.....The company claims that there are approximately 90 million pounds of uranium with an average ore grade of 0.06%, one of the largest deposits in the US. For comparison, Canadian uranium deposits have ore grades at 10-18% uranium; the World Nuclear Association, the industry trade organization, considers an ore grade of 0.1% as low-grade and 0.01% as very low-grade.
......The Tallahassee Area Community (TAC), a Colorado not-for-profit corporation consisting of residents and property owners in the immediate vicinity of the proposed mine site, is opposed to the Black Range project and believes that the company's assertions are incorrect and misleading in many ways.
There are a number of regulatory, technical, and environmental issues that the company has not commented on and that raise serious concern:
1. The amount of water that would be required to be injected into the bore hole is massive: up to 50,000 gallons per hour/ up to 800 gallons per minute during operations.
2. This water would be pressurized to 1000-1500 psi (up to 100 times normal atmospheric pressure). The water pressure must be this high to fragment the sandstone uranium ore.
3. Presumably, the operation would require diesel powered equipment which would be very noisy and produce large amounts of diesel exhaust fumes as well as large amounts of greenhouse gas(GHG) emissions. Keep in mind that uranium powered electricity generating plants are touted as being pollutant and GHG emission free.
4. Water at standard pressure naturally contains dissolved atmospheric oxygen; the amount of dissolved oxygen increases as the water pressure increases. Although the actual amount that would be in the UBHM water is unknown, the scientific literature discloses that it would be at least four times standard and likely considerably higher.
5. When this highly oxygenated water comes in contact with the fragmented uranium ore, chemical reactions will occur. An unknown but significant fraction of the water-insoluble uranium oxide will be oxidized to the soluble form and would be dissolved into the water in the cavern (as will any other radioactive constituents and heavy metals). This contaminated water will end up in two places: some unknown amount will, under pressure, be forced out of the unconfined cavern into the surrounding sandstone aquifer to contaminate the local groundwater and the many domestic water wells in the area; the remaining contaminated water would be returned to the surface as the water/ore slurry.
6. Although Black Range considers this process as "mining", statements from the US Nuclear Regulatory Commission, as long ago as 1977 (NRC reviewed and updated in 2012), consider that the line that is to be drawn between uranium "mining" and "milling" is when ore in its natural form has had its gross appearance (and chemical nature) changed from the point of mining. It is at that point, NRC has stated, that the resulting change in the radiological characteristics require regulatory, health, and environmental consideration. TAC believes that the specific point is when the oxygenated pressurized water fragments the ore in the cavern. It is TAC's position that UBHM is a non-conventional uranium milling activity and would require a source material Radioactive Material License in addition to a Designated Mining Operation mining permit. Neither the NRC, the Colorado Department of Public Health and Environment (CDPHE), nor the Colorado Division of Reclamation, Mining and Safety (DRMS) have made a regulatory determination as yet (December 2012).
The second step in the proposed mining plan is to subject the water/ore slurry to a truly experimental process called Impact Ablation. A 750 pound/hour test machine unit has been developed by Ablation Technologies LLC of Casper, Wyoming (ABT). A 20 ton/hour production unit is proposed but has not yet been built. Black Range has announced that it will fund 100% of the construction cost of the production machine as a major part of its recently announced Joint Venture Agreement with ABT to develop the commercial process, to use it at Hansen, and to market the process to other uranium mining operations.
The procedure is for the water/ore slurry from UBHM to be injected from opposing sides of the machine at high pressure to create a high energy impact zone. The ore fragments would be further broken down by this impact, the fine grain uranium oxide portion would be separated from the bulk rock by gravity screening then collected, dried, and packaged for shipment (presumably by truck) to a conventional uranium mill for further processing into U3O8 "yellowcake". The company claims that the "ablated concentrate" will contain most (but admittedly not all) of the uranium in the ore in only 10% of the bulk volume, thereby significantly reducing the cost of conventional chemical processing.
This process also raises serious regulatory, health, and environmental concerns:
1. Impact Ablation is a brand new concept and has not been proved in production. One highly experienced mining engineer and consultant has told TAC that he has doubts that it will work as claimed.
