U.S Nuclear Regulatory Commission (NRC) - Ablation Technology Meeting December 19 2013

E-mail from Sarah Fields Re NRC Dec. 19 Meeting with Mineral Ablation: Applicable Guidance.  

Copy of Email sent on Monday 12/16/2013 to the NRC

 

Black Range Minerals Acquires Shootaring Uranium Mill From UraniumOne

Published on Tuesday November 12 2013 (AEST) 

 

Permitted to process up to 750 tonnes of ore Per Day.

Capacity to process 1000 tonnes Per Day.

Black Range Minerals has agreed to buy the mothballed Shootaring Canyon uranium mill in Utah from Uranium One for $10 million.

The acquisition includes surface stockpiles of uranium ore, with a historic mineral resource estimate of some 250,000 pounds U3O8 (97 tU) at a grade of 0.13% U3O8. Black Range has also agreed to acquire Uranium One's other "conventional mining assets" within the USA, the most advanced being the previously mined Velvet-Wood deposit in Utah with remaining NI43-101 estimated resources of 5.3 million pounds of U3O8 (2039 tU).

 

Black Range already owns the Hansen/Taylor Ranch uranium project in Colorado. The company says that the cost of acquiring, refurbishing and restarting the Shootaring Canyon mill is expected to be "significantly less" than building a new processing facility at Hansen, and should enable it to fast-track the development of its Colorado project while avoiding costs from toll-milling at a third-party mill.

The company is expected to customise the mill so it can preferentially receive high-grade concentrates from multiple projects across the USA.

The purchase was described by Black Range as being "transformational," noting that "ownership of the Shootaring Mill, one of only three licenced mills in the USA, assures control of production all the way from mining to finished yellowcake."

The Shootaring Canyon mill, located approximately 77 kilometers south of Hanksville, Utah, is permitted to process up to 750 tonnes of ore per day, but has a capacity to process 1000 tonnes per day. The mill - the last conventional uranium mill to be built in the USA - was commissioned and operated for just four months in 1982, before being mothballed due to declining uranium prices. Black Range estimates it would take about 18 months to acquire the necessary permits to bring the mill back into action.

Uranium One acquired the Shootaring Canyon mill from US Energy Corp in April 2007.
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http://www.agapito.com/2010/04/velvet-mine-ventilation-analyses%E2%80%94moab-ut/___________________________________________________________

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Australian-World Uranium-News Updates

Black Range Minerals Water Monitoring & Water Rights Within Hansen Uranium Deposit Colorado

I just want to nip the current untruths in recent media reports from the TAC, whereby this organization are suggesting that no Water monitoring procedures has taken place within the confides of the Hansen Deposit I can confide this is 100% not correct, as no doubt all current researched BLR holders would or should already know !

 Monitoring wells with Hansen  

An orange case covers a monitoring well installed downstream from the Hansen uranium deposit to keep tabs on minerals in groundwater. Black Range Minerals installed numerous monitoring wells after acquiring the privately owned mineral rights to the Hansen and other nearby uranium deposits. 

Black Range Minerals are at this very moment in the process of installation of five new water monitoring wells immediately adjacent to the Project’s 39.4 million pound Hansen Uranium Deposit 

Pdf Link
ASX Release 2 October 2013DRILLING PROGRAM COMMENCES AT THE HANSEN URANIUM DEPOSIT 

 Baseline environmental data will be collected from all of these new wells and integrated with, and be complementary to, data from the Company's ongoing surface and ground-water monitoring programs 

In My Opinion Only*Word of caution is don't believe all the content that these Environmental activists circulate.. 



 Water Rights

“The North Spring Ditch water rights were changed in 1980, rendering any irrigation use since that date unusable for calculating historic consumptive use for a subsequent change of use.” Court documents show that the 1980 change of use involved the transfer of irrigation water rights from Taylor Ranch to Cyprus Mine, which changed the use of that water to mining. Alter said Cyprus Mines sold those water rights back to the Taylors in 1993, and in 2012 the Taylors filed a case in Division 2 Water Court, to “confirm” their rights.

