Pinon Ridge Hearing Transcripts Part 5

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1048

JUDICIAL ARBITER GROUP

JAG No. 12 A 1318__________________________________________________

REPORTER'S TRANSCRIPT OF HEARING, VOLUME VINovember 12, 2012__________________________________________________

IN RE: THE APPLICATION OF ENERGY FUELS RESOURCES,INC. FOR A RADIOACTIVE MATERIALS LICENSE FOR THEPINON RIDGE URANIUM MILL__________________________________________________

PURSUANT TO NOTICE to all parties in

interest, the above-entitled matter resumed for

hearing before Honorable Richard W. Dana on Monday,

November 12, 2012, beginning at 8:35 a.m., at

1045 Main Street, Nucla, Colorado, before Janet Lee

Priestley, Registered Professional Reporter and

Notary Public within and for the State of Colorado.



1049

1 APPEARANCES:

2 FAEGRE BAKER DANIELS, LLP By James R. Spaanstra, Esq.

3 Olivia D. Lucas, Esq. 1700 Lincoln Street, Suite 3200

4 Denver, Colorado 80203 ENERGY FUELS RESOURCES

5 By Curtis H. Moore, Esq. Director of Communications & Legal

6 Affairs 44 Union Boulevard, Suite 600

7 Lakewood, Colorado 80228 Appearing on behalf of Energy Fuels

8 Resources.

9 TRAVIS STILLS, ESQ.

10 Energy Minerals Law Center 1911 Main Avenue, Suite 238

11 Durango, Colorado 81301 and

12 JEFFREY C. PARSONS, ESQ. Western Mining Action Project

13 P.O. Box 349 Lyons, Colorado 80540

14 Appearing on behalf of Sheep Mountain Alliance.

15

16 MATT SANDLER, ESQ. Rocky Mountain Wild

17 1536 Wynkoop Street, Suite 303 Denver, Colorado 80202

18 Appearing telephonically on behalf of Rocky Mountain Wild, Center for

19 Biological Diversity, and Colorado Environmental Coalition.

20

21 OFFICE OF THE ATTORNEY GENERAL By Jerry W. Goad, Esq.

22 First Assistant Attorney General 1525 Sherman Street, 7th Floor

23 Denver, Colorado 80203 Appearing telephonically on behalf

24 of Colorado Department of Public Health and Environment.

25



1050

1 APPEARANCES: (Continued)

2 ROBERT LOUIS GROSSMAN, PhD 6215 Baseline Road

3 Boulder, Colorado 80303 Party in Interest

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1051

1 I N D E X

2 PUBLIC COMMENTS: Pages 1,056 to 1,230 Pages 1,290 to 1,307

3WITNESSES PAGE

4 FRANK FILAS Cross-Examination by Mr. Filas 1,232

5 Cross-Examination Resumed by Mr. Filas 1,308 Cross-Examination by Dr. Grossman 1,364

6

7 SMA EXHIBITS ADMITTED

8 Exhibit 19 10-17-12 press release 1,247

9 Exhibit 20 CD of Energy Fuels self-reporting 1,267 documents to CDPHE

10Exhibit 21 Excerpt from environmental report 1,272

11Exhibit 22 12-14-07 E-mail exchanges among 1,284

12 Frank Filas and Zach Rogers and others

13Exhibit 23 11-25-09 Pinon Ridge mill license 1,309

14 application, potential technical issues

15Exhibit 24 4-5-11 E-mail to John Harvey 1,318

16 from Frank Filas and related E-mail

17Exhibit 25 Pinon Ridge Three Step Plan dated 1,326

18 March 2012

19 Exhibit 26 5-3-10 E-mail to Frank Filas 1,329 from Bob Monok and related

20 E-mails

21 Exhibit 27 December 2010 monthly report 1,335 prepared by Frank Filas

22Exhibit 28 11-8-10 confidential memorandum 1,338

23 to Steve Antony from Frank Filas

24 Exhibit 29 8-13-09 Pinon Ridge mill 1,348 decommissioning and reclamation

25 cost estimate



1052

1 I N D E X (Continued)

2 SMA EXHIBITS ADMITTED

3 Exhibit 30 Notes from 9-7-10 conference call 1,354 with Fish and Wildlife Service

4 and Pinon Ridge mill representatives

5Exhibit 31 5-31-12 E-mail to Frank Filas 1,361

6 from Steve Tarlton and related E-mails

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1053

1 P R O C E E D I N G S

2 HEARING OFFICER: For the record, we'll go

3 back into session for the administrative hearing for

4 the Pinon Ridge uranium mill application. Time is

5 set aside today for public comments. I have received

6 some in writing, and we're going to start a process

7 in a moment where we'll do oral comments.