2. Black Range insists that this process is "mining" and not source material processing ("uranium milling"). It bases its belief on peculiar wording in the definition of "ore" found in the Colorado Radiation Regulations, and thereby expecting to avoid the necessity of obtaining a source material Radioactive Material License. Federal regulations contradict this position and includes the "crushing" or "grinding", separation, screening, and concentration of uranium ore as beneficiation processes which are identified as source material processing activities. TAC pointed out the contradiction between Colorado and Federal regulations to the manager of the Radiation Management Unit of CDPHE. After reviewing our documentation, he stated (in correspondence to TAC in October and November 2012) that "the process, if implemented as we now understand it, would result in the possession of source material and would, therefore, require a source material radioactive material license at a minimum".
3. Since ablation is considered a non-conventional uranium milling activity, the waste product from the process -- 90% of the recovered rock from UBHM and all of the recovered process water -- would be defined as 11e.(2) byproduct uranium mill tailings. This would require very extensive (and expensive) procedures for their storage and ultimate remediation.
4. As mill tailings, the regulations imply that the waste rock could not be used to backfill the exhausted caverns and bore holes from the UBHM process as Black Range has proposed. That means that 90% of the rock fragments brought to the surface from the ore body would have to be impounded on the surface at the mine site creating a permanent environmental problem.
5. Black Range has proposed to recycle the water output from ablation by re pressurizing and re injecting it into the UBHM bore holes thereby minimizing the requirement for new water. As liquid mill tailings, contaminated by both the UBHM and Ablation processes, that would not be permitted , thus requiring "new" clean water for the entire UBHM/Ablation procedure. The contaminated water would have to be impounded on the surface in specially constructed impoundment ponds to preclude seepage down to the groundwater aquifer as well as being protected from overtopping the pond banks and contaminating the surface land and nearby streams and irrigation ditches during major storm events.
6. Both Colorado and Federal regulations have established criteria for the location of uranium mills and mill tailings storage facilities. The very first part of the first criterion is "remote[ness] from populated areas". The Tallahassee rural residential parcels (mostly ranging from 5 to 80+ acres), surrounding the entire Black Range project site on three sides, have been developed over the past 30 years, long before Black Range began their project plans. In addition to the ~600 individual property owners -- organized into 16 Property Owners Associations -- the area also includes a 160+ acre Benedictine Religious Retreat located on Tallahassee Creek and approximately one mile from the Hansen site.
7. Colorado legislation, confirmed in a 2010 Colorado Supreme Court decision, authorizes counties to disallow any mining (and milling) activity from specific portions of the county, at their discretion, based on human health, environmental, and/or socioeconomic concerns. TAC is committed to vigorously insisting to Fremont County that the rural character of Tallahassee be preserved and protected.
The third step of the Black Range plan is to transport the "ablated concentrate" out of the area for final chemical processing into yellowcake. The nearest conventional uranium mill is the White Mesa Mill in Blanding, Utah -- over 300 miles west of Tallahassee. A proposed new mill in western Colorado -- about 250 miles away -- has not yet received final regulatory approval and is facing strenuous opposition from some of the local population. Even if it receives final permit approval, there is no assurance that the mill would ever be funded or constructed.
An alternative that Black Range has suggested is to sell the concentrate outright to a major uranium producer who would then transport it to its facilities for processing, perhaps in Canada. The price that would be received by Black Range for the concentrate would be at a significant discount from the spot price of yellowcake since transportation and final processing costs would be borne by the purchaser.
Although Black Range continually cites the US market as the target market for its product, American nuclear energy demand is expected remain flat for the foreseeable future. The demand for uranium power plant fuel is, however, expected to increase elsewhere in the world, especially in Asia and the Middle East.
TAC has been instrumental in the passage of strong new legislation and regulations regarding how uranium is to be mined and milled in the state of Colorado. We intend to continue our efforts to protect our pristine rural mountain community from the adverse impacts to our health, environment, and socioeconomic wellbeing that would result from the mining and milling of a marginal uranium resource.
