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NRC:  "Draft EIS for IS Uranium Recovery and Alternatives"
NRC Map of Dewey Burdock Uranium Mine Proposal; color added
While the property clearly abuts on the Black Hills National Park, according to the NRC’s EIS for Powertech’s proposed Dewey Burdock uranium mine: “97 ha [240 ac] of surface rights are owned by the U.S. Government and administered by BLM“. This is almost the exact amount cited as “require vegetative removal, will affect approximately 98 ha [243 ac].” This, along with the following map, suggests that a portion of National Park surface may be lopped off by this project, with the idea that no one will miss it https://miningawareness.wordpress.com/2014/08/17/powertech-pennystocks-propensity-to-withhold-information-re-uranium-mine-property/ While 97 ha (240 acres) sounds small compared to the “total land area of the proposed Dewey- 36 Burdock Project is 4,282 ha [10,580 ac]“, 240 acres is still huge. While this post is about excursion leaks, there appears a prospective public land-park “excursion”, by Powertech, going on here! What about this waste water application to land? Isn’t it illegal under US EPA rules? How radioactive will it be?

Excursion appears a euphemism for a leak within the ground during ISL uranium mining, euphemistically termed “recovery.” According to the NRC: “This unintended spread, either horizontally or vertically, of recovery solutions beyond the production zone is known as an excursion. An excursion can be caused by:
Improper water balance between injection and recovery rates
Undetected high permeability strata or geologic faults
Improperly abandoned exploration drill holes
Discontinuity within the confining layers

Poor well integrity, such as a cracked well casing or leaking joints between casing sections
Hydrofracturing of the ore zone or surrounding units
” (US NRC: “Generic Environmental Impact Statement for In-Situ Leach Uranium Milling Facilities“). Almost all of these are concerns of those opposing the uranium mining and/or common sense.

Good news is that the NRC judges just ruled that Powertech must turn over recently acquired hydrogeological data, as per the NRC judges’ previous order. However, it sounds like it may not be publicly available, which is bizarre since the original source appears to be the US government owned TVA (Tennessee Valley Authority).

One thing we’ve also wondered upon examining various geological documents for the region: “If faults and joints are so pervasive and ubiquitous in this region, why is Dewey-Burdock viewed as an exception?” From LaGarry testimony, July 14, 2014 (see below)
LaGarry to NRC July 2014 p. 1
LaGarry to NRC July 2014 p. 2
LaGarry to NRC July 2014 p. 3
LaGarry to NRC July 2014 p. 4 http://pbadupws.nrc.gov/docs/ML1419/ML14197A376.pdf (Emphasis added) http://www.wise-uranium.org/umopusa.html

Is the Powertech-Dewey-Burdock project mostly based on the old US government uranium mining documents from the 1950s, now available online? Geological survey instruments have improved greatly since then.
NRC:  "Generic EIS for ISL Uranium Milling Facilities, Chapter 2, Final Report" Manifold inside well field header house ISL facility
NRC:  "Generic EIS for ISL , Chapter 2, " Well Heads and Header House
From NRC: “Generic Environmental Impact Statement for In-Situ Leach Uranium Milling Facilities, Chapters 1 through 4, Final Report
What are those things in the pictures? Are there biosentinels for ISL uranium mines? Sure looks like it. These seem to be Pronghorn, American “antelope”.
Pronghorn American "Antelope" USDA
Pronghorn American Antelope, Photo by Jack Dykinga-USDA (ARS, K3912-1) http://en.wikipedia.org/wiki/Pronghorn
They occur at the Dewey Burdock site too, along with potential deer sentinels:
Big game species that occur in the proposed project area include pronghorn antelope, mule deer, white-tailed deer, and elk.” US NRC, Draft, “Environmental Impact Statement for the Dewey-Burdock Project in Custer and Fall River Counties, South Dakota“. (Picture colored, except well head covers which are and which remain white. This and top picture were colored to enhance contrast for clarity. Also because Pronghorn are not gray.)

Throwing the National Bird Under the Radioactive Bus!
Bald Eagel Whitmore, UFWS
Of state-listed species, the bald eagle is known to occur on and in the vicinity of the site and two bald eagle nests were observed during wildlife inventories conducted at the site (Powertech, 2009a; SDGFP, 2012c). As described in SEIS Section 3.6.3, the first bald eagle nest was observed in 2008 and 2009 approximately 1.6 km [1 mi] west of the proposed Dewey satellite processing plant in a cottonwood tree along Beaver Creek. A second bald eagle nest was observed approximately 1.2 km [0.75 mi] southeast of the first bald eagle nest along Beaver Creek.” US NRC, Draft, “Environmental Impact Statement for the Dewey-Burdock Project in Custer and Fall River Counties, South Dakota

Here’s the nearby Crow Butte Nebraska Mine owned by Cameco and whose extension seems to still be contested. You can see the well heads, house, as well as the edge of the huge evaporation ponds for radioactive waste water. Then they haul away the radioactive sludge to be someone else’s problem and/or inject it into the ground.
Crow Butte NE well heads, house and evaporation ponds

These are some of Dr. LaGarry’s comments regarding the Crow Butte ISL mine. Notice that he speaks of the long tectonic activity of the Black Hills. Looking at the NRC’s EIS, the tectonic activity seems to continue in the region of the Black Hills – Dewey Burdock. The Dewey Burdock Powertech property is adjacent to the Black Hills, whereas the Crow Butte property is much further south:
Secondary porosity, in the form of intersecting faults and joints, is common in northwestern Nebraska, especially along the Pine Ridge Escarpment (see Swinehart & others 1985). These faults and joints are generally oriented NW-SE and SW-NE, and are most likely a result of the uplift of the Black Hills of southwestern South Dakota. The Black Hills have been tectonically active since the late Eocene (Evans & Terry 1994), and continued to fault, fracture, and fold the rocks of northwestern Nebraska and southwestern South Dakota into the middle Miocene (Fielding & others 2007). These faults and fractures transect all major bedrock units listed above. These faults could potentially connect the uranium-bearing Chamberlain Pass Formation to modern river alluvium, and connect the uranium-bearing Chamberlain Pass Formation to the overlying secondary porosity of the Brule Formation.