Alter said TAC members believe the Taylors filed the case to determine how much water they can sell to Black Range Minerals for proposed mining operations, prompting TAC to enter the case as an objector.
Given: (1) the significance of historical consumptive use in determining the amount of water Black Range could acquire and
 
(2) the SWSP ruling rendering “irrigation use since (1980) unusable for calculating historic consumptive use,” Alter said he believes Black Range has insufficient water for mining for underground borehole mining. He cited estimates that the mining process could require as much as 50,000 gallons of water per hour.

http://coyotegulch.wordpress.com/2013/06/08/fremont-county-tallahassee-area-residents-are-now-1000-strong-in-opposition-to-black-ranges-uranium-operation/

Black Range Minerals Management & Project Team

Over the past 7+ Years, Black Range Minerals have compiled one of the better qualified Uranium Project teams, that a speculative Uranium Explorer could endeavor to put together, and all in the good ole USA ! 

No High Risk African Connection ! 

Mike Haynes – Managing Director/CEO  
ex BHP Minerals Limited 

Ian Cunningham – Company Secretary  
ex Adamus Resources Limited 

Rod Grebb – VP Government and Regulatory Affairs  
ex 30 years experience in mine permitting with Tetra-Tech Inc and SRK in a senior consulting capacity specialising in mine permitting and regulatory matters for their clients. 

George Glasier – Consultant  
ex President and CEO of Energy Fuels Inc (TSX:EFR). During his time at Energy Fuels, George was responsible for building the company from scratch and leading the application process for licensing of the Pinon Ridge uranium mill planned for construction (still pending) in Colorado. Mr Glasier has over 40 years experience in the uranium industry in the USA, with extensive experience in sales and marketing, project development, and in permitting of uranium processing facilities.IMO: there's little doubt George Glasier will be the instrumental force in attaining Production at the Shootaring Uranium Mill to which BLR has recently attained rights to acquiring early 2014.  

Alexander Molyneux 
ex Chief Executive Officer &founder of SouthGobi Resources, until taken over by Rio Tinto.Also ex Managing Director, Head of Metals &Mining Investment Banking, Asia Pacific, with Citigroup. Has spent approximately 12 years providing advice and investment-banking services to mining, metals and industrial corporations.Currently Executive Chairman Celsius Coal Limited (ASX:CLA)Director International Resources Group (private)Chairman, Azarga Resources Limited (private)Director, Ivanhoe Energy Inc (TSX:IE, NASDAQ:IVAN)  

Ben Vallerine 
Serves as its Exploration Manager of USA. Mr. Vallerine has been leading Black Range Minerals' exploration and development activities for over 4 years. During this period he has developed an in depth understanding of its operations.Involved in a numerous resource projects, predominantly in Australia, Canada and the USA. He has worked for both junior and major mining companies, including Harmony Gold Mining Company Limited and Rio Tinto Limited 

Leon Pretorius Top 20 Holder 
And to top it all off we have ex Paladins Chief Geologist sitting on BLR's Top 20 Holders at #5 with 26.4 Million Shares. 

  

For the record As an Executive Director of Paladin Resources (now Paladin Energy), Dr Pretorius led Paladin through a growth phase that saw the stock price rise from less than $0.01 per share to more than $1.10 when he resigned in May 2005. He remains a Director of Paladin’s operating Company, Langer Heinrich Uranium in Namibia. 

 http://www.blackrangeminerals.com/content/corporate-governance/management/

AGREEMENT EXECUTED COVERING OCTOBER URANIUM ORE STOCKPILE

Agreement Covering the October Uranium Ore Stockpile

The  Company  is  very  pleased  to  advise  that  it  has  entered  into  a  definitive  development  agreement covering  the  “October”  uranium  surface  ore  stockpile  in  western  Colorado,  with  unlisted  company Nuvemco  LLC  (“Nuvemco”),  which  holds  extensive  mineral  rights  over  uranium  properties  in  Colorado,  USA (the “October Agreement”).

The  October  stockpile  comprises  circa  10,000  tons  of  uranium  ore  that  was  mined prior to 1972  but never transported  to  a  processing  facility.  Previous  production  from  the  October  underground mines  comprised  more  than  50,000  tons  at average  grades  of  0.31%  U3O8  and  0.91%  V 2O5. 

The  average  grade  of  the October stockpile is  yet to be determined, but  is  expected  to  be  in  the  range  of 0.075% to 0.25% U3O8. Nuvemco LLC holds approved permits that allow for the removal of the entire October ore stockpile.

