Memo to: EPA Docket (EPA-EPA-HQ-OAR-2012-0788) 

Subject: Meeting on Notice of Proposed Rulemaking for “Health and Environmental Protection Standards 

for Uranium and Thorium Mill Tailings”, Subpart F of 40 CFR Part 192 

On May 14, 2015, EPA staff members met with representatives of the uranium recovery industry at the Best 

Western Ramkota Inn in Casper, Wyoming to discuss the proposed rulemaking that would revise "Health and 

Environmental Protection Standards for Uranium and Thorium Mill Tailings” (40 CFR 192). The 

representatives gave the presentation attached to this memo and discussed it with EPA. The meeting agenda is 

also attached. 

The following persons participated in the meeting: 

Industry representatives: 

Harry Anthony, Uranium Energy Corp 

Eric Brandjord, IML 

John Cash, Ur-Energy 

Jim Clay, Cameco Resources 

Travis Deti, Wyoming Mining Association 

Paul Goranson, Uranerz Energy Corporation 

Tracy Hanna, Uranerz Energy 

Leland Hoffman, AUC LLC 

Ben Klein, Heather Podesta and Partners 

Ralph Knode, Strata Energy 

Dawn Kolkman, Uranerz Energy 

Gregory Kruse, Uranium One, Inc. 

Oscar Paulson, Kennecott Uranium Company 

Mark S. Pelizza, M.S. Pelizza and Associates 

Katie Sweeney, National Mining Association 

Mike Thomas, Uranerz Energy 

Jim Viellenave, AUC 

Donna Wichers, Uranium One Americas 
EPA Representatives: 

Anthony Nesky, Center for Radiation Information and Outreach, EPA Radiation Protection Division 

Tom Peake, Director, Center for Waste Management and Regulations, EPA Radiation Protection 

Division 

Ingrid Rosencrantz, Center for Waste Management and Regulations, EPA Radiation Protection Division 

State of Wyoming 

Miles Bennett, Wyoming Department of Environmental Quality 

USGS Study on 

Texas Uranium 

Restoration 

released in 2009.

Report used by the 

environmental community 

to claim that ISR uranium 

mines have not been able 

to restored back to 

baseline.

May, 14, 2015

Casper, WY
But when viewing under a different light, a totally different story is uncovered. 

Yes, a few ions that carry no related EPA health standards or concerns are not 

restore exactly to baseline values. This is because they vary in concentration as a 

function of pH. These innocuous ions include: Calcium, Bicarbonate, Carbonate.

However when the light is focused more accurately on the 13 Primary 

Drinking Water Standards Ions the story changes to one of a successful 

restoration legacy. The environmental opposition has offered only myth, emotion 

and hyperbole; the industry offers these following facts as reported by the USGS.
Restoration Table Elements and EPA Standards

EPA Primary Standard EPA Secondary Standard

Calcium None Non

Magnesium None None

Potassium None None

Carbonate None None

Bicarbonate None None

Ammonia-N* None None

Molybdenum None None

Silica None None

Conductivity None None

Alkalinity None None

Sodium None None

pH None 6.5 to 8.5 

Iron None 0.3 ppm

Manganese None 0.05 ppm

Sulfate None 250 ppm

Chloride None 250 ppm

TDS None 500 ppm

Fluoride 4 ppm 2 ppm

Nitrate-N 10 ppm None

Arsenic 0.01 ppm None

Cadmium* 0.005 ppm None

Lead* 0.015 ppm None

Mercury* 0.002 ppm None

Selenium 0.05 ppm None

Uranium 0.03 ppm None

Radium-226 5 pCi/l None

* Ions not introduced while mining and are not contained in the ore. 
Total Dissolved Solids. 

None of the 22 projects reviewed by USGS met EPA’s MCL 

for TDS of 500 mg/l. 

Values ranged from 786 to 6349 for baseline. 

After restoration, TDS was restored to baseline values at 15 

sites. The remaining sites were restored to within 200 

mg/l TDS. These remaining sites still did not meet EPA’s 

TDS MCLs before mining, nor again after restoration. With 

continued pumping and disposal these remote sites 

probably would certainly have achieved lower TDS values . 

