# U RANIUM 

# P RODUCERS OF 

# A MERICA

141 E AST P ALACE A VENUE, P OST O FFICE B OX 669, S ANTA F E, N EW M EXICO 87504

- 0669

T ELEPHONE (505) 982

- 4611 ; F AX (505) 988

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April 27 , 2015

Ingrid Rosencrantz

Office of Radiation and Indoor Air

Radiation Protection Division

Mailcode 6608T US Environmental Protection Agency 1200 Pennsylvania Avenue NW Washington, DC 20460

Re: Request for EPA/Industry Meeting Regarding Ground water Data from In

Situ Uranium Recovery Facilities

Dear Ms

. Rosencrantz :

On Jan. 26 , the U.S. Environmental Protection Agency (EPA) proposed a rule regarding “Health and Environmental Standards for Uranium and Thorium Mill Tailings. ( 80 Fed. Reg. 4156 ) . The comment period for the proposed rule was recently extended until May 27, 2015. The industry, including the National Mining Association, the Uranium Producers of America, the Nuclear Energy Institute, the Wyoming Mining Association, the Colorado Mi ning Association and the Texas Mining and Reclamation Association would like the opportunity to use this extra time to meet with the agency to discuss groundwater monitoring and restoration data that is relevant to the rulemaking. Much of this data was re cently made more publicly accessible due to state agency efforts to digitize the information.

Industry representatives from the abovementioned associations request such a meeting be held in conjunction with the upcoming May 13

- 14

, Part 192 hearing in Cas per, WY. We think it is important that the agency and industry work together to review the existing data to identify any data gapsIngrid Rosencrantz April 27 , 2015 Page Two

and engage in a collaborative discussion to assess the current requirements and any proposed changes

.

In the meantime, w e believe it would be appropriate for EPA to either extend the comment period for an additional 60 days or put the rule on temporary hiatus to allow these important collaborative discussions.

The National Mining Association (NMA) is a national trade asso ciation representing the producers of most of America’s coal, metals including

uranium, industrial and agricultural minerals. NMA’s members include producers of domestic uranium as well as companies that have exploration projects or pending applications fo r development of domes tic uranium mining projects.

The Uranium Producers of America (UPA) is a trade association consisting of domestic uranium mining and conversion companies whose mission is to promote the viability of the front end of the nation’s nuc lear fuel industry. UPA members are conducting uranium exploration, development and mining operations in Arizona, Colorado, Nebraska, New Mexico, South Dakota, Texas, Utah and Wyoming.

The Nuclear Energy Institute (NEI) is the organization responsible for establishing unified industry policy on matters affecting the nuclear energy industry, including the regulatory aspects of generic operational and technical issues. NEI's members include all entities licensed to operate commercial nuclear power plants in the United States, nuclear plant designers, major architect/engineering firms, fuel cycle facilities, uranium mining operations, nuclear materials licensees, and other organizations and entities involved in the nuclear energy industry.

The Wyoming Mining Association (WMA) is an industry association representing mining companies, contractors, vendors, suppliers and consultants in the State of Wyoming. Among its mining industry members are uranium recovery licensees, including four (4) in

- situ uranium recov ery operations, one (1) conventional uranium recovery operation (on standby), and several companies planning new uranium recovery operations. Wyoming uranium production in 2013 was 2,600,000 pounds (Wyoming State Geological Survey), accounting for 56% of United States production. Wyoming contributes the largest share of any state to the total production of uranium in the United States. As such, the issues raised in this rulemaking are of special concern to the WMA and its uranium recovery industry

mem bers.Ingrid Rosencrantz April 27 , 2015 Page Three

The Colorado Mining Association (CMA) is an industry association, founded in 1876 and incorporated in 1897, whose more than 1,000 members include individuals and organizations engaged in the exploration, development and production of coal, metals, uranium, and other minerals throughout Color ado, the west, and the world. CMA’s membership also includes members providing equipment, materials, support and services to the industry. Colorado has significant uranium reserves.

The Texas Mining and Re clamation Association (TMRA) is a non

- profit trade association representing over one hundred fifty (150) members and companies actively involved in the mining of numerous materials, including

uranium, coal and industrial minerals. As the collective “voice ” of uranium mining in Texas, TMRA supports regulatory decisions that are made after careful discussion and input is received from all affected or potentially affected parties consistent with applicable laws and regulations and with open and full opportuni ty for public input.

Thank you for your consideration of this request. If you have any questions

or need additional information , please contact Katie Sweeney, NMA General

Counsel at ksweeney@nma.org or (202)463

- 262 7

.

Sincerely,

National Mining Association

Uranium Producers of America Nuclear Energy Institute Wyoming Mining Association Colorado Mining Association Texas Mining and Reclamation Association