WDEQ REPORTING & COMPLIANCE UPDATE FOR

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1 WDEQ REPORTING & COMPLIANCE UPDATE FOR CLASS I UIC WELLS: APPLICATION TO ISR URANIUM OPERATORS WES JANES, P.G. / HAL DEMUTH, M.S. PETROTEK CORPORATION 6/5/2018

2 2 INTRODUCTION WDEQ Chapter 27 (rev. 9/15/15) Regulations apply to Class I UIC wells New WDEQ Project Managers Increased focus on quarterly & annual reporting New MIT guidance (7/6/15) Enforcement of historic requirements annual COI/AOR update Summary Questions

3 3 EFFECT ON URANIUM OPERATIONS? Increased scrutiny likely to result in more compliance issues Loss of institutional knowledge for many uranium operations Staff reductions may result in need for outside reporting help Enforcement of existing regulations may complicate AOR review AOR impacted for facilities with or considering multiple wells Higher costs for annual falloff testing analysis & MITs due to frequency

4 4 WHAT ARE THE CHANGES? WDEQ Project Managers for individual facilities Enforcement of all reporting requirements due to closer scrutiny MIT intervals & requirements Quarterly & Annual reporting & injectate analysis requirements COI calculation may be impacted by pressure interference Annual updates Permit applications

5 5 WDEQ PROJECT MANAGERS Four WDEQ Project Managers covering Class I wells at Uranium Sites Project Managers: Direct contact for all permitting, compliance/reporting, enforcement & inspections for the well/facility to which they are assigned Company Name Facility Name Project Manager Office Contact UEC/AUC LLC Reno Creek Carrie Steinhorst Sheridan (307) Cameco Resources North Butte Ursula Willimas Sheridan (307) Cameco Resources Smith-Highland-Reynolds Ursula Willimas Sheridan (307) Cameco Resources Gas Hills Laurel Morrow Cheyenne (307) Energy Fuels Nichols Ranch Ursula Willimas Sheridan (307) Lost Creek ISR, LLC Lost Creek Chris Brown Cheyenne (307) Strata Energy, Inc. Ross Carrie Steinhorst Sheridan (307) Uranium One USA, Inc. Christensen Ranch Ursula Willimas Sheridan (307) WDEQ 2018

6 6 REPORTING REQUIREMENTS Reporting requirements are permit specific New permit model (based on 12/17 Class I permit) Quarterly reports submitted via (pdf) within 30 days of end of quarter Quarterly reports (pdf) uploaded & online table completed (GEM) within 45 days of end of quarter In our experience, some PMs may only require an uploaded pdf to GEM check with your PM for guidance Annual reports submitted via (pdf) within 30 days of December 31

7 7 QUARTERLY REPORTING REQUIREMENTS 1. Injection rates for each month of the quarter Minimum, average, maximum, maximum permitted injection rate 2. Injection pressure for each month of the quarter Minimum daily, average daily, maximum permitted pressure, alarm/kill pressure 3. Injection volume per well Total volume for each month, total for quarter, total volume to date 4. Annulus pressures Maximum & minimum for each month of the quarter, alarm/kill pressure

8 8 QUARTERLY REPORTING REQUIREMENTS CON T. 5. Quarterly Analytical Results Temperature & ph measured on site Specific Gravity & TDS analysis performed by USEPA certified lab Additional constituents may be required for ISR facilities 6. Any permit exceedances within the quarter Brief explanation must be added in Comments on GEM report 7. Description of all events that triggered alarms/shutdowns during the quarter & responses taken 8. Reports for any well test or workovers conducted more than 30 days before the end of the quarter

9 9 ANNUAL REPORTING REQUIREMENTS 1. Graphical representation & digital data of injection pressures & volumes for previous five years of operation 2. Graphical representation & digital data of analyte concentrations (presumed TDS only) over time for previous five years of operation 3. Annual analytical data Quarterly parameters (4) Volatile organic compounds (11) Semi-volatile organic compounds (13) Metals (8) Herbicides (2) & Pesticides (6) It is possible that a smaller analytical list may apply to ISR operations

10 MIT REQUIREMENTS 10 Based on 12/17 Class I permit & WDEQ memo 7/6/15 MIT Frequency Part I & II MIT conducted every three years for wells >10 yrs. old & every time tubing or packer is pulled If a well >10 yrs. old is recompleted with full liner: 5-yr. MIT If a well is completed with a patch/partial liner: 1-yr. MIT Part I MIT: 30 minutes <10% loss conducted at 1,000 psi or LSIP (highest) Part II MIT (Temp & RAT) conducted >2 hrs. (24 hrs. preferred) after SI Temperature log from base of conductor to well TD

11 11 ANNUAL PRESSURE FALLOFF TEST New permit model requires use of downhole gauges Annual falloff required for each well Measurement of downhole pressure for at least 1 hour prior to test start Injection period greater or equal to the falloff period Falloff test results used to update cone of influence (COI) calculation Account for historical injection & remaining project life Provide map showing updated COI & all wells that penetrate the confining zone within COI Digital data, results, analysis & interpretations submitted in hardcopy & GEMs within 30 days or with the next quarterly report, whichever is later

12 12 COI/AOR ANNUAL UPDATE COI calculated per Chapter 27, Section 6(f)(iv) AOR is the greatest of ¼ mile, COI, or area of emplaced waste (AEW) If the updated COI encompasses wells not previously identified within the AOR: Permittee shall demonstrate that the new wells do not represent potential pathways from the injection zone to lowermost USDW above injection zone If a demonstration is not possible (plugging records, etc.), a corrective action plan shall be submitted to & approved by WDEQ & incorporated as permit condition

13 COI/AOR UPDATE EXAMPLE 13 Three wells without pressure interference COI: ~5,280 ft. 17 wells in AOR Three wells with pressure interference COI: ~14,700 ft. 130 wells in AOR

14 14 SUMMARY THE GOOD NEWS A strong state program is more effective and reduces regulatory risk The higher level of scrutiny benefits the well operators by helping to assure compliance with federal UIC regulations The WDEQ Project Managers serve as a direct contact for ISR operators Should lead to higher level of efficiency Answer questions - permitting, testing & approvals

15 15 QUESTIONS? WES JANES, P.G. / HAL DEMUTH, M.S. wjanes@petrotek.com hdemuth@petrotek.com PETROTEK CORPORATION 5935 SOUTH ZANG STREET, SUITE 200 LITTLETON, CO P: F:

FOR THE PERIOD JANUARY 1, TO DECEMBER 31, GENERAL INFORMATION

FOR THE PERIOD JANUARY 1, TO DECEMBER 31, GENERAL INFORMATION 3850-PM-BCW0083h Rev. 11/2016 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF ENVIRONMENTAL PROTECTION BUREAU OF CLEAN WATER PAG-03 NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES) GENERAL PERMIT FOR