URANIUM PRODUCERS OF AMERICA

141 EAST PALACE AVENUE, POST OFFICE BOX 669, SANTA FE, NEW MEXICO 87504-0669

TELEPHONE (505) 982-4611; FAX (505) 988-2987; WWW.THEUPA.ORG

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 Groundwater 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 Mining 

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 recently 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 Casper, WY. We think it is important that the agency and 

industry work together to review the existing data to identify any data gaps 
Ingrid Rosencrantz

April 27, 2015

Page Two

and engage in a collaborative discussion to assess the current requirements 

and any proposed changes. 

In the meantime, we 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 association

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 for development of domestic 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 nuclear 

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 recovery 

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 

members. 
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 Colorado, 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 Reclamation 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 opportunity 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)463-2627.

Sincerely,

National Mining Association

Uranium Producers of America

Nuclear Energy Institute

Wyoming Mining Association

Colorado Mining Association

Texas Mining and Reclamation Association