Below are my notes from Wednesday's meeting as promised.
Sorry for the delay but I've been trying to piece together the project fly-through section as the reception dropped out (a big thanks to Hangseng for helping my to try and fill the gaps). I have opted to keep this section as it really amounts to a lot of partial phrases and is just too fragmentary to understand when you read it.
Anyway, just a couple of points about the notes:
................... = Poor Reception/ I couldn't hear what was said.
( ) = Clarifying comments made by me to help you.
? = Things that I was not 100% sure of.
** ++ """" = Not sure of identity of speaker.
Anyway, I hope you all get something out of them. It really was a VERY positive meeting, the tone of which can be lost in a written format.
NRC/STRATA ENERGY PUBLIC MEETING ROSS URANIUM ISR PROJECT 25 MAY 2011
ATTENDEES (PHYSICAL & TELECONFERENCE)
Stephen Cohen, NRC Keith McConnell, NRC Chris Pugsley, Thompson & Pugsley Ben Schiffer, WWC Engineering Tony Simpson, Strata Energy Wade Filkins, WWC Engineering John Kyle, Lyntek Rachel Hawkins, Lyntek John Fisher, WDEQ John Saxton, NRC Mal James, Peninsula Energy Gus Simpson, Peninsula Energy Pam Viviano, Ranchers & Neighbors Protecting Our Water and Board Member, Powder River Basin Resource Council Craig Hults, WDEQ/LQD James Bashor, BLM Richard Currit, Wyoming SHPO ?K?K?K?K?K?K?K?K?K?K ?K?K?K?K?K?K?K?K?K?K ?K?K?K?K?K?K?K?K?K?K
I. INTRODUCTION
Stephen Cohen (SC): This is an open meeting held at the request of Strata Energy, an applicant for a NRC license regarding the proposed Strata Energy Ross in situ recovery project, Crook County, Wyoming. This is a Category 1 open meeting. Members of the public are welcome to attend. If time permits, questions from the public will be solicited by the NRC staff at the end of the meeting.
A meeting report will be prepared by NRC staff. This report will be placed in a document file in the main public document room. Documents presented by any party will form part of the meeting record and be made available for the public to view, unless it is a proprietary document, and in accordance with NRC regulations. At the close of the meeting, I will repeat a list of action items and responsible parties, as agreed, so there are no misunderstandings. Our goal is to have this meeting report completed within 30 working days. We??ll start with introductions (see attendees section).
Ok, thank you very much. It??s Strata??s meeting so the floor is yours. I just want to point out that Strata will go through a PowerPoint presentation, which will be part of the public record, and Strata also gave us some large plots (?) which we will also put in the docket for the meeting report. Go ahead.
Tony Simpson (TS): Thanks Steve, thanks again for allowing us to come and put the best project in front of you again. As you saw last year, we approached with vigor, in terms of the quarterly meetings that we had and we actually tried to put everything together with all the different agencies. I think that what we are going to demonstrate here today is that we have been progressing this project quite rapidly and successfully. Actually, looking at our document now, I??m very happy with it. Hopefully it won??t take too long before we get your acceptance review comments and then we??re on our way again.
We also note that we were probably the first guys to have a pre-submission visit and I??m also happy to say that it looks like we are going to have a visit from one of your commissioners, probably out to the site in June. Magwood??s (NRC Commissioner) coming out there and we look forward to hosting him and showing him our project and also demonstrating a little bit about ISR mining, which will be great.
Same members of the team again. I would like to let them introduce themselves properly. Wade and Ben (from WWC Engineering), as you know, are basically the drivers of the permit process. At the end of this PowerPoint we??ve got for you, we??re also going to show you a bit of a video presentation which shows the level of detail of the design of the project and how far that??s actually progressed with Lyntek. Lyntek are actually here today to lend support to the project and the design that??s actually been accomplished.
WWC are the main runners of our project and Ben Schiffer is our coordinating our permits. As you know, Ben has been running it and running it very, very well. The only reason I??m in the room is because my dad said ??if you??re the most intelligent guy in the room, get out??. So I??m going to hand it over to Ben and let him run with it.
