Frequently Asked Questions about the Centennial Project
Regulatory Oversight of In-Situ Recovery
What agencies oversee uranium recovery operations in Colorado?
The U.S. Nuclear Regulatory Commission (NRC) oversees and regulates the process of in-situ uranium recovery. However, Colorado is an ‘Agreement State,’ meaning that state agencies have entered into agreement with NRC to oversee all in-situ recovery licensing and permitting on that federal agency’s behalf. The Colorado Department of Natural Resources’ (DNR) Division of Reclamation, Mining and Safety (DRMS), in conjunction with the Mined Land Reclamation Board, will oversee the mining and reclamation sites at the Centennial Project, including permitting and regulating the extraction of the mineral, reclamation of affected land and protecting and implementing the state’s groundwater quality standards. The Colorado Department of Public Health and Environment (CDPHE) will handle licensing and oversight of the handling, transportation and disposal of uranium and any byproduct material, as well as any applicable issues relating to surface water and air quality for the site.
Colorado agencies have a strong record of reviewing radiation matters and licensing uranium mills. The effect of this agreement is that the local state personnel are going to be the regulators, rather than a distant federal agency out of Washington. Regulatory standards are available on the agencies’ respective Web sites.
Also, the U.S. Environmental Protection Agency (EPA), Region 8, which is located in Denver, will be directly involved in the review and issuance of the underground injection control (UIC) permit.
What procedures will Azarga be required to follow at the Centennial Project?
Specific procedures for the site are part of the permits and are dependent upon background data, mine planning and engineering design. Since April 2007, Azarga has been gathering environmental data and conducting baseline studies for groundwater and surface water hydrology, air, geology, traffic, soil studies, geography, socioeconomic impacts, and other data to support its permit applications to federal, state and local regulatory agencies in the latter part of 2008. Operational, emergency and reclamation plans will be available when the permit application is submitted.
Upon granting permits and licenses, the regulatory agencies will issue site-specific conditions that Azarga is required to follow. All industrial safety procedures, including the testing of air, water and soils, will be conducted regularly to alleviate concerns of nearby residents. Until the agencies have the application and data to review, Azarga cannot know the site-specific requirements. Once approved, those documents will be available for public inspection.
What type of bonding has Azarga secured to ensure that site restoration is completed at the end of the project?
Azarga intends to be an excellent corporate citizen in all aspects of mining operations. The company has already submitted the required bonds for installing and rehabilitating monitoring and exploration wells. As of August 2007, for the two Notices of Intent (NOI) approved by the Department of Natural Resources’ Division of Reclamation, Mining and Safety (DRMS) for drilling monitor wells and core holes, Azarga has provided reclamation performance bonds in excess of $350,000 for its preliminary testing operations.
For ISR operations, Azarga will also secure surety bonds as required by the government so that any costs of restoration and plugging of wells and removal of surface facilities are guaranteed, should a state or federal agency be required to contract with a third party to complete the restoration work covered by the bond. This money is held in an Escrow account, which is managed and controlled by either the State or Federal Government, until the restoration work is completed and approved. This type of “insurance” will guarantee the healthy future of the site for generations.
When will Azarga detail its engineering plans for the Centennial Project?
The company will present its formal applications for mining permits and licenses to the regulatory agencies in the latter part of 2008. The applications will contain all specifications for the planned ISR program and will be available for public review. As of August 2007, Azarga is in the early stages of collecting baseline environmental data. Therefore, the company cannot detail the proposed operations before our applications are presented to the permitting regulatory agencies.
How is Azarga communicating with the public about the Centennial Project?
Azarga communicates its plans with the public through our Web site, fact sheets, informational hotline, ongoing public meetings and periodic email updates on field activities.
What is the difference between leaching and In-Situ Recovery?
Leaching implies heap-leaching above ground using strong chemicals, a process used in gold recovery. Because In-Situ Recovery (ISR) does not use strong or caustic chemicals, but rather oxygen and sodium bicarbonate, ISR has become the common name now used to describe the process of recovering uranium through water wells.
