SPEARFISH — The Black Hills Pioneer recently submitted a series of questions to Powertech officials regarding their proposed Dewey Burdock in situ uranium mining project that would extract an estimated one million pounds of uranium a year for eight years from an almost 11,000-acre piece of land that straddles Fall River and Custer counties. The questions were carefully drafted to cover issues the Pioneer felt had not been significantly addressed. Questions and answers are printed verbatim below.
Black Hills Pioneer: If the Dewey Burdock project is green-lighted and another company takes controlling stake in Powertech, or Powertech is bought out altogether, what assurances do the people of South Dakota have that the new entity in charge will do what the state requires them to do as well as what Powertech has promised in writing to do?
Powertech: The Dewey-Burdock Project can operate only when authorized by state and federal permits. These permits are legally binding documents containing requirements and conditions to which Powertech (USA) Inc. must adhere.
If ownership should change, the new owner is bound by all permit and license conditions. This includes the commitments that are made in the permit and license applications. For example, the draft Nuclear Regulatory Commission license contains a requirement that, “The licensee shall conduct operations in accordance with the commitments, representations, and statements contained in the license application.” Regulatory notifications are required when transferring permits and licenses to any new owner. This ensures continuation of regulatory oversight of the mining operation, including routine inspections by regulatory agencies.
Regardless of ownership, all permit conditions and federal, state, and local laws must be followed by the operator of the project. The water cannot be used for any other purpose, except for that approved in the permits granted by the state. In the case of the Dewey-Burdock Project, this means that water can be used only for ISR (in situ recovery) uranium mining, groundwater restoration associated with uranium mining, and provided to local ranchers in the vicinity of the project.
Black Hills Pioneer: What sort of chemicals/substances will be in the post-mining wastewater that Powertech proposes to dispose of by either land application or injection into Class V deep disposal wells? Will this wastewater contain any uranium, radium, selenium or arsenic in any levels?
Powertech: Because most of the water removed during the ISR process will be recirculate through the well field, the net consumptive use of the water will be a small portion of the gross withdrawal rate. A small amount of (2 percent or less of the water circulated through the ore body) will be “bled off” during the process in order to maintain flow gradients toward the center of the well field and help control the flow of recovery solutions to the production wells. Any constituents that occur naturally in the native groundwater, including low levels of arsenic and selenium, will also be in the bleed stream.
The bleed stream will be treated to remove uranium and radionuclides, including radium, and will be disposed by one of two disposal methods.
The preferred disposal option is underground injection of treated liquid waste in non-hazardous Class V deep disposal wells, which are permitted by EPA. In this disposal option, liquid waste will be treated to satisfy EPA non-hazardous waste requirements before injection.
The alternate disposal option is land application. This option involves treatment in lined settling ponds followed by seasonal application of treated waste through center pivot sprinklers. Land application will be regulated under a Groundwater Discharge Plan authorized by the State of South Dakota and under the proposed large scale mine permit. The water quality limits protective of groundwater quality will be established in the Groundwater Discharge Plan.
In addition, Powertech’s mine permit application describes the protective measures that will be used to prevent bioaccumulation of selenium and other constituents associated with land application of treated wastewater, including water treatment; extensive monitoring of treated water, soil, vegetation, surface water, groundwater, livestock and wildlife; and adjustment of operations based on monitoring results.
Black Hills Pioneer: Has any recent testing been done regarding the geochemical makeup of the Minnelusa and Deadwood formations Powertech proposes to drill these Class V wells into?
Powertech: The Minnelusa currently serves as the disposal horizon for waste from oil and gas production within five miles of the Dewey-Burdock Project. Existing regional data indicate water quality exceeding 10,000 parts per million total dissolved solids in the project area. Powertech also anticipates that the Deadwood Formation will contain total dissolved solids exceeding 10,000 parts per million. Information supporting this assumption is found in Powertech’s permit application to EPA. Powertech will be required to verify the water quality in each target injection zone by testing prior to receiving authorization from EPA to use the wells. This will be done by sampling the water for EPA-required parameters, including general water quality parameters such as total dissolved solids, metals, radionuclides, and organic constituents.
Black Hills Pioneer: What are the chances this water could migrate from the Minnelusa and/or Deadwood formations into other aquifers?
Powertech: Powertech must demonstrate that the formation utilized is hydrologically separated and confined prior to authorization for injection by EPA, demonstrating that no water can migrate to another aquifer.
EPA’s Class V Underground Injection Control regulations require protection of any other aquifers from injected fluid through protective well construction requirements and evaluation of the confining properties of the injection zone.