Extensive  Ablation  testwork  has  been undertaken  on  samples  from  the  October stockpile  during  the  past  few  months. These  samples  averaged  0.13%  U3O8  and 0.25% V2O5, however these grades may not be representative of the entire stockpile.

Importantly,  recoveries of  >90%  of  both  the  uranium  and  vanadium  into  a  fine-grained  “high-grade  ore”product were achieved with Ablation. Equally importantly, virtually all of the uranium  was removed  leaving a  coarse-grained,  “clean  sand”  product  after  Ablation.  Hence  it  is  anticipated  that  a  very  benign  coarsegrained product will result following remediation of the ore stockpile with Ablation.

The Ablation Uranium Recovery Process

Published on Wednesday November 06 2013 (AEST)

NRC (U.S Nuclear Regulatory Commission) response, to Lee J Alter Chairman, of Tallahassee Area Community, Inc. In regards to his letter.

SUBJECT: 
TAC INQUIRY REGARDING UNDERGROUND BORE HOLE MINING AND ABLATION TECHNOLOGIES FOR URANIUM RECOVERY


Dear Mr. Alter:

The U.S. Nuclear Regulatory Commission (NRC) is in receipt of your letter dated July 12, 2012, addressed to Bill Von Till and myself, regarding your concerns about the emerging technologies in uranium recovery including ablation technologies in the State of Colorado. 

After reviewing the issues related to Underground Bore Hole Mining - (UBHM) and Impact Ablation, the NRC staff determined that the Colorado Department of Public Health and the Environment (CDPHE) is the regulatory authority with jurisdiction on these matters within the State of Colorado.

It is our understanding that although there have not yet been any applications submitted to CDPHE for licenses or permits requesting use of this technology in the State of Colorado;there are companies in Colorado investigating the possibility of doing so in the near future. The NRC will defer to the CDPHE to communicate with their potential licensees in this area to better understand the process that will be utilized in implementing this new technology. CDPHE may request technical assistance from the NRC to address this new technology for uranium recovery.

Until then, the NRC will continue to monitor the state of the technology in order to consider what regulatory changes will be necessary should companies request NRC authority to utilize such technology for uranium recovery.

If you have any further questions or concerns regarding ablation technologies and their implementation in the State of Colorado, we suggest that you direct them to Steve Tarlton, Program Manager, at (303) 692-3423 or steve.tarlton@state.co.us.___________________________________________________




Extract from letter NRC response


  



This is indeed excellent news for BLR, as it clearly stipulates to TAC, that due to Colorado being a self regulating "Agreement State" due to agreement between Colorado’s Governor and the United States Nuclear Regulatory Commission, that dictates that the Colorado Department of Public Health and Environment (CDPHE ) is the sole regulator of radioactive material within Colorado through its Radiation Management Unit.
 
Colorado Department of Public Health and the Environment (CDPHE) has already from what I can attain, associates no link between BHM &Ablation within Milling jurisdiction.

Within the CDPHE guidelines that are currently in place both BHM &Ablation will be jointly classified as a Mining process, as no grinding or chemical processing will take place within the Mine site.


Milling can be clearly defined to where Ore is crushed and then leached with a leaching agent, usually sulfuric acid or an alkaline leaching product. Ideally, the Mill is located near the mine to reduce transportation costs. The final product is referred to as "yellow cake," which consists of U3O8 and impurities.


As we all know the ablated ore will under no circumstances, be classified as " Yellow Cake " therefore Milling has not yet taken place. 

 
PDF LINK
LIST OF AGREEMENT STATES
As at January 2012

"Agreement States" are those states that have signed a formal agreement with the U.S. Nuclear Regulatory Commission (NRC) pursuant to Section 274 of the Atomic Energy Act.

Under this agreement the NRC has relinquished regulatory control over certain by-product, source and special nuclear material uses in the state.

NRC periodically assesses the compatibility and adequacy of the state's program for consistency with the national materials program for Atomic Energy Act radioactive material. List of current agreement states and their date of agreement are .............. Click to access :)

 

U.S Nuclear Regulatory Commission Re Ablation Uranium Recovery Technology

Here's a recent 2012 letter sent by TAC to the U.S. Nuclear Regulatory Commission Washington.

It's now apparent that TAC are attempting to imply that ablation is a milling activity & therefore will be subject to a Radioactive Materials License.