8 For those of you who haven't been with us

9 every day, we're going to do all the comments of

10 those of you that are present. And when we run out

11 of people to do that, we're going to put the lawyers

12 back to work and me back to work hearing the evidence

13 in the case. And then we'll interrupt that at fairly

14 regular intervals to do more comments from other

15 people that come in. And hopefully we'll balance

16 this out and get the day done.

17 The process is if you're to make an oral

18 comment, there's a sign-up sheet in the back of the

19 room. And I would appreciate it if I could get your

20 name and very brief information so that I spell

21 everybody's name right and make the record clear

22 here. The written comments for the record that

23 people have given me, I have about 30 of them

24 available on the Internet. And there's a link I can

25 get you, if anybody particularly wants to look at



1054

1 them, that will get you into the file that has all

2 those comments in it. For the benefit of counsel I

3 will say that I spent some time yesterday trying to

4 get them all in a format that is readable by

5 everybody. And I've asked Mr. Stills, who we know

6 had difficulty reading my first cut at it, to check

7 and see if he can read it. And if he can, then I'll

8 put the additional comments I have on there. I have

9 about 80 that are not yet on there because I wasn't

10 sure about the format I was saving them in. I didn't

11 want to do it and have it be unproductive. And

12 that's my lack of technical skill with the computers

13 that drives that exercise, so bear with me. But

14 eventually all of the written public comments will be

15 available to be read by anybody on that link.

16 The oral public comments are made from

17 right here (indicating). Since Dr. Grossman hasn't

18 arrived yet, we'll use this chair if you want to sit

19 down, but most people have stood. You have to speak

20 so the reporter can hear you and so that I can hear

21 you. We've not time-limited this, but I'd ask you to

22 accommodate everybody. We've got a lot of people

23 here. And we'll go from there. I'll walk back and

24 get the list and -- is anybody here that has not

25 signed up on the sign-up sheet that would like to



1055

1 make a comment?

2 AUDIENCE MEMBER: Where is it?

3 HEARING OFFICER: Over on the table by the

4 donuts or whatever is there. And I'll walk back and

5 get the list in a minute, and we'll start calling on

6 you. I will ask you to take an oath. I'll do that

7 as a group. It's quicker to do it that way. I will

8 tell you that to this point, none of the counsel have

9 asked questions of the people making oral comments,

10 although I think they're entitled to. But those are

11 going to be questions more than cross-examination.

12 We're not going to get in arguments about this in

13 this context. We'll get into arguments about it from

14 the parties that are sitting in the front of the

15 room. Trust me, they'll make your argument for you.

16 Whatever side you're on, they'll make your argument.

17 You can on that.

18 So with that premise, that's the protocol

19 for the morning. And I'll walk back and get the

20 sign-up sheets, and we'll get started. If you have

21 acquaintances or friends that come in as we're going

22 through this, if you'd point them in that direction

23 I'd appreciate it.

24 MR. STILLS: The text and PDF format comes

25 up fine.



1056

1 (Discussion off the record.)

2 HEARING OFFICER: All right. Let me ask,

3 if I could, for those of you in the back of the room

4 who intend to make public comments, if you'd raise

5 your right hand.

6 (Audience members intending to offer

7 public comments were sworn by the Hearing

8 Officer.)

9 HEARING OFFICER: All right. I mixed

10 these up as I was coming forward, folks, so they're

11 completely out of any kind of rational order. And

12 bear with me. I'm just going to go through the list.

13 Rein Van West. How closely did I miss

14 that one?

15 MR. VAN WEST: You're a lot closer, Judge,

16 than many. It's Rein Van West. And I'm a resident

17 of Ouray County here in the state of Colorado. And

18 good morning to all. I'm not at all opposed to

19 citizens in Western Colorado either having more jobs

20 or financial benefit from the proposed Energy Fuels

21 uranium mill. However, I'm strongly opposed to the

22 operation of this mill should it begin processing

23 uranium ore on two counts. Number one, given --

24 (Speakerphone interruption.)

25 HEARING OFFICER: Go ahead. You'll get



1057

1 that all day.

2 MR. VAN WEST: -- given that there is a

3 well documented history of radioactive groundwater

4 contamination in the state of Colorado, I'm very

5 concerned that the applicant is being granted a

6 permit by the Colorado Department of Public Health

7 and Environment under requirements that are similar

8 to ones where radioactive groundwater contamination

9 has already occurred in other locations in our state.

