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

February 13, 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 “Health 

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 extension 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 supporting 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 these supporting 

materials, many of which are scientific or technical in nature, is crucial to the 

associations’ effort to provide meaningful comments on the proposal. In 
Ingrid Rosencrantz

February 13, 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 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.

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 
Ingrid Rosencrantz

February 13, 2015

Page Three

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.

In conclusion, the 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 that 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 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