Looks like there is no end to TAC's fear mongering against Uranium Mining within Fremont.





July 12, 2012

U.S Nuclear Regulatory Commission Washington, D.C. 20555-0001
Attention: Mr. Duncan White, Branch Chief, Agreement State Programs;
Division of Materials Safety and State Agreements
Mr. Randolph (Bill) Von Till, Branch Chief, Uranium Recovery ;
Division of Waste Management and Environmental Protection

Federal and State Materials and Environmental Management Programs

Via email attachment (Duncan.White@nrc.gov; RWV@nrc.gov)




Dear Mr. White and Mr. Von Till:

This letter is related to the reference to Emerging Technologies in Uranium Recovery at the recent April 17, 2012 IMPEP review meeting with the Radiation Management Unit of the Colorado Department of Public Health and Environment (CDPHE). Black Range Minerals, Ltd. (ASX:BLR) has made numerous recent announcements regarding their expected utilization of both Underground Bore Hole Mining (UBHM) and Ablation technologies for uranium recovery at their Hansen/Taylor Ranch Uranium Project. Please see: www.blackrangeminerals.com, Investor Relations, ASX Announcements.

The Tallahassee Area Community, Inc. (TAC) is a Colorado not-for-profit organization consisting of residents and property owners in the Tallahassee area of northwest Fremont County, Colorado who are concerned about the potential adverse human health and environmental impacts of large scale uranium exploitation in the immediate vicinity. Please see: www.taccolorado.com.

Both UBHM and Ablation for uranium recovery are acknowledged experimental technologies. To the best of our knowledge, neither have ever been used commercially nor have been specifically considered in NRC or Agreement State regulations or guidance.

TAC believes that their regulatory status is unclear and that there appears to be a conflict between NRC and Colorado definitions and possible interpretations with respect to the question of whether either or both of these technologies should require the issuance of Colorado Radioactive Materials Licenses.




A/ Underground Bore Hole Mining

1. Black Range, and its consultant Kinley Exploration, LLC, describes the process as the injection of high pressure water, without added chemicals, into large bore holes drilled to the depth of the targeted uranium ore body which then, by use of an "under reamer", excavates a "cavern" by fragmenting the uranium containing rock and returning those fragments to the surface as a water slurry. http://www.blackrangeminerals.com/content/wpcontent/uploads/2012/05/New/BlackRangeSelectsDevelopmentApproachForHansenDeposit26Apr12.pdf

2. The company has not disclosed many details about the process ,however, TAC research has revealed that up to 50,000 gallons per hour of water pressurized to 1000 - 1500 psi or greater would be required to fragment the sandstone-embedded uranium ore body.
3. The water recovered from the slurry would be reused -- supplemented with make-up water, re pressurized and re injected into the bore hole -- until the cavern is exhausted of the targeted material.

4. It is, at present, unknown what concentration of atmospheric oxygen would be dissolved in the water injected into the bore hole. It would surely be greater than for water at standard temperature and pressure conditions. Oxidation of insoluble uranium oxide to the soluble state, depending on the pH and other conditions in the cavern, would be enhanced. It is expected that as the water is reused, the concentration of uranium, other radioactive constituents , and heavy metals would increase.

5. Some portion of this high pressure water would inevitably be forced out of the cavern into the surrounding sandstone aquifer and threaten the quality of the groundwater and local domestic water wells. Ultimately, the remaining water would be impounded on the surface and presumably left to evaporate away.


6. While UBHM poses many of the same environmental issues as does In-Situ Leach Uranium Recovery, it does not meet the current definition since only the fragmented ore pieces are processed for its uranium content; the "leachate" is not processed for recovery of uranium but rather would be treated as waste.


7. The Colorado Hard Rock Mining Rules distinguish between In-Situ Leach Uranium Mining, which it regulates concurrently with CDPHE, and In-Situ Mining. However, the point at which uranium mining ends and uranium processing begins appears to be defined by conflicting definitions of CDPHE and NRC. The difference is: precisely when does "ore" becomes "source material". CDPHE regulations specify that uranium ore prior to chemical processing is not source material but rather the product of mining. The NRC Office of General Counsel has ruled to the contrary.


8. OGC has said that the line between "mining" and "processing" is drawn at the point of "unrefined and unprocessed ore" in its "natural form" and when "its gross appearance...has not been altered from the point of mining". http://www.nrc.gov/about-nrc/radiation/protects-you/hppos/hppos184.html.