But that would have been wasting a resource, water. 
Restored Amended Change between

Mine Baseline Value Value Baseline and

(ppm) (ppm) (ppm) Restored Value

________________________________________________________

Bruni-5-2 2282 1366 2282 -40%

Bruni-5-1 2282 1395 2282 -39%

Pawnee 903 710 900 -21%

Benavides-4 1211 1088 1211 -10%

O’Hern-2 979 890 ** -9%

Longoria-1 1928 1860 1928 -4%

Brelum-2 6349 6155 6349 -3%

Holiday-3 1442 1414 1442 -2%

Benavides-1 1211 1351 1211 0%

Brelum-1 5970 6065 5971 0%

Bruni-6 1333 *** 1333 0%

El Mesquite-1 1071 1075 1071 0%

Nell-1 5383 5372 5383 0%

Trevino-2A 1635 1628 1884 0%

Trevino-2B 1635 1627 1635 0%

Trevino-1 1577 1661 1700 +5%

McBryde-1 1580 1727 1738 +9%

Longoria-2 2013 2208 2200 +10%

Benavides-2 1663 1875 2100 +13%

Benavides-3 1356 1560 1358 +15%

El Mesquite-3 786 900 910 +15%

Hobson-1 1111 1379 1492 +24%

Total Dissolved Solids. 
Arsenic -

EPA’s current MCL is .01 mg/l. Baseline values for 

the 22 mine sites ranged from .004 to .15mg/l. 

At the time these 22 mining projects were mined 

and then restored, the EPA’s MCL was .05 mg/l. All 

were restored to below the existing MCL for the 

time. 

All but two sites were restored to less than 

baseline values.
Arsenic Restoration 

Restored EPA Drinking Restored Value

Baseline Value Water Standard* Compared to

Site mg/l mg/l mg/l EPA Standard

__________________________________________________________________

Benavides-1 0.004 0.002 0.05 25 Times Lower

Benavides-3 0.037 0.002 0.05 25.0 Times Lower

Brelum-2 0.013 0.003 0.05 16.7 Times Lower

Bruni 5-2 0.009 0.003 0.05 16.7 Times Lower

Benavides-2 0.008 0.004 0.05 12.5 Times Lower

El Mesquite-1 0.007 0.004 0.05 12.5 Times Lower

Bruni 5-1 0.009 0.005 0.05 10.0 Times Lower

McBride 0.041 0.007 0.05 7.1 Times Lower

Holiday-3 0.08 0.010 0.05 5.0 Times Lower

Nell-1 0.028 0.012 0.05 4.2 Times Lower

Pawnee-1 0.05 0.016 0.05 3.1 Times Lower

Trivino-1 0.05 0.016 0.05 3.1 Times Lower

Brelum-1 0.074 0.017 0.05 2.9 Times Lower

Longoria-2** 0.023 0.021 0.05 2.4 Times Lower

O’Hern-4 0.042 0.039 0.05 1.3 Times Lower

Longoria-1 0.023 0.025 0.05 2.0 Times Lower

El Mesquite-3 0.08 0.027 0.05 1.9 Times Lower

Trevino-2b 0.032 0.026 0.05 1.9 Times Lower

Trevino-2a 0.032 0.036 0.05 1.4 Times Lower

O’Hern-2 <0.2 0.047 0.05 ~Equal

Benavides-4 0.004 0.010 0.05 5.0 Times Lower

Hobson-1*** 0.15 0.323 0.05 6.5 Times Higher
Selenium –

EPA’s MCL is .05 mg/l. 

All were restored to significantly less than

EPA’s MCL except for one site.

Radium 226 -

All sites exceeded EPA MCL of 5 pCi/l prior to 

mining. Baseline values ranged from 10 – 430 

pCi/l.

After restoration all sites, except one, were 

restored to below baseline.. 

Uranium -

EPA current MCL is .03 mg/l. 

Of the 22 sites reviewed, 8 were restored to baseline and 

better values, 9 sites were restored to within 1 mg/l, 4 

sites were restored to within 2 mg/l, and 1 former mining 

site was restored to within 3 mg/l.