II. UPDATE NRC ON OTHER PERMITTING PROGRESS
Ben Schiffer (BS): Thanks Tony. We just had an introduction from Tony Simpson, Strata??s Chief Operating Officer. I??d like to talk briefly about some of the other permitting actions that have been ongoing.
As Tony mentioned, at the compliance recommendation of the NRC, we submitted three significant applications within three weeks, so all of those are ongoing along with the NRC Acceptance Review. So I??m going to talk about some of those. I??d like to also revisit the progress that the NRC has made on our application - it??s important to do that - and also talk about one significant item that the NRC has done, which is initiating the Section 106 tribal consultation. And then, as Tony mentioned, we??ve really been working hard, on the design ?V particularly of the plant - and we??d like to demonstrate where that??s gone, particularly in regards to safety and health to the public.
LAND QUALITY So we??ll start with the DEQ. As I mentioned earlier, we submitted three applications, almost simultaneously, to the NRC, then the DEQ and then the BLM Plan of Operations, all within three weeks in January.
The LQD determined that the application was technically complete in less than 45 days which really goes to them, that??s a lot of hard work, and we were happy with the outcome. Some of the review staff attended what we call a quarterly meeting. We really went on a tour of the site to look at some of the items they were interested in - some of the baseline items or places where we??re proposing some infrastructure. We did that on 21 April.
On 11 May, the LQD provided Strata with the first round of technical comments, and that was less than 120 days after receipt of the application. Again, that??s a lot of hard work on their part and now the work is back in our laps. We??re happy to do it. We have some comments and some questions and we??re proposing to respond and get back to them in about three weeks.
So in terms of the exploration programme, we??ve updated the drilling notification license to include areas west, southwest and north of the current permit boundaries as well as significant acreage to the south of the Barber project area, and that??s also through LQD.
WATER QUALITY From the Water Quality Division, Strata, on 14 April of this year, received a Class I Permit for up to five deep disposal wells targeting the Cambrian Flathead Edwards (?) systems. That was submitted in June 2010 and we received it after basically a nine or 10 month review. Air and Water Quality (divisional staff) really worked through it effectively and that says a lot about the quality also (of the application)?K?K?K.Right now we have other water quality permits in progress ?V construction stormwater, industrial stormwater. We??re also evaluating the need for a ?K?K?K.. and we??re also looking at a Class 5 USD (?)for domestic waste.
AIR QUALITY Our Chapter 6 Air Quality application is scheduled for (submission in) early June 2011 - I should actually have a draft of that on my desk later in the week. One of the things we??ve taken from some comments received on the GEIS, is really providing an extensive emissions inventory for the plant and wellfield operations, as identified in the Environmental Report (ER) provided to the NRC and site notes?K?K?K..We??ll also be providing the air quality application to the NRC as part of the common response package.
BUREAU OF LAND MANAGEMENT On the third week in January, we provided a Plan of Operations to BLM??s Newcastle Field Office. We received an email notification that the Administrative & Technical Review had determined that the application was complete and without deficiencies.
All the major components of the Plan of Operations were present although the BLM is kind of withholding formal determination, following the NRC??s Acceptance Review (deferral to lead agency?). Big parts of that plan are the surface reclamation plan, wildlife, cultural, hydrology, soil, use of private owners?? surface water, which Strata will be able to demonstrate.
CROOK COUNTY We??ve really been working extensively with Crook County, actually since the initiation of the project. In a lot of ways, we formalised that in April, with a MOU for road maintenance and dust mitigation. That was also provided to the NRC and we??re really proud of that. It was a kind of a keystone of our mitigation efforts in the ER and we??re really happy to follow through on the commitment we made in the ER.
It will also form a big component of the Chapter 6 Air Quality application. We looked at Chapter 6 and said ??ok, how does this fit in, what can we do that we know we are going to do it for air quality and how can we improve on that in terms of the MOU???
III. REVISIT PROGRESS ON STRATA APPLICATION TO NRC TO DATE
As everyone knows, on 4 January, we provided the NRC with the Combined Source & By-product Material License application. Within a couple of weeks, it was posted to ADAMS and, in a similar time, the review schedule was posted to the website.
Per the cover letter, on 25 February, Strata provided the NRC with a data set updating the radiological and meteorological data. That was received on the 25th. It also matched the ADAMS compliance requirement.
