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The deadline was listed at midnight on Friday May 19th, apparently one minute to Saturday, but it’s not clear. It was just extended to June 19th, midnight. Normally they should put 11.59 pm to make it clear, but this is now Trumpistan la-la land.
Supposedly this is about Class III and V, but appears to be Class III and IV, “Dewey-Burdock Class III and Class V Injection Well Draft Area Permits”
“* Class III wells are used to inject fluids to dissolve and extract minerals.
* Class IV wells are shallow wells used to inject hazardous or radioactive wastes into or above a geologic formation that contains a USDW.
* Class V wells are used to inject non-hazardous fluids underground. Most Class V wells are used to dispose of wastes into or above underground sources of drinking water“. https://www.epa.gov/uic/underground-injection-control-well-classes
Cameco Crow Butte ISL (In Situ Leach) uranium mine across the border in Nebraska. Those who want to promote these mines euphemistically call them, ISR, In Situ Recovery. Another concern should be probably “land application” of waste water/by-product containing lethal radium. Often there is a combination of “land application” and injection of these wastes. This blog has covered these topics, at length, over the last 3 1/2 years and links to earlier posts may be found below.
Water Protector Debra White Plume speaking at EPA public hearing, last week (May 11, 2017):
link – http://youtu.be/prJ9sJF1XoM
USGS: Figure 5. Schematic showing hydrogeologic setting of the Black Hills area
Sample letter provided by Black Hills Clean Water Alliance who have opposed this mine for almost a decade:
“Dear EPA, Region 8: Here are my comments on the Underground Injection Control Program’s Draft Permits for the Proposed Dewey-Burdock Uranium Mine and Deep Disposal Wells:
Old uranium mines in the Dewey-Burdock area should be fully reclaimed before new mining is permitted.
Adequate oversight of the quality of liquid wastes pumped into the Minnelusa Formation through the proposed deep disposal wells will be impossible, and our groundwater is likely to be contaminated.
A full survey of cultural and historical sites is needed before mining or deep disposal is allowed. Cultural and historical sites must be protected.
The proposed mine and deep disposal wells are in an area that is documented to have faults, fractures, breccia pipes, and over 7000 old boreholes that have not been properly plugged. It will be impossible to contain mining fluids or waste liquids, and contamination of our groundwater is very likely.
The history of uranium mining indicates that uranium mining cannot be done without creating and leaving contamination. This project should be stopped until it can be proved to be safe, rather than relying on imperfect protection and clean-up processes.
Sincerely,” Emphasis our own. See original with address here: https://bhcleanwateralliance.files.wordpress.com/2017/03/comment-card-3-17-pdf.pdf
More here: https://bhcleanwateralliance.org
From the US EPA:
“Public Notice: Administrative Record for the Dewey-Burdock Class III and Class V Injection Well Draft Area Permits
“The EPA Region 8 UIC Program is issuing two Draft UIC Area Permits to Powertech (USA) Inc., Suite #140, 5575 Denver Technical Center Parkway, Greenwood Village, Colorado 80111, for injection activities related to uranium recovery. One is a UIC Class III Area Permit for injection wells for the ISR of uranium; the second is a UIC Class V Area Permit for deep injection wells that will be used to dispose of ISR process waste fluids into the Minnelusa Formation after treatment to meet radioactive waste and hazardous waste standards.
The EPA is also proposing an aquifer exemption approval in connection with the Class III Area Permit to exempt the uranium-bearing portions of the Inyan Kara Group aquifers. Written comments must be received by midnight on May 19, 2017.” https://www.epa.gov/uic/administrative-record-dewey-burdock-class-iii-and-class-v-injection-well-draft-area-permits
Deadline appears to be 11.59 pm on June 19th. The link says midnight on the 19th.
Normally comment should be at Regulations.gov which allows anonymous comment, but they want emails-mail apparently to a) make it complicated and b) compile names, which should raise alarm. Those who wish to remain anonymous will need to make a disposable email. Related: https://www.regulations.gov/document?D=NRC-2016-0001-0060
Our Previous Posts on the topic:
“Is midnight the end of a day or the beginning of a day?
When someone refers to “midnight tonight” or “midnight last night” the reference of time is obvious. However, if a date/time is referred to as “at midnight on Friday, October 20th” the intention could be either midnight the beginning of the day or midnight at the end of the day.
To avoid ambiguity, specification of an event as occurring on a particular day at 11:59 p.m. or 12:01 a.m. is a good idea, especially legal documents such as contracts and insurance policies. Another option would be to use 24-hour clock, using the designation of 0000 to refer to midnight at the beginning of a given day (or date) and 2400 to designate the end of a given day (or date).” https://www.nist.gov/pml/time-and-frequency-division/times-day-faqs