# 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

- 2987; WWW.THEUPA.ORG

February 1 3 , 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 Extension of Public Comment Period on proposed “ H ealth and Environmental Standards for Uranium and Thorium Mill Tailings ( 80 Fed. Reg. 4156 )

Dear Ms

. Rosencrantz :

On Jan. 26 , the U.S. Environmental Protection Agency (EPA) proposed the above reference rule and provided a 90

- day comment period. Due to the complexity of the rule and the novel issues it raises, 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 request an extens ion of the comment period for an additional 90 days.

The associations intend to submit substantive comments on the proposed

rule but the current comment period is simply insufficient to allow adequate time to review the more than 2500 pages of supportin g materials (including one 244 page document that is not available online as part of EPA’s docket due to copyright issues). The ability to review and analyze the se supporting materials, many of which are scientific or technical in nature, is crucial to th e associations’ effort to provide meaningful comments on the proposal

. InIngrid Rosencrantz February 1 3 , 2015 Page Two

addition, industry commenters will need to assemble cost and other site specific data for use in their comments.

The National Mining Association (NMA) is a national trade associati on 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 dev elopment 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 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

esta blishing 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 U nited 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 Assoc iation (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

o perations, 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 Un ited 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.

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, urani um, and other mineralsIngrid Rosencrantz February 1 3 , 2015 Page Three

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 Reclamat ion 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 u ranium 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.

In conclusion, t he proposed changes are very complex and could significantly impact the domestic uranium recovery industry. Considering the complexity and significance of the proposal, an additional 90 day comment period is necessary so th at the public, including interested companies and industry can properly and adequately respond to the agency’s proposed changes.

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

or need additional information , please contact K atie 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 Assoc iation Texas Mining and Reclamation Association