At the time these mines were mined and restored many 

years ago, the EPA had not yet established a uranium 

MCL. Instead the industry and Agreement States 

recognized the only existing National Standard; 

Wyoming’s Livestock Standard, 5 mg/l.

In conclusion the data presented by the USGS in its 2009 

study, when tabulated and sorted in matter that is more 

succinct to the statistician, becomes more obvious that 

successful restorations can be achieved, and have occurred in 

the IRS Uranium Industry.

To suggest and insist that the entire environment where ISR 

mining is conducted be returned to natural backgrounds, 

especially when those backgrounds currently don’t meet 

federal standards, is unrealistic on an ion by ion basis.

ISR mining for uranium comes exceedingly close to achieving 

that goal nonetheless. Surface land is returned for 

unrestricted use, and water quality is returned, on average, to 

less than a part per million of baseline. 

If Part 192 proposed rules were applied to other viable 

industries (manufacturing, power generation, conventional 

mining, etc.), none could or would come close in obtaining 

the degree of success that the ISR uranium industry has 

demonstrated. They would all be regulated out of business.



Uranium One Americas 

Restoration at the Willow Creek Project
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Uranium One Americas Head Office

Casper, Wyoming

U1 Americas ISR Projects

Uranium One Americas Inc is a 

wholly owned subsidiary of 

Uranium One Inc. – based in 

Wyoming, USA

ISR development properties are 

located in 4 main areas of 

Wyoming – Powder River Basin 

(PRB), Great Divide Basin 

(GDB), Wind River Basin and 

Shirley Basin

Uranium One’s Wyoming properties 

cover 7,886 mining claims, 170 

leases on 250,571 acres

M+I resources of 38.6 M lbs U3O8, 

inferred resources of 4.0 M lbs 

U3O8, historical resource 

estimates of 81.7 M lbs U3O8

Great Divide Basin

Powder River 

Basin

 Development Properties
20 WWW.URANIUM1.COM

Willow Creek Project

Johnson/Campbell Counties, Wyoming

20

TO HIGHWAY

192 (Lynch, WY)

STREETER

RANCH

STREETER

ROAD

Johnson Co.

Campbell Co.
21 WWW.URANIUM1.COM

 Willow Creek Highlights:

 500K to 1,000K lbs./yr operation

 Fully licensed CPP and IX satellite plant 

 Mine Unit 7 in operation as of January 2011

 Mine Unit 8 in operation as of January 2012

 Mine Unit 10 in operation as of January 2013

Willow Creek Project

Johnson/Campbell Counties, WY

Irigaray CPP Christensen Satellite Plant Irigaray CPP

Mine Unit 7

Header House MU7
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Irigaray Central Processing Plant
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Aquifer Restorations Completed

at Willow Creek

At the Willow Creek project alone: restoration of 5 pilot operations and 14 production units:

 1975 to1977: 5I7 R&D ammonium bicarbonate mining pilot test (3 wellfield patterns); restoration of a portion 

of the wellfield completed in1977. 

 Result: uranium <1 ppm, chloride restored to 159 ppm

 1977 to 1978: USMT (Uranium Solution Mining Technology) pilot test of calcium lixiviant and restoration.

 Result: (still looking for report) 

 1979 to 1985: Test mining of sodium bicarbonate and subsequent restoration in the E wellfield.

 Result: uranium 0.96 ppm, chloride 40.2 ppm

 1987 to1988: 5I7 R&D: testing of magnesium bicarbonate lixiviant followed by restoration of entire 5I7 

wellfield.

 Result: uranium 2.3 ppm, chloride 154 ppm

 Irigaray Production Units 1 through 9: mined 1977 through 1995; restored 1990 through 2002. All 

wells and monitor wells reclaimed in 2005 – 2007.

 Result: uranium 1.9 ppm, chloride 42.2 ppm

 Willow Creek R & D mining and restoration pilot for the Christensen Ranch site (1985 through 1989).

