2015-01-20_REVISION - P2009025 (5)

Home Browse Search

Azarga Uranium Corp. Chairman Alex Molyneux has made recent public statements that the Centennial project was "quietly revived" in 2014 and that the company has "prepared a couple of different mine plans for it and will be revealing our plan for it probably in Q2 2015." Molyneux is a well -known proponent of UBHM and the experimental uranium concentration process of ablation. The UBHM and ablation system envisioned by Black Range Minerals and Azarga has never been used for uranium mining and processing and therefore is not directly addressed by the Act and the Rules. This regulatory gap is concerning since UBHM has the potential to contaminate groundwater aquifers by mobilizing radionuclides and heavy metals. The Division's response to the applicant's modification request will set a precedent for future mining permit applications for proposed northern Colorado uranium projects, most notably the Centennial project. For this reason, CARD should be accorded party status in this matter. CARD's comments on the modification request are as follows: 1. The applicant should apply for a reclamation permit, not a modification to a prospecting NOI. The proposed activity does not fall under the definition of "prospecting" in the Act. Prospecting includes various activities conducted for the purpose of searching for or investigating a mineral deposit. The proposed activity is not prospecting. The applicant proposes to insert a hydraulic jet cutting tool into a drill hole and then cut a cavern via a pressurized water stream. The cavern would be cut "within the Hansen Uranium Deposit ". The resulting fragmented uranium ore would then be lifted through the drill pipe to the surface via air lift suction. The applicant proposes to extract a "bulk sample" of 200 tons of dry material. Rather than searching for or investigating a mineral deposit, the applicant appears to be proposing a pilot plant to test the UBHM process. Since UBHM has not been used previously to mine uranium, the need to conduct a pilot project to determine feasibility makes sense. Conducting pilot plant operations falls under the definition of "development" in the Act. Development occurs after proving that minerals are in existence in commercial quantities but prior to production activities. Numerous Black Range securities filings and investor presentations document the company's successful efforts to prove the existence of commercial quantities of uranium in the Hansen project area. 2