hundreds of miles from other large townsand with limited financial means. Pleasepressure your organization to take astand - in your community, in Denver, andin Washington, D.C. We need you to helpto shine a light on what's going on in theBlack Hills and apply pressure on thefederal government. Alert your mediacontacts to the issues here. Be sure yourlobbyists know what's going on at theEPA. Let your members know what'shappening here, and encourage them tosupport our efforts. Tie what's going on inthe Black Hills to issues in your area.

Learn more on our website and contactus, so we can work together to stop thisplan. And thank you for helping to saveour water and the Black Hills!

A struggle over a proposed uraniummine in the Black Hills of South Dakota— far from population centers —illuminates important aspects of waterissues, Native American rights, deepdisposal wells, the EnvironmentalProtection Agency's (EPA) role, and thelegal issues swirling around them all.Uranium mining is an issue of nationalimportance, because it is the first step inthe nuclear chain. Without uraniummining, there could be no nuclear poweror nuclear weapons. But the issues startwith water.

BACKGROUNDThe Black Hills are a beautiful and uniquearea in the middle of the northern GreatPlains, characterized by pine-coveredhills, dramatic rock outcrops, and freshwater that flows into undergroundaquifers to recharge groundwater acrossthe region. The Black Hills are subject totreaties between the Lakota (Sioux)people and the United States thatreserved control of the Hills to the Lakota.

its mining operation to begin. It currentlyhas one -from the Nuclear RegulatoryCommission (NRC) - but that license isunder litigation. A Federal court recentlyordered the NRC to rework the licensingprocess for the project and comply withthe National Environmental Policy Act(NEPA).

THE EPA ROLE The company has applied to the EPA fortwo permits. One would allow water useand consumption for the ISL miningprocess in the lnyan Kara aquifers, aClass Ill permit. The other would allow thecompany to pump its wastewater intodeep disposal wells in the Minnelusaaquifer, using a Class V permit. Deepdisposal wells have been an issue forwater quantity and quality across theU.S. The permit processes are beinghandled by the Underground InjectionControl Program in the Region 8 EPAoffice in Denver.

The Region 8 office issued two draftpermits to the company in March 2016.Public hearings were held in five areatowns in April and May 2017, and publiccomments were due in June. Over 700people attended the public hearings, and93% of those who commented wereopposed to the permits. Similarly, theopinions expressed in the writtencomments were lopsided — 95% of the

comments opposed the permits. As ofJuly 2018, the EPA is still consideringwhether to issue final permits toPowertech.

Historically, the EPA has issued deepdisposal well permits. In the currentpolitical climate, they are likely to faceadditional pressure to issue permits. Andthe current head of the agency has ahistory as a lobbyist for a uraniumcompany.

But the public's opposition needs to beheard in this process. This is clearly a testcase on whether the EPA takes publicinput into account in its decision making.Legal issues, including protection ofLakota rights and cultural resources,need to be carefully considered. Science,which indicates that ISL uranium miningcannot be done safely, should also havea role in the discussion. An EPA processthat would shut out the public, science,and law could set a horrible precedent.

A NATIONAL ROLE National support and involvement areneeded to stop EPA from issuing finalpermits and to end this mining proposal.The price of uranium is currently belowthe cost of production, and there's norational reason to start new mines. Still,the uranium industry is pushing for tariffson imported uranium to buoy the price ofthe mineral and encourage new mining inthe United States. This would support thenuclear industry and nuclear proliferationinternationally, encouraging theconstruction of more nuclear powerplants and nuclear weapons.

We are a small, volunteer organization

WATER,THE EPA, AND

THE BLACKHILLS:

A NATIONALISSUE

Clean Water Alliancewww.bhcleanwateralliance.org

nobhuranium@gmail.com

Lilias Jarding, Ph.D.P.O. Box 591

Rapid City, SD 57709 Facebook- Black Hills Clean Water Alliance

605-787-2872(slow to respond on M, W, and F due to travel)

In a classic case of environmentalinjustice, this promise has not been kept.But the Lakota maintain a strong legal, 4.traditional, and spiritual link to the BlackHills.

The Hills are probably best known todayas the home of Mount Rushmore and theSturgis motorcycle rally. Most touriststoday don't know that the areaexperienced uranium mining and millingin the 1950s to early 1970s. This left 169abandoned mines and prospects and atrail of contaminated land and water to thesouth and west of Mount Rushmore. Inthe late 1970s, determined and diversecitizen opposition — and eventually adrop in the price of uranium — held offthat wave of uranium fever.

In the mid-2000s, there was again aboom in uranium exploration, as the priceof a pound of yellowcake (minimallyprocessed uranium) jumped to $138 froma low of $7. Eleven companies expressedan interest in Black Hills uranium. One,Powertech Uranium, is the focus of —

again — determined and diverse citizenopposition. It is also the subject of apending Environmental ProtectionAgency (EPA) action that should concernpeople across the United States.

THE POWERTECH PROJECT The proposed Powertech Uraniumproject is located in Custer and Fall RiverCounties. It is known as the Dewey-Burdock project, and the site is over10,000 acres, or about half the size ofManhattan.

The company proposes to mine uraniumusing the “in situ” leach (ISL) miningmethod. In order for ISL mining to work,the uranium must be located directly in an

underground aquifer. The methodinvolves pumping a solution undergroundthrough wells. The solution is forcedthrough a uranium deposit and leachesthe uranium out of the rock. The solutionis then pumped back to the surface, andthe uranium is removed for furtherprocessing.

Powertech, which has never mineduranium, proposes to drill 4,000 wells intoan aquifer that is used for domestic waterand livestock. The project would use9,000 gallons of water per minute, 1/3larger than the amount of groundwaterused by nearby Rapid City, the second-largest town in the state. Italso plans to pump itswastewater into anotheraquifer that is used byarea residents throughfour deep disposal wells.If it fails to get permissionfor deep disposal wells, itplans to spray itswastewater on thesurface of the ground,covering 1,052 acres. Alltold, the project wouldimpact water from 3 of the4 major drinking wateraquifers in the Black Hills,

a semi-arid area that relies ongroundwater.

Resistance to the project includes theCity Council of Rapid City. It also includesthe South Dakota State MedicalAssociation, which passed a resolutionagainst the proposed mine in 2013. TheOglala Sioux Tribe has taken leadershipin fighting the proposal, and all nine tribalgovernments within South Dakota havepassed resolutions against it. Local non-profit groups have also led the opposition.

Powertech, which was organized inCanada, has become part of AzargaUranium. Azarga has ties to China andKyrgyzstan. Its largest investor, PlatinumPartners, was organized in the CaymanIslands. Seven corporate leaders werecharged in New York federal court withfraud and other crimes in December2016. Platinum Partners is now inreceivership.

Powertech/ Azarga needs to get at leastten federal, state, and county permits for

New York Times 1980

Drilling New ISL Site. Casper Star Tribune

ISL Wellfield Installation