Few investors and analysts have a firm grasp of the length of time environmental studies and the approvals process requires. Having visited numerous investor forums, we realized many investors believe a property is drilled and then mined, after a brief permitting period. Quite the opposite is true, as explained to us by Richard Blubaugh, environmental manager for Powertech Uranium (PWURF). A highly respected environmental manager, Mr. Blubaugh got his start in government service before moving to private industry. We found the same governmental background with others of Mr. Blubaugh's caliber, such as Strathmore Minerals' Juan Velasquez and Uranerz Energy's Glenn Catchpole.
Permitting a uranium mine requires more than a simple application to mine. And, as we discovered, the process can take between three and six years (sometimes even longer), costing several million dollars and requiring numerous scientific studies on a company's property. This could add additional pressure to uranium prices.
StockInterview: After studying several company news releases, it appears one of the first environmental studies required is the archaeological survey. Why is that done before mining uranium?
Richard Blubaugh: The archaeological surveys are required to evaluate cultural, archaeological and paleontological resources. It's necessary to do to in order to identify and protect those resources for the whole state--academia as well. You can't really go out and disturb these areas without knowing what's there, what might be valuable and what might not. The first thing is to identify a reputable and competent archaeologist or a group of archaeological professionals that have some standing with the regulatory community.
StockInterview: What does the consulting group do then?
Richard Blubaugh: They start with literature review, which would go through the records and see if any previous studies have been done in this area. Those studies are archived generally with the state archaeologists or historical preservation society. Then they determine best where to start and, in this case, we are asking them to start where our drill sites are located because we want to clear those sites so that we can go ahead and start our drilling activities. Then they will review the rest of the property. It could take anywhere from months to years depending upon what's found in any given area.
StockInterview: What happens if you find something of historical interest?
Richard Blubaugh: If you find something, this doesn't mean you are out of luck or your project is stopped. It just means that it's going to take a little more time and effort to deal. It usually is a negotiated process under the Federal actions, a Section 106 consultation. If it's determined to be eligible, then it requires more research and negotiation, which is often avoidance. You fence it off or somehow mark it and stay away from it. But if you have to disturb an area where there's a cultural asset, then that requires mitigation through digging, identifying, recording, photographing and reporting on everything that's found. Then, that stuff is often removed and archived in a museum.
StockInterview: What do the archaeological consultants look for when going over your ground?
Richard Blubaugh: Items such as dinosaur bones or old stone tools and baskets, and historical resources, which are within the last few hundred years, since the white man has been on the continent. You could have buildings, an old school building or some other structure that had some significance, which maybe is a hundred or more years old.
StockInterview: How does your initial review for PowerTech in South Dakota look with regards to this part of the environmental studies?
Richard Blubaugh: We are fortunate at our Dewey Burdock project in South Dakota. Previous parties involved with the site, TVA and Silver King mines, had already done a lot of archaeological work on the site. Because the data is more than 20 years old, we have to go out and confirm they didn't miss anything on the earlier surveys. I talked to the state archaeology office last week. Indications are that there isn't anything that's eligible at the project site. But there are a number of artifacts, mostly in the nature of stone flakes, points, arrowheads and that kind of thing.
StockInterview: What are some of the other environmental studies which need to be done?
Richard Blubaugh: There are a dozen or more specialized disciplines that have to be studied, such as meteorology, archaeology, paleontology, seismology, vegetation, wildlife and soils. You look at all aspects of the environment that could possibly be impacted by your operations or that could impact your operations.
StockInterview: Why are you doing a meteorology study when mining for uranium?
Richard Blubaugh: So that you know which way the wind blows. It takes often a whole year's worth of data to determine with accuracy which is the predominant wind direction. The data exists at weather stations around the country, at Federal installations, at cities, and so forth but the focus and, I guess the key phrase is, site specificity. Along with meteorology is air quality. We also take samples of the air and send the filters in for analysis so we know what kind of contaminants exist in the air before we start operations. It's information that you need to determine who is most likely to be contaminated if, for example, you had some type of accident. The data we collect gets inputted into computer programs for the NRC.
StockInterview: What other type of data are you required to assess?
Richard Blubaugh: You have to determine whether there are other economic resources in the area and whether you are going to be impacting their potential recovery as well, such oil and gas, or sand and gravel. If you have wetlands or surface water then you are going to have to also examine those critters. Typically you look at fish but you can also look at reptiles, frogs and so on.
StockInterview: And of course the water testing?
Richard Blubaugh:
We have two pump tests included in our exploration plan. The pump tests are going to be up front. That's going to be the first thing we do relative to groundwater, particularly for the Dewey project. We will probably be starting baseline groundwater monitoring at the Centennial project by June. I expect it will be pretty close to that for Dewey Burdock as well. In surface water hydrology and water quality, we also have to test so if we had any running streams in the project or near the project area, you have to do your sub-baseline on those surface waters as well, determine the water quality and the water quantity also.
StockInterview: What do the water studies determine?
Richard Blubaugh: Environmentally it tells you, kind of like the meteorology, which way the water flows, what kind of water it is, quality-wise, and what's in the water. It also provides certain data for production, such permeability, transitivity, porosity and those kinds of things. Transitivity has to do with how fast the water moves in the ground and the speed of water in the ground, i.e. so many feet per year.