Will Azarga be undertaking open pit mining at the Centennial Project?
As of August 2007, Azarga continues to evaluate the feasibility of mining all of the deposits with the ISR method.
However, open pit mining for a couple of the deposits is a last-resort possibility. Also, we are considering the possibility of a commercial gravel quarry on a portion of the southern properties where the ore bodies are much shallower. Where the ore is shallow, there may not be any water present surrounding the ore. We are looking at several methods of recovery for this shallow ore and we are considering removing the valuable gravel deposits over the ore and then removing the natural uranium ore to transport it to a mill facility. We have also identified another method wherein we can use slurry walls surrounding the ore to isolate the uranium, and through purchase of water rights, increase the water level for In-Situ Recovery (ISR) production.
It will take more extensive testing before we make an application for either of these methods. Economics and regulatory approval will dictate the mining method. Permit applications will be submitted in the latter part of 2008.
Does ISR create tailings?
No. One of the key advantages of ISR mining is that tailings are not generated. There will not be tailings at the Centennial site even if there were to be an open pit. Azarga will extract and transport the ore to a central processing facility and quarry the gravel for sale as a commercial rock product. How will Azarga remediate the site after the ore has been depleted?
Azarga will totally reclaim the site in a manner approved by the State of Colorado, such that it can be returned to its former uses. The groundwater quality will be restored to prior use, wells plugged, pipelines removed, surface re-vegetated, and any leased land returned to the landowner. Any surface disturbances created as a result of Azarga’s activities will be remediated as required by the regulatory authorities.
Has the restoration and closure of U.S. ISR operations been proven to be feasible?
Yes. The groundwater restoration, or cleanup of an aquifer impacted by in-situ uranium solution mining, has been shown to be technically, physically and economically achievable. (Ref. NRC NUREG/CR 6870) Some recent successful ISR mine closures include the O’Hern, Hobson, Zamzow, Pawlik, and Longoria mines in South Texas, all owned by different companies. There are no historical cases in the United States where ISR has made a long-term negative impact on public health or the environment.
Well Field Operations
What is the location of the uranium in the aquifer?
The uranium is contained in the uppermost sands of the Laramie-Fox Hills formation, which is a marginal marine sandstone horizon of Cretaceous age. Some drinking water is produced from this horizon, but wells are located at a considerable distance from the uranium ore, where the water quality is not conducive for human consumption. The depth varies from 80 – 600 feet below the surface, depending on the thickness of the over-lying strata. The uranium ore body and aquifer already naturally have heavy metals and salts present, the foremost of which is uranium.
How much water will Azarga need for the ISR process?
The water that is used in the mining operations is derived from the pore space in the rock that contains the uranium ore. During in-situ operations, about 99 percent of the native groundwater is continually recirculated and is not consumed. However, a one percent bleed is required by regulation, which will be diverted to an evaporation pond. Assuming an operation flow rate of 2000 gallons per minute, this would result in 20 gallons per minute being consumed— approximately the same flow as a garden hose. The company’s objective is to minimize consumption of water.
How will the recovery solution be treated before injection into the aquifer?
“Treated” during operation means adding oxygen and sodium bicarbonate to native groundwater. During the restoration process, the word “treated” means removal of any ion build-up in the water during recovery. Some of the metals are re-circulated with the injection solution and not removed (or precipitated) until the end of the recovery process at the groundwater restoration phase. These precipitated metals, such as selenium, would be packaged and disposed of at a licensed facility.
Does Azarga plan to use any acidic recovery solution for this or other projects?
No. We do not plan or intend to use any acidic recovery solutions at this operation. In the history of ISR uranium mining in the United States, only Nine Mile Lake in Wyoming has had a test of acid production. While some in-situ operations in foreign countries have commonly used stronger leaching agents, such as sulfuric acid, which is more reactive and leaches out much more of the metals and salts and takes longer to restore, these operations are regulated by a different standard and are irrelevant to the U.S. industry.
When will drilling begin for the Centennial Project?
