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Robert Vance

Subject: Public Comment on Redesigning the Uranium Resource Pathway from Robert Vance, UMNP Consulting
4 February 2019
Please see a marked copy of the report with questions, comments and corrections for the authors to address

While I agree that uranium needs a huge boost in order to take a much more prominent place needed in the ongoing efforts to decarbonize power generation and that the UNFC adds more detail to existing resource classification schemes, this publication in its current state falls far short of giving uranium a desired boost and overstates the role UNFC could play in this proposed U pathway.
The zero-waste approach is a lofty goal for any mining industry. Efforts are being made to minimize wastes, but there are limits to what can be done with existing technologies and market driven pricing. Solution mining offers a production pathway that eliminates tailings and reduces waste rock volumes (heap leaching with OP won’t, but in place heap does reduce waste rock in UG mines).However, ISL produces wastes that need disposal and U extraction in this fashion alters groundwater and host rock chemistry (points not mentioned in report). In addition, there are limits to how much U can be produced in this fashion. Mining high grade ores underground by remote technology, not ISL, is arguably a far more important technical development in the last two decades. Wastes are also minimized with this technology since waste rock needs to be added to dilute ore in order to process with existing mill technology. Moreover, ISL is not a recent technological development – it has been used since the early strategic era of U mining and is responsible for significant legacy waste issues (e.g. Czech Republic).

Co-product and by-product operations offer a possible pathway to lower waste volumes associated with U production, but the accounting slight of hand proposed in the report to attribute all wastes to the primary mining target is not now and will likely never be an acceptable way to accomplish this. For example, phosphate miners must deal with environmental impacts of waste stacks and if U is to once again be produced as a by-product in these operations it U production revenue must share in the environmental clean-up costs, as well as the added regulatory burden that U production will most likely bring to the operation.
The UNFC adds detail on socio-environmental aspects of resource development compared to other widely used classification systems, but the effects that broader implementation of the UNFC will produce are consistently overstated in the report. For example, the UNFC does not in itself “ensure” that socio-environmental aspects will be addressed, it simply offers a way of numerically expressing the state of play of these seemingly ever-expanding issues in a three-dimensional classification matrix. A quick examination of the U case studies that have been conducted to date reveals that it is precisely the socio-environmental axes that are often uncertain and left incomplete because the issues are complicated and often not always easily boiled down to simple numerical code. Even though there are overarching issues, each U mine typically has its own site-specific issues as well. Moreover, the example of comprehensive mine development activities in Tanzania presented in the report is completely the result of ongoing U mining and IAEA guidance and programs. Implementation of the UNFC has had little, if anything, to add to the exhaustive preparatory work conducted by the Tanzanian government and international agencies.
The most significant gap in this forward-looking report is the ultimate means of low impact U production, the extraction of U from the inexhaustible resource in seawater, which is only mentioned in passing. This has been researched for multiple decades and shown to be possible, although costly, but recent research has been driving down production costs. Extraction of U from seawater must be included as more than just passing mention in order for this report to be complete.
A marked copy of the report with questions, comments and corrections for the authors to address. Arguing for a change in the commodity markets for U should be founded on a better understanding of the existing market than is presented here. Stating that U requirements will decline and long-term contracts for U will disappear with the introduction of SMRs needs to be better founded in fact; e.g. how much U/GWe/yr will be required in an SMR compared to today’s large reactors? Will SMRs use U enriched to greater than 5%, thereby increasing the amount of U utilized?
The point that SMRs will change the market is presented as fact when at present only one SMR design has just been put into operation, actual costs for multiple SMR production have not been determined and the size of the market is unknown. Installation of a large number of SMRs is a necessity for financial success of these emerging designs. Moreover, large (1 GWe +) reactors are still being built, albeit in declining numbers, with lifetimes that may span 80-100 years and they will need a secure supply of U.
In summary, many shortcomings and misunderstandings need to be addressed before this report is ready for release in my view.