:
Sent:
To:
Subject:
Please do not allow waste disposal in Sout Dakota's aquifer. That is ridiculous to consider contaminating the water
supply with nuclear waste. Please stop!!
Sunday, March 12, 2017 8:26 PM
Shea, Valois
Uranium
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Shea, Valois
Sent: Monday, June 19, 2017 10:30 AM
To: Shea, Valois
Subject: Comment on black hills
I am sending an email about my concern over the potential uranium mining in the black hills and to say that this
is harmful and I am against it. There should be no mining of this or any kind on native territory where is can
harm the environment and pollute natural resources. I hope that this will be taken into consideration and that the
right decision is made. Thank you.
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Shea, Valois
Sent: Tuesday, March 14, 2017 10:02 AM
To: Shea, Valois
Subject: Mining waste dump
Of course citizens are against allowing toxic waste dumping into our waterways.
How can the government even ask? This is the primary reason for EPA.
Stop irresponsible actions against our natural places and resources. This effects all people in the US.
Sent from my iPhone
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Shea, Valois
From:
Sent: Tuesday, March 14, 2017 10:02 AM
To: Shea, Valois
Subject: Mining waste dump
Of course citizens are against allowing toxic waste dumping into our waterways.
How can the government even ask? This is the primary reason for EPA.
Stop irresponsible actions against our natural places and resources. This effects all people in the US.
Sent from my iPhone
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Shea, Valois
From:
Sent:
To:
Subject:
Sunday, March 12, 2017 6:27 AM
Shea, Valois
Permits and Exemption
Dear Ms. Shea,
It is my understanding that the EPA has issued two draft Underground Injection Control (UIC) Area Permits to
Powertech (USA) Inc., for injection activities related to a proposed uranium recovery project in the southern Black
Hills region in Custer and Fall River Counties of South Dakota.
I strongly urge you to reconsider any decision to allow permits to mine any region that impacts
Native American lives. We all know how Native Americans are considered second class
citizens in this country; how their lands are up for grabs; and how their health is not as
important as expanding drilling for oil, uranium, copper and so on. These substances are not
for consumption here (not that this would be acceptable) but to enrich the companies that sell
them overseas.
Please do not continue to perpetuate these injustices and do not approve any draft permits or
any aquifer exemption.
Thank you.
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Shea, Valois
From:
Sent:
To:
Subject:
Monday, March 06, 2017 9:21 PM
Shea, Valois
proposed Dewey-Burdock Uranium In-Situ Recovery Site located near Edgemont..SAY
NO!!!
I am against this proposal, as all the caring neighbors in the Custer Highlands subdivision. We are
close to the site and dont agree with the pollution associated with the mine. It would permanently
contaminate the water and make surrounding properties unlivable. Most of the residents here have
come from another place and gravitated toward this area because of the natural beauty and healthy
wildlife. Bringing toxic waste to the surface is not what this beautiful area is all about. Please
reconsider and SAY NO!!!
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Shea, Valois
From:
Sent:
To:
Subject:
A foreign holding company is seeking three EPA permits to pollute the precious water tables underlying the Black Hills of
South Dakota, which is the recharge area for our streams and lakes, municipal supplies, private wells, and agricultural use in the
entire
Wednesday, May 03, 2017 1:35 PM
Shea, Valois
no to black hills mining and milling..not worth the risk!
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Shea, Valois
Sent: Monday, June 19, 2017 12:03 PM
To: Shea, Valois
Subject: Please don't allow Black Hills uranium mining
Dear EPA staff:
I'm writing to urge you not to permit uranium mining in the Black Hills. Such mining would have potentially
devastating effects on the region's aquifers. I urge you to adhere to the high standards of your agency and refuse
this permission.
Regards,
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Shea, Valois
From:
Sent:
To:
Subject:
Monday, June 19, 2017 4:10 PM
Shea, Valois
Comments on Dewey Burdock proposal
Clean water is nearly nonexistent in our nation, and the situation is becoming worse each year.
It has been well established historically that this type of project will (not could, but will) cause environmental
contamination.
The EPA was formed with the charge with the mission of protecting the environment and human life
and wellness.
I don't believe that the EPA's mission should be to experiment with how much environmental destruction can
we accomplish before we all die.
You won't see this in the modern 24/7 media, but you don't have to look far to find that unfortunately this is
already happening. Documented cases of cancer and other toxicity related illnesses - affecting not just older
people, but young children, babies born with birth defects - are happening and are correlated with
environmental impacts.