 Christensen Ranch Mine Units 2, 3, 4, 5 and 6 restorations 1997 through 2005 (regulatory review in progress).
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USMT Test Site

5I7 R&D Test Site

Locations of USMT and 5I7 Test Sites

Willow Creek Project
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Irigaray Mine Site

Willow Creek Project
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Irigaray Plant Water Well (IR#1) 

 Drilled in 1976, placed into operation in 1976. The well is located directly next to the Irigaray Central Processing Plant, down gradient from the 

Irigaray wellfields. The well is still in use today, 40 years later.

 Completed in the Upper Irigaray Sandstone from 200’ to 300’ below surface – the same interval as mined and restored in all of the Irigaray 

mining, restorations.

 Use of the well, and a second plant water well, has varied over the past 40 years, but combined consumptive use has ranged from a high of 50 

gallons/minute or 72,000 gallons per day, to today’s use of about 7 gallons/minute, or 9,600 gallons per day.

 Distance from the Irigaray wellfields ranges from 4,626 feet (end of Production Unit 9) to 1,062 feet from the “E” wellfield.

 Water quality data for this well is provided in the following table. Baseline could not be found, so the nearby “E” wellfield baseline is used for 

comparison purposes.

Analysis of Down Gradient Water Well

Irigaray Plant Site

IR#1

Plant Well

Cl 

(mg/L)

Conductivity

(umhos/cm)

Total Alkalinity

(mg/L)

pH

(units)

SO4

(mg/L)

Se (mg/l) U3O8 

(mg/L)

Baseline 12.1 (TDS – 435) 133.6 8.4 204 <0.01 0.081

2011 13.1 736 83.4 8.1 - - <0.4

2012 12.2 547 80.5 8.3 - - <0.4

2013 13.7 707 86.1 8.4 - - <0.4

2015 13.0 703 85.3 8.4 230 <0.1 0.07

IR 1-9 

Restoration 42.2 1081 350.0 7.9 133.6 0.028 1.98

NO impacts to down gradient water well during 40 years of monitoring 
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• Bison Basin Project - Great Divide Basin, WY

• Leuenberger pilot scale test – Converse County, WY

• North Platte pilot scale test – Converse County, WY

• Nuclear Dynamics pilot - Campbell County, WY

• Collins Draw pilot – Campbell County, WY

• Reno Creek (2 pilots) – Campbell County, WY

• Ruth pilot – Johnson County, WY

• Nine Mile pilot – Natrona County, WY

• Smith Ranch pilot – Converse County, WY

• Highland ISL pilot – Converse County, WY

• Smith Ranch/Highland A, B, C wellfields – Converse County, WY

• Willow Creek 5I7 (twice), USMT, E Wellfield, Production Units 1 through 9 at IR, Willow Creek 

pilot at Christensen Ranch, Christensen Ranch Mine Units 2, 3, 4, 5 and 6.

Data from these mining and restoration tests are available from company records and 

State of Wyoming, DEQ archives. 

Did EPA review any of this information in preparation for the proposed rule making?

Summary of Aquifer Restoration Projects in Wyoming

Project Operator State Status (2014)

