Reclamation of these mine sites and historic tailing piles also can lead to additional uranium production depending on the ore concentrations in the waste rock or remaining ore on piles. Many of these mines are located on federal land. These reserves are subject to regulation by the State with jurisdiction over the site as well as the applicable federal land management agency — either the U.S. Bureau of Land Management or the U.S. Forest Service. As a result, duplicative but complimentary permitting often is required. Some historical mines have existing permits from a boom that occurred in the late 1970’s and early 1980’s; however, environmental regulations were new at that time, and the permits can range from two to ten pages or so. A modern uranium mine permit will be in the hundreds to even thousands of pages once all applicable permits are obtained.
Permitting starts with a literature search and understanding of the mineral and surface ownership of the claims. If additional exploration is required, a separate permit would be required, which may include an accompanying NEPA assessment. To promote a successful permitting process, community outreach should begin as soon as practicable to ensure that community concerns are addressed proactively in the permitting process. Meetings with State and federal regulators will facilitate coordination of the NEPA process and the State Mine Development Plan process. Because uranium mining permits are likely to be “vintage,” it is useful to find common agreement on the level of environmental assessment, sampling, modeling, and monitoring required for permitting. A project is likely to be required to navigate another tier of permitting with local governments, departments of transportation, and air and water quality.
Specifically, mine plans include a mining plan, reclamation plan and environmental impact assessment. The latter should include assessment of potential impacts to air quality, surface water, spills, groundwater, mine water, waste rock characterization, wildlife and biological resources, historic preservation assessments and consultations, tribal consultations, radioactive materials license(s), archaeological resources assessments, visual quality, noise, wetlands, floodplains, and transportation plans. Local permits for buildings, access roads, visibility, special use, and transportation also may be required to name just a few examples. This is all in accordance with local planning and zoning regulations, transportation and hazardous waste requirements, state environmental regulations, and 40 CFR 1500 (NEPA) and, for projects on federal lands, 40 CFR Part 3800 (Mining Claims under the General Mining Laws). Many of these processes include public comment periods, responses to comments and public hearings. Approvals are followed up by an appeals process (or several). After a project begins operations, there are ongoing operational, maintenance, monitoring and inspection requirements that include a wide range of environmental protections. The mine permit will also include a cost estimate and mine reclamation plan with a surety bond or similar assurance for the full cost of reclamation.