One of the things that we have really tried to do is keep in contact, basically PM to PM communication. Typically, we??ll talk with John (Saxton, NRC?) every couple of weeks and let him know what we??re doing and he keeps me in the loop on how things are going on the technical review side and also anything at all in terms of the Section 106.
By email notification on 2 May, the NRC was actively doing an Acceptance Review and we now feel that it is on track for 1 July 2011.
IV. SECTION 106 CONSULTATION
The NRC elected to initiate the Section 106 process very, very early and they did that, I believe, in February, via letter. The NRC has really followed through on that, following up with phone calls and emails to ensure that there??s broad outreach. Strata had actually proposed to do tribal outreach in October 2010 and we talked to the NRC about it and realised that it was going to be starting very early on anyway and we didn??t really want to pre-empt that.
Right now there are 10 tribes that have indicated that they would like to participate, 2 have declined, 3 are interested but not quite sure, 2 simply could not be contacted, 1 is kind of doing a wait-and-see and 6 are awaiting decision.
The NRC has really, really worked hard to ensure that these tribes are being contacted. One of the things that we??d like to do, as much as possible, as the applicant, is to acknowledge that this is really a government to government communication, but it is important and we want to actively track it and keep abreast of it.
Outreach to stakeholders ?V all stakeholders ?V has been really a strength of this project and we don??t look at the tribal outreach differently to other stakeholders. So, for us, we want to keep track of that process, actively anticipate and address any concerns that arise, facilitate interagency communication. We??re very glad to have the SHPO (State Historic Preservation Officer) on the line today?K?K?K.Coordinate on Section 106 outreach and what we??re thinking of here is a tour or anything like that, we??re prepared to do that.
Really, there are two primary issues here. One is the potentially eligible sites within the license area and then a similar issue, but a little bit different, is the potential impacts to Devils Tower TCP (Traditional Cultural Property). Basically, the other eligible sites will be worked through during the review.
We have taken a very close look at basically a viewshed analysis of Devils Tower and that??s the exhibit we have here, that we will be providing to the NRC, basically indicating that this project will not impact the viewshed of the Tower.
As I mentioned earlier, in terms of eligible sites in the permit, that??s part of the review. We did a Class III survey. It was comprehensive and exhaustive. The TCP, Devils Tower Monument, we??re about 10.2 miles east of the project, boundary to boundary, and again this demonstrates that we??re out of site of that viewshed. One of the things that we would like to be able to do, hopefully during a tour, would be to demonstrate that, particularly to the tribes that are interested, and we??d go to the Tower and we??d go to the project and see that you really can??t see the project from the viewshed.
One of the things we??re going to try and clarify is, in the Section 106 letters, some adjacent geological structures were identified to the tribes, as being part of that TCP, and our homework indicates that these are really not. The TCP extends, I believe, to the monument boundaries but that??s something that we??d like to talk about with the NRC and get clarification and confirmation of that. Obviously, all of the other eligible sites in the permit area will be addressed, in depth, during the review process.
One of the things we typically like to do is show (alludes to visual aid) where the project is. Here??s the monument with the Tower in the middle; here??s the proposed Ross permit boundary. We can point out a lot of other things - groundwater flow direction is?K?K?Kaway from the national monument. Predominant wind direction is actually from the south. So, again, there are a lot of ways beyond visual ?V water, the way the wind blows - that we can demonstrate that the project will not impact that TCP.
Moving forward, as Tony mentioned, we are clearly excited to have Commissioner Magwood coming out on site on 8 June. It will be a tremendous opportunity to talk about ISR, in general, and a very good project. We??re proposing to hopefully meet again with the NRC ?V we??re thinking maybe in 3 months after acceptance, in late September/October ?V and really close the loop with them.
We will continue coordination with the NRC on Section 106 outreach; really what we??re talking about there is hosting a tour, facilitating special visits to the site, anything we can do to ensure that the SHPO is brought in as soon as possible after the acceptance review and they can start their review of the project, in terms of eligible sites within the permit. As always, our stakeholder outreach continues, and we??ll have another quarterly stakeholder outreach meeting and we??ll let the NRC know when we??re doing those things and they typically want to know?K?K?K?K?K?K?K?K?K
As I mentioned before, I really believe that it??s very important that with the different applications that are ongoing?K?K?K?K?K?K?KThe NRC will be provided with a Chapter 6 Air Quality submission as well as the common response package in the LQD??s technical review.