Azarga began drilling monitoring wells, as allowed by its exploratory drilling permit, during July, 2007. Well field drilling for recovery will begin after all mining permits are in place. Permit applications will be submitted in the latter part of 2008.
How deep will the wells be?
The wells will be drilled through the ore horizon. The depth varies from 80 – 600 feet below the surface, depending on the thickness of the over-lying strata.
How many wells will there be during operations?
The number of wells is dependent on the final engineering study. However, in the area of the ore, wells will probably be spaced between 75 to 100 feet apart. In the ISR process, wells need to be closely spaced in order to extract the uranium, due to its tendency to precipitate in the subsurface environment over longer distances.
Where will the wells be located?
The injection and production wells will be sited on the surface above the ore bodies. Specific surface locations will be determined, along with the final number of wells, following the final engineering study that will be reviewed during the public permitting processes. Azarga will provide the exact locations and other details in its regulatory permit applications, which will be open to public inspection. Previous drilling by Union Pacific RR’s Rocky Mountain Energy subsidiary precisely located the deposits when exploration drilling was done. Colorado law allows that information will remain proprietary and confidential, due to the number of the other uranium prospectors and Azarga competitors in the area.
Who pays for the electricity to run the wells?
Azarga will secure electric power for its operations at the Centennial Project from Poudre Valley REA.
Will the well fields and recovery operations create any light pollution?
Plant operations will be inside buildings and there will be very little light pollution. Where lights are required in well fields for night operations, the company will evaluate such alternative measures as downward-directed lights and barriers to minimize light pollution.
Is Azarga handling the closure of bore holes and monitoring wells left by Rocky Mountain Energy Corp. after the initial exploration of the ore zone in the 1980’s?
Yes. RME installed and plugged bore holes during exploration of the ore zone in the 1980s, and our understanding from the State is that there may be some unplugged. Azarga will perform aquifer testing to determine if the bore holes were sealed adequately. Where the testing determines that sealing is not adequate, the company will undertake a re-plugging of the bore holes through a process of re-drilling and plugging with bentonite gel.
Azarga is also attempting to locate and repair old monitoring wells that were installed by RME in the early 1980s. Some of these were broken and have been repaired for our use in baseline monitoring; some cannot be repaired and are being sealed by our contractor. The Department of Natural Resources Division of Reclamation Mining and Safety and Division of Water Resources have inspected the wells and our repair activities, and found our efforts to be satisfactory.
Can Azarga ensure that the recovery solution will not spread outside of the ore deposit into underlying or overlying aquifers and affect the water quality?
Yes, for several reasons:
Nature of the Strata: Previous studies have revealed that the ore zone is confined above and below by layers of impermeable strata (mudstone/siltstone), through which the solution cannot travel.
Wellfield Design: The proposed ISR operations are designed to isolate the operational portion of the ore zone from any surrounding zones that contain potable water. This necessity to confine the operations to the uranium zone is a primary requirement by the regulatory authorities before a company is allowed to mine. The movement of the recovery solution through the ore zone is controlled by the design and operation of the ISR system, instrumentation and monitors of the wellfield and the monitor wells that surround the wellfield. Once the uranium is dissolved, the loaded recovery solution is pumped to the surface, and this extraction pressure keeps the solution moving through the ore in the closed recovery process.
Bleed Pressure: Furthermore, slightly more water will be withdrawn than is re-injected, known as a bleed, which maintains a “cone of depression” in the mining area. Because water flows from high to low water levels, this gradient results in a flow from the ore zone up into the production well, confining the recovery solution to the mining zone.
Monitoring: As a final safeguard, the ore zone will be surrounded, both laterally and above and below, by monitor wells which are frequently sampled to ensure that all mining fluids are retained within the mining zone. This zone is surrounded by the mandated monitoring wells surrounding the mine zone, and those wells are measured daily by highly-trained staff for water pressure (indicator of flow direction), as well as chemistry, on a weekly basis that tells if indicator elements that are more mobile than uranium can be detected. Any imbalance in a well field can be reversed by increased pumping in the wells that are closest to the monitor perimeter to level out any imbalance.