Scientists and engineers draw these maps to define boundaries. "Here is one aquifer, here is another." "Here is
where they are connected", or, "they are not connected at all." As a scientist, I will say that while these
analyses have their purposes, they are still only approximations of reality. This is the earth we are talking about
- everything, everything, everything is connected, as multiple speakers at the hearings have already
stated. The idea of containing contamination is only an optimistic dream, not reality.
We've got people willing to put their names on the line and spend hours and days out of their week attending the
EPA hearings and making comments - not to mention the time spent organizing, reading the published
documents and policies to put together these comments, etc.
The current story of our nation seems to be that a project is set up, the real people who are affected show up and
give their voice (when they are allowed to do so), and the people with the money and power steamroll ahead
anyway.
However, people young and old are coming up, getting involved, and showing up to do the work that will make
the cultural shift from valuing money (which, if you ever took economics, you know is an arbitrary, imaginary
concept) to valuing human life, to valuing nature, to valuing the connections between people, between people
and nature, valuing what is really important to human life, to finding the meaning of life.
The meaning of life seems mysterious and out of reach to American culture - but there are plenty of people
around who have a grasp of it, it's just that those people, by their exact nature, are considered to be the quiet
ones, not the ones who become famous or go on TV media or whatever.
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So I urge you to listen, as many of the speakers at the hearings have already said. Listen to the people here
when you make your decisions. Seek the input of the native tribes who occupy and know this area, and truly
listen to them. Listen to your own hearts: what matters to you? Does your children's future matter to you, or
does money matter to you? Which is going to last longer? Which is something you want to look back on at the
end of your life?
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Shea, Valois
From:
Sent:
To:
Subject:
Monday, May 22, 2017 10:05 AM
Shea, Valois
Uanium etraction project in western South Dakota.
Dear Environmental Protection Agency,
At the recent hearing held in Rapid City I referenced a study conducted by the U.S. Geological Service. This
study was in reference to a series of earthquakes instituted by the injection of nuclear and hazardous wastes
mixed with water into bore holes in the area of the Rocky Mountain Arsenal in Colorado. These incidents were
in the 1960's.
Although these were deep bore holes, this unfortunate process illustrates that, in spite of any geological
knowledge we have attained, we still do not have an understanding of the far-reaching effects of any possible
damage we can do to the structure of the Earth.
As a lifelong resident of the Black Hills of western South Dakota and a student of the geology of this area I
know from my experience and knowledge how fragile is the rock strata of the western Black Hills. Particularly
the underlying limestone and sandstone.
I shall repeat some incidents that reveal the porosity of the rock strata. When I was active in drilling oil wells
not far from the proposed Dewey-Burdock uranium extraction program we would often 'lose circulation1. This
meant that we would drill into large cavities or fissures underground which would carry away our drilling mud
or lubricant. A rancher who lives not far from the proposed project decided to drill a new water well. He
actually has a water-well-drilling business. He was in the process of drilling this well when he suddenly drilled
into a huge cavity. He withdrew his drilling pipe and later notified the superintendent of the nearby Jewel
Cave National Monument. The Jewel Cave people came to the bore hole site with fiber optic cameras and
equipment to put down the hole. When asked what the saw, they responded: "It looks just like Jewel Cave."
I am a member of the Darton Geological Society. We have guest speakers at out monthly meetings. One
speaker presented professional documentation related to a study of how fluids migrate underground in
limestone and sandstone strata. In addition to a bore hole in which fluid was injected they had a series of bore
holes near the injection hole to monitor for the migration of fluids. They had injected harmless ionized water
and it was amazing how quickly and how far the fluid had spread from the injection site. Another speaker, who
was a professor from my alma mater, South Dakota School of Mines and Technology, was the project leader in
a project to drill experimental bore holes through South Dakota. Many holes were drilled but the astounding
knowledge gained was that it was discovered that a fault line existed either under the Missouri River or
paralleling it for a great distance from the Nebraska border northward.
We are reminded that the famous Homestake Mining Company did core-drilling from the surface down to
great depths to discover new ore bodies. As a result of their core drilling they decided to excavate a tunnel 2
miles in length to where they assumed the new gold ore body lay. When they got to the area they did not find
the any new gold ore bodies. This was done relatively recently before Homestake gave up the gold mine after
some 140 years. This work was done in hardrock, of course, and not sedimentary stone, but the fact is evident.
We do not really know what lies beneath the surface.