As always, we will investigate ways for one-on-one tribal outreach.
At this point, I??m going to let Wade and Rachel and take over and they??re going to show you the project fly-through.
V. PROJECT FLY-THROUGH
?X General areas of central processing plant including IX, elution, precipitation, drying, chemical storage and restoration area.
?X Worker/public safety monitoring and decontamination.
VI. CONCLUSION
TS: In conclusion, we are really looking forward to the 8 June (NRC Commissioner Magwood??s visit). Will you be coming?
SC: As a tour guide.
TS: We??d like to talk to you to find out if there??s anything special you??d like?K?K?K..
SC: I wouldn??t do anything differently from the pre-submission visit. A site tour ?V allow about two hours there?K?K.
TS: Will you have time for a barbecue after?
SC: No, I have a 5pm appointment?K?K..
TS: We would also like to set another meeting for us to get together again?K?Ksay two or three months after the review.
SC: October is looking like a lot of things could possibly fall together, we might be out there for other purposes, perhaps we can meet with you out there.
TS: That would be perfect for us.
SC: While I have you all here, John can you please give us a brief synopsis of where we are at with the Acceptance Review ?V anything that you can say publicly?
John Saxton (JS): It??s proceeding on schedule. We??re going to have a meeting with the team in about the first week of June and see where everybody??s at and any issues that they??ve identified. Then we??ll send it to the upper management, probably about a week after that.
SC: Great, thanks.
TS: As I said, we want to continue the S106 process. I??ve been contacted by Alan (Bjornsen, NRC) and?K?K?K.
**: We urge you to continue your outreach, when we??re defining TCP??s, that??s when the NRC staff should be there.
TS: We believe the process is progressing on schedule despite the delays, which we had a number of. I think it??s given us all time to do other things and get on with it. We just thank everybody for the cooperation, thank the NRC, we??ve had nothing but a good relationship and we hope that continues.
SC: John, do you have any questions?
JS: No
SC: Do any other NRC staff have any questions?
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SC: At this time, we have finished the business of the meeting and we will now open it to members of the public. Are there any questions from members of the public?
QUESTION ??????: I missed the first part of the meeting through poor reception here and just wanted to ask, could you quickly elaborate on the tribal concerns, if there are any tribal concerns?
ANSWER SC: From the NRC??s perspective, where we are at with the tribes is that we started what we call the consultation process under the National Historic Preservation Act ?V Section 106. We started that process early because our experience has been that the tribal consultation process can take awhile, it can take a long time.
I don??t think that we??ve identified any issues; we??ve actually just started contacting the tribes. At this point, we??re just trying to find out which tribes are interested in consulting with the NRC. I don??t think at this point, although someone from staff or Strata can correct me, we??ve identified any issues yet.
??????: Ok, thank you, that??s what I??m seeing. I keep in contact with the NRC??s ADAMS quite often and I see there were no issues put forward but when the NRC queried them, some did come forward, seemingly reluctantly.
SC: No, we??re just starting the process and trying to find out which of the tribes are interested in consultation. The next step is to actually meet with the tribes and gain information on what their concerns are and then have some site visits.
??????: Ok, that??s great, thank you, that answered my question.
++: Need to work with the?K?K?K.the Wyoming SHPO be involved in that.
SC: That??s correct, that??s the Wyoming State Historic Preservation Office. Are there any other questions from members of the public?
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SC: Okay, I have not identified any action items. Is that correct?
**: Clarification of the TCP??s?
SC: Okay, clarification on the TCP??s. That??s an NRC action item.
TS: You??ve also got to get yourself out there (to site).
SC: Oh, it??s already a done deal.
SC: If there are no other questions, no other action items, I??d like to adjourn this meeting and thank Strata for coming in, thank everyone for listening. This is the last of our public meetings. We do have one more meeting today but it is a closed meeting, so thank you everyone and enjoy the rest of your evening.
(20min delay)