The deadline to file written comments on the Environmental Protection Agency’s (EPA) draft permits to provide water for uranium mining and deep waste disposal wells in the southwestern Black Hills is now Wednesday, Dec. 11, 2019 at 9:59 PM MST. This is the Dewey-Burdock project proposed by Powertech/Azarga Uranium. And it’s very important that a lot of people send comments by mail or online.
The public comment period has been extended to Dec 11, 2019 11:59 PM ET or 9:59 PM Mountain Time.
Or mail your comment to be post-marked before/or on Dec. 11th to:
Ms. Valois Robinson
U.S. EPA Region 8
Mail Code: 8WD-SDU
1595 Wynkoop St.
Denver, CO. 80202-1129
Your comments can be short (“Stop uranium mining and waste disposal wells in the Black Hills”) or you can use some of the comment ideas provided here.
When you write your comments, it’s a good idea to start by saying who you are and why you care. (“I live in the Black Hills and worry about the future of our limited water supplies.” Or “My family has gone to the Black Hills to pray for generations, and mining would disrupt that.” Or whatever is honestly about you.)
Then give your comments on the EPA’s plans for water use at the proposed uranium project. Here are some ideas drawn from the hundreds of pages of EPA materials. Do not copy them all – pick a few and focus on them:
The EPA suggests removing the requirement that Powertech begin construction within one year of getting its permit(s). The requirement should be kept in place – the company should not be allowed to have permits forever by filing a simple report once a year.
Draft permits should not have been issued until meaningful Tribal consultation was completed. The EPA has jumped the gun, and now the damage has been done, as the results of Tribal consultation were not included in the draft permits. This means the public cannot consider and comment on the issues raised by the Tribes as part of the review process.
The climate change discussion in the EPA’s documents ignores the greenhouse gases emitted by most of the uranium enrichment process. These emissions are substantial and should be identified and discussed in detail as part of the cumulative impacts of this project.
The EPA has made a critical and unwelcome change in its documents since 2017. This is to remove all down-gradient compliance boundary wells and post-restoration monitoring from this project. In other words, there would be no physical monitoring using water measurements along the critical edges of the site. Instead, the EPA proposes to use a mathematical model to determine what the contaminated water is doing underground. This would be ridiculous, if the likely impacts weren’t so serious. A model is not adequate protection — especially in a complex geological area like the Dewey-Burdock site that is bordered by domestic and livestock wells that are in use. Both nature and human interactions with nature are dynamic and complex, unlike models.
The EPA suggests allowing Powertech to take a sample of the Minnelusa Aquifer to see if it is appropriate for drinking water after giving the company its permit to inject mining wastes into the aquifer. Water testing of the Minnelusa Aquifer must be done before any permit is issued. The EPA, not Powertech, must select testing sites, take samples, and insure that they are tested properly.
In its revised draft permits, the EPA acknowledges that the Lakota and other indigenous nations have important cultural, spiritual, and legal ties to the Black Hills. But then the EPA says it won’t consider these issues in making its decisions. This is a clear violation of the requirement that these types of issues must be considered during the permitting process.
No permits should be issued until the 7500 + old boreholes on the Dewey-Burdock property have been identified and properly plugged. If the boreholes are not plugged, mining fluids will not be contained, and radioactive and toxic contamination is likely.
In addition to the Dewey-Burdock project, Powertech has about the same number of claims on the Wyoming side of the state line at its Dewey Terrace uranium project. The EPA’s cumulative impacts discussion does not include the Dewey Terrace project. This must be corrected, and the cumulative impacts of two neighboring uranium projects – especially on water — must be fully considered.
The current plan to identify and protect cultural resources is totally inadequate. It allows unqualified Powertech employees to self-monitor and determine the locations of cultural sites when they think they encounter one using heavy equipment. This creates a situation in which cultural resources are very likely to be destroyed. A thorough, tribally-designed process for cultural resources identification and protection should be undertaken and completed before any permit is issued or any earth is moved.
Floods are becoming more destructive in our area with climate change. Using a past “100-year flood” as the guide for protecting landscapes, radioactive settling ponds, and mining structures in the future is not adequate. Additional protections must be put in place.
You do not have to stick to these comments. In fact, it’s a good idea to add your own thoughts. So feel free to add your own information and thoughts in your comments. And thanks for taking the time to send in your comments by Monday, December 9.
Important notice: The public comment period has been extended to Dec 11, 2019 11:59 PM ET.