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One of the colored displays at the EPA hearings up here in the Black Hills showed a cross section of the
underlying rock strata in the Dewey-Burdock area. I submit that the drawing is NOT REPRESENTATIVE of the
underlying rock. Instead of solid rock displayed it should more accurately be shown to be filled with cavities,
holes and fissures, Much like a sponge or Swiss cheese.
I find that the series of 'monitoring bore holes' around the perimeter of the proposed project is misleading
and moot. If contaminating fluids reach these monitoring holes it is too late. The underground would already
be contaminated. From maps of the proposed project area I see that the proposed 'holding dams/ponds' are
in the area of possible flash flooding. A few years ago I was traveling the gravel road from Dewey to the
Jewel Cave area. This would be northwest of the proposed project. As I came around a curve I encountered
many burned logs, trees and debris covering the road. This debris had been swept down a basin in a flash
flood from a forest fire many miles distant. A similar flash flood would destroy these holding ponds and
further contaminate the environment. I submit that if the go-ahead for this uranium project was to
be submitted to a vote of the local and area residents, the people would adamantly vote against the project.
We strongly urge the EPA to NOT GRANT any of this drilling and water injection to proceed. This company
does not have the monetary resources to remedy any of the possible detrimental effects to our environment
and peoples health. We in the Black Hills daily confront the disastrous effects of the abandoned Gilt Edge
Mining project. Now a superfund site.
2
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Shea, Valois
From:
Sent:
To:
Subject:
Monday, March 13, 2017 2:55 PM
Shea, Valois
RE: Public comment on draft permits and aquifer exemption for uranium mining project
in southwestern South Dakota
Attention:
Valois Shea
U.S. EPA Region 8 Mail Code: 8WP-SUI
1595 Wynkoop Street
Denver, CO 80202-1129
Dear Ms. Shea:
Absolutely no exemptions for groundwater contamination, whether from uranium, or any other foreign (non-
H20) substance. We (U.S. EPA) must prohibit any contamination of water, whether they are ground water or
surface waters.
https://www.epa.gov/newsreleases/epa-seeks-public-comment-draft-permits-and-aquifer-exemption-uranium-
mining-proiect
Thank you,
l
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Shea, Valois
From:
Sent:
To:
Subject:
Monday, June 19, 2017 8:39 PM
Shea, Valois
Azarga Uranium
We are begging you please do not allow Azarga to mine or dump uranium in the Hills or anywhere in SD. The Hills are
sacred to the indigenous people here and to us too.
We have had 2 new leaky oil pipelines forced on us. Between the oil pipelines and Azarga we fear for our ground water
and the deep aquifers.
We hope you will reject Azarga's application.
Please help us protect our state,
l
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Shea, Valois
From:
Sent:
To:
Subject:
Friday, June 02, 2017 9:05 AM
Shea, Valois
Azarga
Dear Ms. Valois:
I am writing to urge the EPA not to grant Azarga permission to mine uranium in South Dakota's Black Hills.
First, the area currently needs cleanup from previous mining. Second, the mining will undoubtedly adversely
affect aquifers. Third, this is yet another out-of-state (or, in this case) foreign company seeking to exploit our
state's resources. Fourth, this enterprise would not bring significant economic benefits to the state or its people.
Best,
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Shea, Valois
Sent: Monday, March 13, 2017 3:29 PM
To: Shea, Valois
Subject: Uranium/Aquifer
I'll keep this simple. Don't do anything to contaminate the aquifer in South Dakota. Nevada's water issues with surface
level fallout is bad enough.
l
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Shea, Valois
Sent: Wednesday, March 15, 2017 8:01 AM
To: Shea, Valois
Subject: Aquifer Exemption South Dakota
There is no safe level of Uranium waste in drinking water, and you won't be able to reach safe levels of uranium
waste if you are exempting an aquifer from the safe drinking water act. By that very act you are saying that the
people of that area don't deserve or need safe drinking water. This is court sanctioned murder of the native
people in Black hills. You have stolen their children, taken their land and now you are polluting their water. I
am strongly against this measure. It violates everything the EPA stands for. I can only assume you are doing
this because of the current president. Stand up and have a spine.
l
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Shea, Valois
From:
Sent:
To:
Subject:
Friday, March 17, 2017 9:41 AM
Shea, Valois
Powertech/Azarga Black Hills
Good Morning,
While the EPA might be gutted financially, my hope is there are people there that still understand the important
of keeping our waterways, and airs clean of all pollutants. This project would be an unbelievable hazard,
contaminating the Inyan Kara aquifer which is being used |