Alta Mesa Mestena TX Standby/Restoration

Benavides URI, Inc. TX Restored/Released

Boots/Brown U.S. Steel TX Restored/Released

Brelum Mobil Oil TX Restored/Released

Brevard Signal Equities TX Licensed/Undeveloped

Bruni Westinghouse TX Restored/Released

Burns U.S. Steel TX Restored/Released

Christensen Ranch Uranium 1 WY Restoration/Stability

Church Rock Hydro Resources NM Licensed/Undeveloped

Clay West U.S.Steel TX Restored/Released

Crow Butte Cameco NE Operating/Restoration/Stability

Crownpoint Hydro Resources NM Licensed/Undeveloped

El Mesquite Cogema TX Restored/Released

Goliad Uranium Energy Corp TX Licensed/Undeveloped

Gruy Everest Minerals TX Undeveloped/Released

Highland Cameco WY Restoration/Stability

Hobson Everest Minerals TX Restored/Released

Hobson/Tex-1 Everest Minerals TX Restored/Released

Holiday Cogema TX Restored/Released

Irigaray Uranium 1 WY Restored/Released

Kingsville Dome URI, Inc. TX Stability

Lamprecht Inter. Energy Corp TX Restored/Released

Las Palmas Everest Minerals TX Restored/Released

Lance Strata WY Licensed/Undeveloped

Longoria URI, Inc. TX Restored/Released

Lost Creek UrEnergy WY Operating

Luenberger Teton WY Restored/Released

McBride Caithness TX Restored/Released

Mt Lucas Everest Minerals TX Restored/Released

Mosier U.S. Steel TX Restored/Released

Nell Mobil Oil TX Restored/Released

Nichols Ranch Uranerz WY Operating

North Butte Cameco WY Operating

North Platte URI, Inc. WY Restored/Released

OHern Cogema TX Restored/Released

Palangana Dome 1 Chevron TX Restored/Released

Palangana Dome 2 Uranium Energy Corp TX Operating

Pawlik U.S. Steel TX Restored/Released

Pawnee Inter. Energy Corp TX Restored/Released

Reno Creek Rocky Mt. Energy WY Restored/Released

Rosita URI , Inc. TX Standby/Released

Ruth Cameco WY Restored/Released

Section 9 Pilot Mobil Oil NM Restored/Released

Smith Ranch Cameco WY Operating/Restoration

Trevino Conoco TX Restored/Released

Unit 1 Hydro Resources NM Licensed/Undeveloped

Vasquez URI, Inc. TX Restored/Stability

West Cole Cogema TX Restored/Released

Willow Creek Uranium 1 WY Operating

Zamzow Inter. Energy Corp. TX Restored/Released

REGULATED ISR PROJECT INVENTORY
TEXAS

RESTORATION/STABILITY REPORTS AND DATA 

RESTORATION TABLE AMENDMENT ANALYSIS REPORTS (ACL)