CONTAMINANT PATHWAYS

There are two principal pathways through which contaminated water could migrate away from Crow Butte Resources well fields and into adjacent areas: 1) along the White River alluvium (modern river alluvium); and 2) along faults. The White River alluvium can receive contaminants from three sources: a) from surface spills at the Crow Butte mine site; b) from waters transmitted through the Chamberlain Pass Formation where it is exposed at the land surface; and c) through faults. Contaminants within the White River can be transmitted into the areas where the alluvium intersects faults downstream from Crawford. Once into the White River alluvium, every rain event will push the contaminants a little bit downstream. In the case of the White River, downstream is to the N-NE and directly onto the Pine Ridge Reservation. Residential users, agricultural users, wildlife, and the City of Crawford all receive water supplies from the White River alluvium.

The second pathway is through faults. These faults can receive contaminants from three sources: a) from surface spills into the White River alluvium; b) from waters transmitted through the Chamberlain Pass Formation; and c) from underground excursions, which can of either lixiviant or uranium-laden water. Once into the faults, contaminants could migrate along the groundwater gradiant (which is generally eastwards) northeastward towards the Pine Ridge Reservation or southeastward toward Chadron and the majority of the remaining High Plains Aquifer. Uranium could also be drawn upwards into parts of the High Plains Aquifer by high-capacity irrigation wells, some of which are known to be within major fault zones (northernmost Sheridan County, Nebraska).

In May of 2008, I was asked to evaluate the importance of a ‘whistleblower letter’ from Mr. John Peterson, a mining geologist, to Mr. Gary Konwinski of the Nuclear Regulatory Commission. This letter is dated 4 April 1989, and expresses Mr. Petersons concern that information pertaining to faults was being suppressed so that that Crow Butte Resources (CBR) could mine in an unsafe area. Mr. Peterson’s main contention is that the uranium mined by CBR occurs within the faults themselves, and is not a roll-front deposit as CBR maintains. This would be the worst possible situation. If there are minerals within faults, they are there because flowing water brought them there and deposited them there. If there are minerals along the faults and CBR is mining them, then they (CBR) are progressively ‘uncorking’ the flow pathways along these faults. If this is the true situation, the risk of spilling contaminants into these faults increases with additional mining, and contamination by chemically altered waters is a virtual certainty. Also, mining the Chamberlain Pass Formation could cause these faults to move again. This could create new, unforeseen pathways for contaminants spread through.

THE PROBLEM OF ARTESIAN WATER

Artesian flow occurs along the Pine Ridge of Nebraska when there is a hydrologic connection, through faults or highly permeable strata, between the Chamberlain PassFormation and the High Plains Aquifer. The weight of water in the topographically higher High Plains Aquifer exerts pressure downward into the Chamberlain Pass Formation, which can be released as artesian water flow where the topographically lower Chamberlain Pass Formation is exposed at the surface, or where it is punctured by drilling. Artesian flow was predicted by NDEQ in their evaluation of CBR’s petition for an aquifer exemption, and was observed by a local landowner as CBR did test drilling for the North Trend Expansion. Artesian flow could transmit the most mineral-laden of waters onto the land surface (and into White River alluvium) and discharge large amounts of contaminants into aquifers or faults in a very short time.

CONCLUDING REMARKS

Based on the arguments presented above, it is my expert opinion that ISL mining in the Crawford, Nebraska area should not be allowed to continue until the potential contaminant pathways of the White River alluvium and the SW-NE and NW-SE trending fault zones are examined and monitored. To this end, I suggest:

1. establishing a GIS database for the mapping of existing geologic units and features (e.g., faults). This would allow computer modeling of the region geology, hydrology, and structure, and would present the most complete picture of the data for final evaluation. Data acquired during the following investigations would be incorporated to the database.
2. map the White River alluvium in order to characterize its potential as a conduit for radioactive contaminants.
3. sample water from the White River at regular intervals (e.g., 2 miles) between Crawford and Pine Ridge to locate a plume of contaminated water or sediments, if present.
4. if contaminants are detected, convert sample wells to monitoring wells.
5. map the network of faults present in northwestern Nebraska and southwestern South Dakota.
6. pump test the faults to determine their permeability and the rate of water flow along them.
7. if water flow is detected along the faults, the convert selected sampling wells into monitoring wells.
http://pbadupws.nrc.gov/docs/ML0831/ML083180236.pdf From: “EXPERT OPINION REGARDING ISL MINING IN DAWES COUNTY, NEBRASKA” Hannan E. LaGarry, Ph. D. (Emphasis added to place focus on points which might be shared with the Dewey Burdock and even other projects. )