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meeting summary - received from nrc

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    MEETING REPORT
    DATE: Tuesday, October 26 ? Thursday, October 28, 2010
    TIME: See agenda (Attachment1)
    PLACE: Strata Energy, Inc.
    2869 New Haven Road
    Oshoto, WY 87271
    PURPOSE: To familiarize the U.S. Nuclear Regulatory Commission (NRC) staff with
    the proposed Ross in situ recovery (ISR) site and to review the application
    prior to submission to identify any major acceptance or technical review
    issues.
    ATTENDEES:
    See Attendees List (Attachment 2).
    BACKGROUND:
    Strata Energy, Inc. (Strata) submitted a Letter of Intent to the NRC staff on October 5, 2009.
    This letter notified the staff that Strata intends to submit an application in December 2010 to
    operate an ISR at the Ross site in Crook County, Wyoming. By letter dated August 25, 2010,
    Strata requested a site visit and pre-submission application review, to which the staff agreed and
    undertook at this meeting.
    DISCUSSION:
    NRC staff read the opening statement for the meeting. The staff explained that the three-day
    meeting would include a site visit in the morning of October 26, a groundwater model
    presentation after the site visit, a review of the application on October 26 through the morning of
    October 28, followed by a one-hour debrief. Members of the public were invited to attend the
    site tour, attend the groundwater model presentation, and observe the application review.
    However, the staff informed the meeting attendees that members of the public would not be
    allowed to view the application itself, as it is a pre-submission document. Furthermore, the
    application will also not become part of the meeting summary, because the application was not
    distributed to meeting attendees or removed from the premises by meeting attendees.
    October 26: Site Tour ? The staff and members of the public toured the entire proposed Ross
    ISR Project. Particular areas of interest were the Oshoto Reservoir,
    meteorological station, air sampling stations, general area of the wellfield
    development, and the central processing plant location.
    After the site tour, Strata staff presented a Powerpoint presentation of their
    geologic and hydrogeologic models for the site (Attachment 3).
    After the presentation, the staff started its review of the application. Members of
    the public left the Strata office.
    2
    October 27: NRC staff reviewed the application. Strata took one NRC staff person on a tour
    of the site to review air monitoring stations and other site features. No members
    of the public were present.
    October 28: Staff completed its review and started the debrief at 10:30 a.m. Members of the
    public were present for the debrief.

    Debrief Notes:
    NRC staff stated that it reviewed significant sections of the technical and environmental reports,
    as well as the groundwater model to be included with the application. The staff then
    summarized the findings by major topics and issues, noting that many other comments were
    provided in the application itself. Summarized comments are as follows:
    TECHNICAL REPORT (TR)
    General Comments:
    ? The staff noted that Strata has been addressing requests for additional information and
    open issues sent to other applicants.
    ? Loose statements ? Strata should ensure that the application includes precise
    statements regarding those aspects of the operation that will be licensed.
    Section 1.0:
    ? Lixiviant Composition ? the lixiviant composition was discussed in two places in the TR;
    however, the two discussions were inconsistent.
    ? Line Drive Pattern ? If the line drive pattern is to be used, Strata needs to demonstrate
    that this well orientation can maintain an inward gradient.
    ? Confidential Information ? Staff reminded Strata of the 10 CFR 2.390 requirements for
    withholding information from the public.
    ? Surety Estimate ? Staff reminded Strata that a surety estimate is required in the TR.
    Section 2.0:
    ? Wellfield Layout ? The staff found the wellfield layout confusing and it may have
    contained too much information. Presenting the wellfield module boundaries produced
    more questions regarding the manner in which extraction and restoration would occur
    simultaneously.
    ? Wellfield Boundaries ? Wellfield boundaries provided by Strata were not complete
    because exploration was still occurring onsite. The staff stated that Strata should
    provide the maximum extent of the wellfields onsite to allow for the most conservative
    assessment.
    ? Abandoned Wells ? Strata should clarify the total number of abandoned wells and then
    provide the number of pre-existing abandoned wells - those installed and abandoned by
    Strata, and the number of wells being plugged.
    ? Meteorological Data ? The staff noted that two months of data are missing. Also, Strata
    needs to provide the long-term meteorological data analysis to determine if the site data
    are representative of long-term conditions. Also, the staff is unclear how the TBNG data
    is representative of the site.
    3
    ? Radiological Background Characteristics - The staff reviewed Regulatory Guide Table 1
    and Table 2 for selecting air particulate locations (including radon, direct radiation, and
    soil) with Strata and compared the current air particulate locations with meteorological
    data. Strata had only one air particulate sampling location in one of the three highest
    potential air concentrations.
    Section 3.0
    ? MIT Failures ? Strata should state its procedures for addressing potential groundwater
    contamination from an MIT failure.
    ? Wellfield operations ? Strata should discuss the methodology used to determine
    sequencing of wellfield operation, surface reclamation, and groundwater restoration to
    ensure that interference does not occur in adjacent wellfields.
    Section 4.0
    ? Staff reviewed air and liquid effluent program. Strata indicated that it plans to include air
    flow and fan location information in the TR. Staff noted that Strata included HVAC maps
    that show positive and negative air pressure; however, staff noted that this information
    was not fully explained in the TR. Staff suggested more information so that staff can
    develop a better understanding of air movement and discharge from restricted to
    unrestricted areas.
    Section 5.0
    ? Staff noted that the organization chart did not recognize the Quality Assurance position
    and recommended that this position be included in the organization chart.
    ? Staff noted that the bioassay section referenced Table 1 and Table 2 of Regulatory
    Guide 8.22. Staff pointed out to Strata that Table 2 applies to in vivo measurements and
    asked if Strata plans to conduct in vivo measurements. If not, Strata may want to revise
    this section.
    Section 6.0
    ? Statistical methods - Clearly identify statistical methods used t determine background
    and baseline values.
    ? Reduction restoration - Provide detailed descriptions of the reduction restoration and biorestoration
    methods that may be used during groundwater restoration.
    ENVIRONMENTAL REPORT (ER)
    ? Alternatives ? only one central processing plant location alternative was presented, and it
    was not a viable alternative. Strata mentioned that the Lance uranium district
    encompasses and area approximately 25 miles x 6 miles and that 12 other ISR sites
    could be developed. Therefore, the staff suggested that Strata describe other potential
    central processing plant sites. Also, other viable alternatives might include size of the
    facility and other means of processing the uranium.
    ? Cumulative Effects ? This was noticeably absent in the ER. Not only are there numerous
    operating oil wells in the area surrounding the site, but there are three operating wells onsite.
    These need to be addressed in the ER.
    ? Mitigation ? Mitigation descriptions need to be expanded in the ER.
    4
    ? Transportation ? Items such as: 1) ingress and egress (location); 2) vehicle types; and 3)
    ingress and egress schedule (construction and operation) need to be described.
    ? Air Quality ? in order to calculate the impact from greenhouse gases (required by EPA),
    the following needs to be described: 1) all vehicles and equipment powered by internal
    combustion engines that would be used on the site; 2) the purpose of each
    vehicle/equipment; and 3) the length of time each would be used.
    ACTIONS:
    None
    ATTACHMENTS
    1. Agenda
    2. List of Attendees
    3. Presentation
 
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