Have any U.S. ISR operations ever contaminated drinking water supplies?
No. No ISR recovery project in the U.S has ever contaminated water supplies. The water located in aquifer zones where uranium occurs is naturally rich in uranium and other minerals, and thus is not appropriate for nor used as a source of drinking water. The purpose of regulatory review and receipt of permits is to assure the public that operations will not negatively impact human health or the environment.
Opponents of ISR point to an NRC report that they say “verifies that ISR contaminates drinking water supplies.- Is that true?
“NUREG/CR6870: Consideration of geochemical issues in groundwater restoration at uranium in-situ leach mining facilities” was published in January 2007 for industry, licensees, state regulators, and NRC staff who oversee uranium ISR facilities and assess the costs associated with their restoration.
The report does not verify contaminated water supplies, which are defined as “a system that supplies drinking water for human consumption.- Rather, it indicates a tendency for ISR operations to increase the mineral content of water at the mine site, where water is already naturally contaminated with high metals beyond human use.
The focus and purpose of the NRC report is to be a guide for industry on future ISR projects to estimate the costs and methods of restoring groundwater at the mine site to its baseline conditions. In no way does it discourage ISR operations. The report states: “For this reason, the U.S. Nuclear Regulatory Commission (NRC) requires licensees to ensure that sufficient funds are maintained by the licensee for restoration of the site to initial conditions following cessation of in-situ leach mining operations.” Clearly, the report is not emphasizing groundwater contamination, but rather provides tools for industry to further facilitate such operations and estimate the restoration costs at a site.
Will the recovery solution and injection pressure have any detrimental impact on the aquifer rock formations?
No. No U.S. aquifer has ever been damaged by ISR mining. Upon completion of ISR operations, the subsurface contacted by the recovery solution returns to a state consistent to what it was prior to mining.
How will Azarga demonstrate that drinking water is safe surrounding the permit site? As required by law, all water supplies surrounding a site that involves ground water chemistry are monitored so the public can be confident that their safety is not compromised. With regular testing, the population can rest assured that their drinking water is not affected.
Hasn’t the EPA lowered regulatory limits for water quality after some ISR operations?
The EPA groundwater standards include what is referred to as an alternate concentration limit (ACL), if all practical efforts to meet the baseline condition of an element are unsuccessful. ACLs apply only to water in the mine area, which is already high in minerals and exempt from human use. The altered concentration limits are not applied to drinking water, and still provide an equivalent protection of human health and the environment.
How will Azarga ensure safe air quality surrounding the permit site?
At the Centennial Project, eight stationary air-monitoring stations will be set up at the boundary of the permit area to measure levels of radon and other parameters as specified by the Colorado Department of Public Health and Environment, and to assure the public that safe levels of air quality are maintained. Two will monitor only particles less than 10 microns in diameter, and the remaining six will test all particle sizes.
Can residents and livestock remain living next to the recovery site during ISR?
Yes, absolutely. The areas surrounding the permit areas will remain safe for all activities and residents, just as they are today.
The suspension of any activities by the landowner is only within the operating area, where the drilling rigs, vehicles, wells, monitoring equipment and backhoes are treated as industrial equipment and restricted to qualified personnel only for the safety reasons just like any industrial site.
ISR production also consists of a well field, which contains numerous water wells usually spaced at approximately 100 feet apart or closer. These wells are constructed from polyvinyl chloride (PVC) and livestock can damage the well head that is exposed above the surface. The Colorado Department of Public Health and Environment will attest to the fact that areas adjacent to the operating permit areas will be as safe for all activity as before mining.
What radiation exposure limits are set for the public from uranium recovery projects?
As an agreement state, the Colorado Department of Public Health and Environment and the Colorado Department of Natural Resources’ Division of Reclamation, Mining and Safety, along with the U.S. Environmental Protection Agency, oversee the Nuclear Regulatory Commission’s limit on radiation exposure for any member of the public from a uranium extraction facility at 25 millirems per year, with the condition that exposure be less if reasonably possible.