TAC believes that it is reasonable and prudent, in view of health & safety and environmental considerations of the UBHM technique, that the fragmenting of ore in the underground cavern be considered as a uranium processing activity requiring (in Colorado) a Radioactive Material License.




B/ Ablation


1. The name of the technology should properly be "Impact Ablation" to distinguish this uranium concentration process from Laser Ablation, which is used to identify minerals and in other applications.


2. Black Range and Ablation Technologies, LLC, its consultant and recently announced Joint Venture partner, describes the process as follows: " In ablation, the slurry from UBHM is ejected from two opposing injection nozzles to create a high energy impact zone. This high energy impact separates the mineralized patina of uranium from the underlying grain. The uranium bearing particles are found in the fine fractions separated in a subsequent screening process. As tested on material from Hansen, ablation allows approximately 90% of barren material to be separated from mineralized material prior to milling, greatly reducing the total OPEX and CAPEX costs to process mineralized material. The final product is an “ablated concentrate” which consists of approximately 10% of the original mineralized material, which will be processed with conventional milling techniques." http://www.blackrangeminerals.com/content/wp-content/uploads/2012/07/07-06-2012-BLR-Secures-Rights-to-Ablation-Technology.pdf. (Emphasis added).


3. Clearly, the company does not consider that this process is "milling" and subject to licensing by CDPHE. It appears to be relying on the Colorado Radiation Control Regulations definition of "ore" as a product of mining and before it becomes "source material". ""Ore" means naturally occurring uranium-bearing, thorium-bearing, or radium-bearing material in its natural form, to be processed for its uranium or thorium content, prior to chemical processing including but not limited to roasting, beneficiating, or refining, and specifically includes material that has been physically processed, such as by crushing, grinding, screening, or sorting." 6 CCR 1007-1 Part 1.2 Definitions. (Emphasis included in the recent PowerPoint presentation by the Black Range Vice President of Regulatory Affairs to the National Mining Association in Denver). http://www.nma.org/pdf/urw_2012/grebb.pdf


4. Regardless of the determined status of the UBHM fragmented ore in the cavern, the material undergoing impact ablation is being subjected to source material processing and the resultant waste, both the "barren" rock and process water, is 11e.(2) byproduct material. The high energy impact which separates the uranium grains from the "barren" rock is the functional equivalent of crushing or grinding. The grains are then separated and sized by a screening and elutriation process to isolate the "ablated concentrate" which is then transported off-site to a conventional mill for final processing into yellowcake.


5. As stated in 40 CFR 261.4(b)(7) the beneficiation of ore (including uranium ore) includes every one of those steps. The fact that they would be done at other than a conventional mill does not change the fact that impact ablation is a milling activity subject to a Radioactive Materials License.


6. In the 2002 Office of General Counsel document entitled Uranium Milling Activities at Sequoyah Fuels Corporation , the question of "What Constitutes Uranium Milling" was considered: "A fundamental, plain-language, working definition of uranium milling can be constructed from the somewhat circular references contained in the ... regulatory definitions (in 10 CFR 40.4, of uranium milling, byproduct material and source material): Uranium milling is an activity or series of processes that extracts or concentrates uranium or thorium from any ore primarily for its source material content, and the resulting tailings or waste are 11e.(2) byproduct material." http//www.nrc.gov/reading-rm/doc-collections/commission/secys/2002/secy2002-0095/attachment5.pdf.


7. The OGC document further discussed non-conventional milling and milling at multiple locations. It stated: " Non-conventional processing ... comprise other technologies.... The distinction among non-conventional milling activities is that these activities often occur at locations other than a uranium mill.... Uranium milling entails many processing steps , which ... are not required to occur at a single location, but often do."
We respectfully request that you consider the regulatory status of both UBHM and Impact Ablation uranium recovery technologies as promptly as possible since Black Range is expected to finalize their intentions for the Hansen/Taylor Ranch Uranium Project by the end of 2012.



Respectfully submitted,

Lee J Alter Chairman, Government Affairs Committee
Tallahassee Area Community, Inc.
0489 Fremont County Road 21A
Cañon City, Colorado 81212
719.276.0864
AlterConsult@Starband.net



Thank you for your attention. I look forward to your response.