1 UR01890-21 Burns/Mosier Restoration Report

2 UR01890-031 Burns/Mosier Restoration Report

3 UR01941-040 O’Hern Restoration Table Amendment Report

4 UR02155-021 El Mesquite Restoration Table Amendment Report

5 UR02155-031 El Mesquite Restoration Table Amendment Report

6 UR02155-041 El Mesquite Restoration Table Amendment Report

7 UR02156-011 Holiday H-1 (EXT) Restoration Table Amendment Report

8 UR02156-011 Holiday Restoration Table Amendment Report

9 UR02156-021 Restoration Table Amendment Report

10 UR02156-051 Holiday Restoration Table Amendment Report

11 UR02156-061 Holiday Restoration Table Amendment Report

12 UR02156-071 Holiday Restoration Table Amendment Report

13 UR02156-071 Holiday Restoration Table Amendment Report

14 UR02208-011 Hobson Amendment Report_ Stabilization

15 URO2381-011 Mt Lucas Restoration Table Amendment Report

16 URO2381-021 Mt Lucas Restoration Table Amendment Report

17 URO2381-031 Mt Lucas Restoration Table Amendment Report

18 URO2381-041 Mt Lucas Restoration Table Amendment Report

19 URO2381-051 Mt Lucas Restoration Table Amendment Report

20 URO2381-061 Mt Lucas Restoration Table Amendment Report

21 URO2381-071 Mt Lucas Restoration Table Amendment Report

22 URO2381-081 Mt Lucas Restoration Table Amendment Report

23 UR02407PAA011 Trevino Restoration Report 1988-07-29

24 UR02407PAA021 Trevino Restoration Report 1986-07-25

25 UR02441-011 Las Palmas Restoration Table Amendment Report & Data

26 UR02441-021 Las Palmas Restoration Table Amendment Report & Data

27 UR02441-011 Las Palmas Restoration Table Amendment Report & Data

28 UR02463-031 West Cole Restoration Table Amendment Report

29 UR02463-031 West Cole Restoration Table Amendment Report

30 UR02827-011 Kingsville Dome Restoration Justification Report

31 URO2827-021 Kingsville Dome Restoration Justification Report

32 URO2880-011 Rosita Restoration Table Amendment Reports

33 URO2880-021 Rosita RT Restoration Table Reports
TEXAS

RESTORATON CERTIFICATES WITH DATA

1 UR01941-021 OHern TCEQ Restoration Certificate

2 UR01942-051-1 Bruni TCEQ Restoration Certificate

3 UR01942-051-2 Bruni TCEQ Restoration Certificate

4 UR02050-011 Pawnee TCES Stability File

5 UR02151-011 Brelum TCEQ Restoration Certificate

6 UR02151-021 Brelum TCEQ Restoration Certificate

7 UR02155-011 El Mesquite TCEQ Restoration Certificate

8 UR02156-031 Holiday TCEQ Restoration Certificate

9 UR02156-031 Restoration Certificate

10 UR02202-011 Nell TCEQ Restoration Certificate

11 UR02208-011 Hobson TCEQ Restoration Certificate

12 UR02222-011 Longoria TCEQ Restoration Certificate

13 UR02222-021 Longoria TCEQ Restoration Certificate

14 UR02312-011 Benavides TCEQ Restoration Certificate

15 UR02312-021 Benavides TCEQ Restoration File

16 UR02312-031 Benavides TCEQ Restoration Certificate

17 UR02312-031 Benavides TCEQ Restoration File

18 UR02407-011 Trevino TCEQ Restoration Certificate

19 UR02407-021a Trevino TCEQ Restoration Certificate

20 UR02407-021b Trevino TCEQ Restoration Certificate

21 UR02420-011 McBride TCEQ Restoration Certificate
New Mexico - Mobil Section 9 Peer Reviewed Technical and Restoration Reports

1 In-Situ Leaching of Crownpoint, New Mexico, Uranium Ore: Part 1-Mineralogical Frame 

of Reference. Vogt et. al. SPE Journal

2 In-Situ Leaching of Crownpoint, New Mexico, Uranium Ore: Part 2-Laboratory Study of a 

Mild Leaching System. Vogt et. al. SPE Journal

3

In-Situ Leaching of Crownpoint, NM, Uranium Ore: Part 3-Laboratory

Study of Strong Leaching Systems: Sodium Hypochlorite. Vogt et. al. SPE Journal

4 In-Situ Leaching of Crownpoint, NM, Uranium Ore: Part 4-Laboratory Study of Strong 

Leaching Systems: Oxidant/Sulfuric Acid. Vogt et. al. SPE Journal

5

In-Situ Leaching of Crownpoint, New Mexico, Uranium Ore: Part 5-

Laboratory Study of Strong Leaching Systems: Oxidant-Heat. Vogt et. al. SPE Journal

6 In-Situ Leaching of Crownpoint, New Mexico, Uranium Ore: Part 6-Section 9 Pilot Test. 

Vogt et. al. SPE Journal

7 Annual Restoration Reports w/data to NMED - 1981, 1982, 1983, 1984, 1985, 

1986,1987, 1988. Mobil Oil Corp.

8 HRI/ Town of Crownpoint down gradient water quality data.
Wyoming - Irigaray Water Well

37 Years of Down Gradient Monitoring

Area of Review Background Data

Assessments

UIC Area Permit Applications

1 Agency validated background water quality data and hydrogeologic tests and analysis 

from Production Area Authorizations, Mine Unit Authorizations, responses to requests 

for additional information (RAIs)

2 UR02051. Union Carbide Palangana Domestic Well Sample History

3 UR02154. Re-permitting/licensing of the Boots/Brown ISPR Project. Baseline/AOR well 

resampling information.

4 UR02312 & UR02463. Background maps, water well inventory and analytical data for 

AOR wells for the West Cole Project (Benavides)

5 UR02381. Background maps, water well inventory and analytical data for AOR wells for 

the Mt Lucas Project. Baseline well turned over to landowner.

6 UR02155 & UR02156. Background maps, water well inventory and analytical data for 

AOR wells for the – El Mesquite Project

7 UR02208. Background maps, water well inventory and analytical data for AOR wells for 

the Hobson Project

8 UR02020, UR02407 & UR02914. Background maps, water well inventory and analytical 

data for AOR wells for the Trevino/Gruy/McBride Projects

23 Well Sampled Before ISR in AOR


TCEQ SPONSORED PROGRAM

• Independently Resampled Well In The 

Area of Review (AOR) of Historic ISR 

Operations

• Compare with Per ISR Background

• Determine changes in water quality two 

to three decades after ISR operations 

have closed