This limit is one-sixteenth of the average amount of radiation (400 millirems) that a Colorado citizen receives each year from natural sources alone. Azarga intends to maintain exposures well below this limit and will follow other requirements issued by regulatory agencies.
Would spills of uranium during transport pose any danger to human health?
No. Operations that use water as the primary component can incur spills, and all ISR projects have had a number of minor leaks, but the most important aspect is that those spills are minor and have had no long term negative affect on human health or the environment. Further, spills of ore or resin beads with uranium from the Centennial Project are very unlikely, but in the case of a spill, would ALSO pose no danger to human health or environment.
The radioactivity of uranium in one gram of Weld County ore is 134 pCi (picoCurie) and that of pure natural uranium is 670,000 pCi (picoCurie) (assume 200 ppm). The latter is close to the radiation contained by a self-luminous watch dial (up to 500,000 pCi). During transport from in-situ wellfields, natural uranium will be tightly bound by ion-exchange bonds to resin beads similar to plastic, presenting no danger to human health. Nevertheless, any and all such spills would be tested and the soil would be excavated, placed in 55 gallon drums and stored until closure or sent to a licensed mill tailings site. Azarga will provide training as needed to local first responders, but the community hazardous material responders already have sufficient training to deal with any such emergency. It can be readily cleaned up and removed to a disposal site.
Can the radiation exposure from ISR cause cancer?
No. Epidemiological studies have shown that ISR operations do not increase the risk of cancer. (Boice, Mumma, Schweitzer, Blot: “Cancer mortality in a Texas county with prior uranium mining and milling activities, 1950-2001”; Journal of Radiological Protection, 2003.) To view additional peer-reviewed scientific studies that confirm this fact, visit the Colorado State University Department of Environmental & Radiological Health Sciences Web site at www.csu-cvmbs.colostate.edu/academics/erhs/health-physics/Pages/health-physics-uranium-mining-information.aspx.
There is no need or requirement for annual cancer screenings as a result of this type of mining operation.
Is the uranium processed into “yellowcake” at the recovery site?
No. The uranium we extract is not yellowcake, nor will it ever be processed at the Centennial Project site into yellowcake. Resin beads loaded with the natural uranium will be transported from the Centennial Project to a central processing plant, most likely located in eastern Wyoming. There, the uranium is stripped from the loaded resin, precipitated and dried, yielding a uranium oxide product (U3O8) with a rich yellow color, called “yellowcake. The resin beads are returned to the ISR site and reused in the recovery process.
What is the method of transport for uranium from the Centennial Project to a processing facility?
Azarga currently is evaluating its options for using licensed truck carriers or rail transport. What market will the uranium recovered by Azarga be sold to?
Due to high demand, a deficit of domestic uranium supplies, and concerns about the security of foreign supplies, the uranium mined in the United States will stay in the United States for nuclear power generation.
U.S. utilities have the largest demand for uranium in the world. Our nation obtains 20-percent of its electricity from nuclear power and consumes approximately 55 million pounds of uranium annually. Only three to four million pounds are produced from domestic uranium reserves, with the other 50+ million pounds coming from foreign markets such as Kazakhstan, Australia and Canada. U.S. nuclear power generators simply prefer to buy uranium produced in the U.S., and we can provide them an adequate and secure supply.
To expand further, we would note that many environmentalists concerned with global warming have asserted their support for nuclear power, as the leading method of reasonably-priced energy production without carbon dioxide emissions. Uranium is the one element that can help meet growing energy demands while not contributing to carbon loading in the atmosphere, as fossil fuels do.
Could the uranium recovered at the Centennial Project be a target for terrorists?
Naturally-occurring uranium in its ore state poses little danger to the public, and ore would be incredibly difficult to use to create a national security issue. Uranium is found in small quantities everywhere, and in perspective, poses less danger to the public than a standard gasoline filling station or surfaceexposed propane tank for a terrorist attack. Azarga knows of no U.S. Department of Homeland Security rules that apply to its operation, and any other security measures required by the regulatory authorities will be addressed accordingly in our permit applications.
Will the Centennial Project produce low-level radioactive waste materials and transuranics?
