2015-08-03_REVISION - P2009025 (5)

Home Browse Search

uranium recovery, UBHM technology — especially when proposed in the midst of many hundreds of rural residential parcels. Although this request is the first explicit application by BLR to the Division for a pilot test of the experimental UBHM procedure, it is actually the third time that the company has attempted to gain approval for the experiment under its Prospecting Notice of Intent. On April 5, 2012, BLR submitted an application for a modification of their NO1 that was obviously for the purpose of conducting a test to evaluate their then recent announcement of plans to utilize UBHM at Hansen. TAC objected on technical grounds raising concerns about the potential threat to the local underground water supply. DRMS requested, in its modification review, that BLR provide a modest amount of hydrological data and to forecast of the potential impact on the groundwater of the process. BLR objected to the DRMS request, stating that it was more appropriate for a mining permit application, and withdrew their application for the modification of the Prospecting NO1. [Each of the above cited documents are posted on the DRMS webpage for P2009025 from 4/5/2012 to 5/3/2012] On July 18, 2012, BLR submitted a second application for modification of their Prospecting NO1 requesting authorization for the installation of monitoring wells and for the expansion of bore diameter for new "prospecting" drilling. Again, TAC objected and expressed concern about the BLR hidden attempt to conduct a partial evaluation of UBHM (a previously announced "cutting test" to be done during the third quarter of 2012) and the potential threat to the groundwater and local supply of drinking water. The MD 02 Adequacy Review disregarded our concerns and the modification request was approved. TAC made a timely appeal to MLRB, a Hearing was scheduled, and a Pre -Hearing Conference was convened on November 5, 2012. [Each of the above cited documents are posted on the DRMS webpage for P2009025 from 7/18/2012 to 10/31/2012] The Pre -Hearing Conference was attended by DRMS staff, attorneys for both DRMS and MLRB, BLR employees, and TAC representatives. Following extensive discussion of the issues, two major determinations were made: First, that the proposed newly constructed monitoring wells would be intended to provide the data necessary to determine what additional monitoring wells would be required to comply with the requirements for submission of a mining permit for the Hansen deposit; and Second, that there could not be even a partial test of UBHM under the auspices of a Prospecting Notice of Intent. Mr. Tony Waldron, then Senior Environmental Protection Specialist, now Minerals Program Manager, clearly and unambiguously stated that any UBHM experiment would have to be conducted under a mining reclamation permit. Mr. Rod Grebb, BLR Regulatory Affairs Vice President agreed that a mining permit would filed at an undetermined later date. As a result of these assurances TAC (and Ms. Kay Hawklee as an individual) withdrew its appeal to the MLRB. [Posted 11/6/2012] In two subsequent email dialogs between Lee J Alter and Tim Cazier, one in February 2013 and the second in June 2013, the question was raised of what type of authorization would be required for a BLR test of UBHM. Mr. Cazier confirmed that BLR "has committed to applying for the appropriate mine reclamation permit as they firm up their plans. The Division will review their application for adequacy when it is submitted." [Email Cazier to Alter Feb 12, 2013]. Despite repeated inquiries as to the specific permit that would be required, the only response from DRMS was that "an appropriate permit is dependent on exactly what was proposed". [Email Cazier to Alter, Feb. 12, 2013, emphasis in original] 2