StockInterview: What do you learn by doing some of these other studies, and why are they required?
Richard Blubaugh: We have to identify each soil type and map it. We have to be able to represent which soils need to be enhanced or not during reclamation. Actually, it's quite an extensive project for soils and certainly the radiometrics are part of it. With vegetation you look at productivity - how much biomass you get off of a given area and also plant cover; what percentage of the underground is covered by plant materials and growing plants. You determine the different species. The wildlife is very similar to that. You have to get into each species. Each one has different habitats and on somebody's list somewhere.
StockInterview: Why would you do a seismic study?
Richard Blubaugh: That deals with earthquakes and the degree of the probability of any particular size earthquake in the region. This goes into your design factors for structures, impoundments and so on.
StockInterview: And the 'bugs and bunnies' survey?
Richard Blubaugh: Yes, I'm glad you mentioned that. That's typically what we refer to those studies as, but it's a lot more than bugs and bunnies. We don't study the insects. That's kind of a misnomer when we say bugs and bunnies. In our wildlife surveys, that's the threatened and endangered species and habitats-- from birds to bears. Flora and fauna, this covers vegetation and wildlife under one term.
StockInterview: How long does it take to complete these studies?
Richard Blubaugh: Typically, baseline data collection--that's kind of the generic umbrella name for all of these different disciplines that you've got going on studying the project area and the surrounding environs. Your baseline data collection period typically runs a year to a year and a quarter. In some cases, it can vary depending upon the state or the key agency but generally, you look at a year so by the time you take the data, massage it, put it into your software programs, get the results and prepare your applications to the different agencies involved. You are looking at roughly a year and a half to two years on the outside for submitting your applications. The next step would be how long would it take to get the permit after you submit it and get all this information in your applications. That is a little more variable and, again, it depends upon the agencies and who is involved in it whether you've got the Federal agencies like NRC, EPA (which typically you are going to have EPA anyway), whether you are have BLM involved or the forest services. These are all contributing factors on how long it's going to take.
StockInterview: What is the general procedure: how much paperwork is involved, and who reviews it?
Richard Blubaugh:
It will be several volumes by the time you are through. You could be looking at anywhere from four to six of those 3-inch binders. It would all go to the NRC and the state agency. You wouldn't send all of that to the EPA. They are just focused on the groundwater so you pull all the groundwater stuff, and they may have some additional requirements that go to EPA.
StockInterview: And what if the accumulated data is incomplete?
Richard Blubaugh:
All agencies have what they call their completeness review so when an application comes in, the first thing they do is do a completeness review and make sure that everything that's required is in the package, in the application. That's before they even look at any of the content. They simply look to see that all the pieces are there. Then, NRC has indicated they are going to take a closer look during the completeness review, which they said could last up to 90 days. But it's more than a completeness review. It's a completeness and adequacy review, which means that at the end of that period, if your application is complete and adequate, then they are going to continue to review the application for licensing. If it isn't complete, then what they are going to do is return it to you. They are going to be a little more explicit in why it isn't complete and where the inadequacies are which will give you a good idea of what else you need to do. At that point then, they go into the EIS (Environmental Impact Study) process. The EIS process has been noted to take anywhere from 18 to 24 months, and longer if you have strong opposition.
StockInterview: How much does the environmental permitting process cost?
Richard Blubaugh: It does cost a small fortune. The costs are going to vary again depending on the project, area and whether or not an EIS is required, all those different factors will come into play. (Editor's Note: We checked with Strathmore Minerals' John DeJoia and Uranerz Energy's Glenn Catchpole, both of whom confirmed that environmental studies would likely cost in the neighborhood of about /pound of uranium mined on a company's project.)
StockInterview: Let's take Powertech as an example. How long would this process take your company to complete so you could mine at Dewey Burdock (South Dakota) or Centennial (Colorado)?
Richard Blubaugh: We are looking at South Dakota where we have NRC. When we are talking about the NRC and EIS process, 2010 or 2011 is what you are probably looking at there. But, for Colorado, in our case, we already have our schedule in place and our consultants selected and we are going to see. But, this is without a mill. We are looking at conventional mining on one of our deposits - open pit - before 2010.
StockInterview: Where would the ore get milled? And would you have it trucked to a mill?
Richard Blubaugh: We've been talking to Sweetwater. It would work just like it would for any other trucking facility, except we would have to get a hazardous transportation permit from DOT (Department of Transportation). Then there's rail. We have rail close to both our facilities in our planned operations in South Dakota and in Colorado.
StockInterview: How do you avoid dealing with a federal agency?
Richard Blubaugh: The agreement states - Texas, Utah, and Colorado - don't have the EIS requirement. They may have requirements that are almost similar to an EIS requirement, but some of them don't. If you are going to build a new processing facility, then yes there will be an EIS. But if you are just going to build a satellite facility, or if you are going to build an open pit mine or underground mine to conventional mining facilities, you do not require an EIS.
StockInterview: And in South Dakota?
Richard Blubaugh: Because South Dakota is not an agreement state, we will be working with the two larger Federal agencies as well: the Nuclear Regulatory Commission (NRC) and the EPA. EPA issues the approvals for the UIC program which is basically governing injection wells and the aquifer exemption process. NRC issues the source material and byproduct license. Anything having to do with uranium processing goes to NRC.
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