How are waste materials handled, and where are they disposed of?
No, low-level and transuranics are definitions for waste products of a nuclear reactor. Transuranics are not a product of uranium mining.
Any wastes generated from ISR mining are called by-product material, and are disposed of only at an NRC-licensed mill-tailings site or a commercial disposal site. There is one such mill site in Colorado in Canon City west of Pueblo. In surrounding states, two mill sites and one commercial site exist in Utah and one mill site exists in Wyoming. Plans are underway by other operators to build additional sites in Coloardo, New Mexico, Utah and Wyoming to meet demand.
Which NCR-approved waste facility will Azarga Uranium Corp. be using?
The Nuclear Regulatory Commission licenses mill tailings sites at uranium processing mills. There are currently four such sites in the U.S. and one commercial site for disposal only. These are the Cañon City Mill in south-central Colorado owned by Cotter Corporation, the White Mesa Mill in southeast Utah owned by Denison Uranium Corp., the Shootering Canyon Mill in east-central Utah owned by Uranium One, and the Sweetwater Uranium Mill owned by Kennecott Mining Corp. The commercial site is located in Clive, Utah. Azarga currently is evaluating its options for a NRC-approved disposal site for the Centennial Project.
Does Azarga expect to recover any other by-products in the ISR process?
As of August 2007, we are not aware of any other by-products or associated minerals that will be mined by the ISR process at the Centennial Project
Why is Azarga purchasing real estate and empty buildings in Weld County?
The company continues to acquire land that it feels is in key locations for recovery of its reserves. In Colorado, the minerals estate is senior to the surface estate, but Azarga has chosen to purchase certain surface lands, rather than exercise its legal option of forced entry onto those lands where we possess mineral rights. Some buildings that Azarga has acquired will be used for storage of equipment to discourage vandalism and prevent theft.
Will Azarga rent pasture and relocate livestock on leased land?
Arrangements will be made with those landowners that may be affected.
Azarga Employees and Contractors
Has Azarga Uranium Corp. or its subsidiaries ever completed and restored an in-situ recovery operation?
While the company just recently entered into the industry and has not undertaken any previous recovery projects, Azarga’s key personnel have a combined 200 years of experience in the uranium industry throughout the United States, and have brought 12 in-situ operations to the mining stage and five to the closure stage.
Does Azarga Uranium Corp. or its subsidiaries have any connection to the activities of the company previously called Azarga?
Azarga Uranium Corp. is a new company and has no connection to the activities of the company that previously used the Azarga name.
Do Azarga’s executives have ongoing affiliations or obligations to past employers in the industry?
Azarga’s executives have no affiliations with previous employer firms, nor involvement in any operational or reclamation issues from previous work done for other firms. The company’s executives are a team of very capable and experienced uranium industry experts who have great respect for the ISR process.
How will Azarga find qualified personnel for the Centennial Project?
Azarga has brought together experienced management and will be able to use this experience in the training of new staff. Azarga has an excellent recruitment and training process and will use the experience of its management team to secure the right staff.
Will employees receive special training for monitoring equipment?
Yes. Azarga operators will receive extensive training, and the regulatory requirements for monitoring practices will be emphasized in training. Both management and the regulatory agencies will be auditing the performance of the operations on a regular basis.
What is Azarga’s current financial standing?
Azarga is very strong financially. The projects that the company has acquired are two of the best deposits in the US. Because of the importance of our projects and the strength of our technical team, the company has been able to raise $23 million in the financial markets. We will use these funds to conduct detailed environmental surveys in preparation for making applications for operating permits to the regulatory authorities, as well as engineering, exploration, administrative needs, land purchases and leasing, bonding, and many other uses. Azarga is a public company and as such makes its finances public. Quarterly and other statements are available online at www.Azargauranium.com.
Will Azarga profit from the mining of uranium?
At current uranium prices, it is anticipated that the company will make a considerable profit from the sales of uranium to U.S. utilities. The project also has the benefit of encouraging economic development, including excellent jobs and employment benefits for the workers.