Black Hills Pioneer (part one of four part question): In every Powertech application report we’ve gone through the text asserts wastewater and/or brine rejected for reinjection in the uranium recovery process after going through IX column and RO treatment will run through ion exchange for uranium removal followed by co-precipitation with barium sulfate in radium settling ponds for radium removal. Each report asserts that Powertech is confident these processes will remove enough thorium-230, lead-210 and/or other radionuclides to meet established discharge limits for both deep disposal well and land application disposal methods. The reports state that if concentrations in storage ponds do not meet those limits that “the effluent will be treated as necessary” to meet those limits. What we haven’t been able to find in any of the documents Powertech submitted to the EPA, NRC and SD DENR is a mention of how Powertech intends to treat over-limit effluents should they appear.
Powertech: Water cannot become effluent (discharged from treated water storage ponds) — whether through deep disposal wells or land application — unless it meets the respective effluent limits. Should thorium-230, lead-210 or any other parameter exceed the effluent limit, Powertech will implement additional treatment as needed for that parameter. The applications do not specify the specific treatment methods for other parameters, since at this time it is not anticipated that it will be needed in order to meet the effluent limits.
Black Hills Pioneer (two): Does the EPA/NRC/DENR not require that information in the application stage?
Powertech: The EPA, NRC and DENR permits and licenses will include effluent limits for treated wastewater disposal. As mentioned previously, Powertech has not specified specific treatment methods for parameters other than radium-226 since it is not anticipated that additional treatment will be needed. Should routine sampling of the water in the treated water storage ponds indicate that additional treatment is needed, Powertech will be required to coordinate such additional treatment with the appropriate regulatory agencies and demonstrate that it is effective before discharging the water in the ponds.
Black Hills Pioneer (three): How does Powertech intend to treat over-limit effluents to meet acceptable limits?
Powertech: Again, there will not be over-limit effluents since the water in the treated water storage ponds will not be discharged (i.e., become effluent) unless it meets the applicable limits for release.
Black Hills Pioneer (four): In the circumstance that these limits cannot be met after this further treatment, however rare such an occurrence may be, what would be done with the offending effluents?
Powertech: In the event that the water in the ponds does not meet the release limits, it will not be released until further treatment is implemented such that it meets the limits. The ponds have been designed with excess capacity and this may be used to perform additional treatment. The production and/or restoration flow rates also may be reduced (while still maintaining hydraulic control of each well field, which will be required by the NRC license).
Powertech is aware of a number of additional methods that can be used to treat effluent to further reduce concentrations of radionuclides. These include other types of ion exchange, reverse osmosis, filtration, coagulation, other co-precipitation reactions, and adsorptive media.
Importantly, the applications describe how the water quality in the treated water storage ponds will be relatively consistent and will not change rapidly due to the size of the ponds relative to their throughput. Frequent sampling in the ponds will be used to determine whether there are increasing trends in constituent concentrations, and additional treatment will be implemented if needed based on these trends.
Black Hills Pioneer: With Hong Kong-based Azarga Resources possessing about 17.5 percent of Canada-based Powertech’s common shares and Belgian nuclear management group Synatom owning roughly another 18.6 percent (Editor’s note: Azarga has made several financial deals with Powertech since this question was originally asked. They’ve also purchased all of Synatom’s former common shares, making them Powertech’s largest shareholder with roughly 40.5 percent of all issued and outstanding common shares), some are saying there’s little to no incentive for any states in the U.S. to approve any of Powertech’s proposed in situ uranium mines as it seems a large portion of the yellowcake uranium Powertech potentially produces would be spoken for overseas. How do you respond to this?
Powertech: Having major shareholders from around the world speaks well of the company and its financial prospects. For a number of reasons, nuclear powered electric utilities within the United States are the prime candidates for future sales of uranium from the Dewey-Burdock project. Significantly, the United Sates is the largest producer of electricity from nuclear power and thus one of the largest markets for uranium. Powertech is also aware that these domestic utilities strongly wish to contract with domestic producers, of which there are relatively few and thus at a premium. Stability and reliability of the domestic supply of uranium is encouraged, as the United States is currently highly dependent on foreign sources of uranium. (United States sources historically provide less than 10% of domestic demand.) Though Powertech has not yet contracted for the sale of uranium from the Dewey Burdock project, it readily expects to execute sales contracts with domestic utilities.
Neither Azarga nor Synatom have a controlling interest in Powertech nor do they have sole say in future sales, which will be a decision of Powertech’s management and board of directors.
Black Hills Pioneer: There have been assertions by opponents that Powertech may have several South Dakota state government officials in its proverbial pocket, helping the company plow through the application process — to the extent that some believe the state has already made its decisions. How do you respond to these assertions? Are there any South Dakota government officials holding Powertech common shares, Azarga resources common shares or Synatom/GDF Suez common shares that you’re aware of?
Powertech: Powertech is not aware of any state or local officials that own any stock in any of the aforementioned companies.
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