10 These requirements have not been

11 researched adequately to establish the statistical

12 probability of a system failure. And yet there are

13 failures; perhaps immediately or perhaps long after

14 the uranium mill has ceased operations. I'm

15 concerned that such a failure relative to radioactive

16 groundwater can contaminate downstream water supplies

17 and thereby cause deep and serious liability issues

18 from other downstream Colorado counties and/or

19 states. Where's the contingency plan should this

20 occur, and who pays the financial cost of such a

21 system failure?

22 My second point is simply how's it

23 possible for the CDPHE to be allowed, who is our,

24 yours and mine, state regulatory agency charged with

25 keeping its citizens safe from industrial health



1058

1 impacts, to issue a permit that says Energy Fuels has

2 met all the requirements and now there are no longer

3 any safety concerns? I think that's ridiculous.

4 Everywhere and anywhere there has been uranium mining

5 and milling, there have been tragic consequences for

6 human beings exposed to radioactivity. There is

7 nothing safe about radioactivity, period.

8 Has the CDPHE done long-term health

9 studies on the effects of radioactivity? There's no

10 need to. The results are well documented in the

11 literature. So why, then, is the CDPHE charged by

12 the state with granting a permit when it knows it

13 cannot guarantee the health and welfare of the

14 citizens it is meant to protect? To give its

15 citizens a feeling of security because it is the

16 CDPHE who is issuing the permit, I believe if the

17 CDPHE was to truly establish requirements for there

18 not to be long-term health impacts on its citizens,

19 then it would not be ever profitable to engage in

20 uranium mining or milling. Instead, the CDPHE has

21 established a reasonable standard of safety. So then

22 who is reasonably safe, and who isn't? From a health

23 impact perspective, I believe that the permitting

24 process is irrevocably flawed.

25 So in conclusion, my two reasons for



1059

1 asking that a permit not be granted to Energy Fuels

2 are, number one, because during the life of the

3 aforementioned mill, there would be a historical

4 probability of radioactivity groundwater

5 contaminating water supplies due to a systemic

6 failure; and second, that the CDPHE should not be

7 permitting a uranium mill when there are too many

8 documented health risks associated with this kind of

9 toxic and incredibly dangerous enterprise.

10 Thank you very much for your time.

11 HEARING OFFICER: Thank you. Noalani

12 Terry. How close did I get on that?

13 MS. TERRY: Very good. My name is Noalani

14 Terry. I'm from Montrose, Colorado. On a personal

15 level, I am especially concerned about uranium

16 particles and other toxins released in mining and

17 milling that can contaminate my neighborhood. And we

18 have terrible winds over there. And over the last

19 weekend we had wind, and you could see the wind

20 across different parts. And a lot of that comes from

21 this area. It can contaminate my neighborhood, my

22 house, car, garden, and irrigation ditch and carry

23 that pollution all the way downstream or downwind.

24 I believe the mission of the Colorado

25 Department of Public Health and Environment is to



1060

1 protect public health, not promote corporate wealth.

2 I am not against corporate wealth if it is used for

3 the public good, but I see a pattern that is very

4 disturbing. First of all, CDPHE nursed Energy Fuels

5 through a flawed permitting process which included an

6 Energy Fuels witness who called himself a health

7 physicist, stating uranium never hurt anyone.

8 Second, CDPHE has shown no leadership when

9 it comes to making sure the national gas industry

10 takes measures to protect Colorado citizens from the

11 ravages of fracking and the contamination it has

12 introduced to our rivers, air, soil, and wildlife in

13 addition to noise and light pollution severely

14 affecting the well-being, quality of life, and

15 property values of those who lived near those

16 operations before they were leased.

17 Third, CDPHE is now part of a misguided

18 nationwide effort to forcefully vaccinate our

19 children and our healthcare workers for influenza and

20 other diseases without considering the many poisons

21 such as formaldehyde, aluminum, MSG, and mercury,

22 often in quantities far above toxic doses, used as

23 preservatives in a typical immunization. The

24 cumulative effects of these neurotoxins include

25 mental as well as physical impairments and have been



1061

1 linked to such conditions as autism and Alzheimer's

2 disease. Fine print in the descriptive literature

3 for flu shots provided by the manufacturers states

4 that no studies have been made as to possible

5 carcinogenic or fertility effects and also that in

6 many cases, if not most, they are not effective in

7 protecting the persons vaccinated.

8 In every instance, there are foreign or

9 multinational corporations, particularly those in the

10 energy, biotechnology, and pharmaceutical industries,

11 who think they are persons making big money and

12 controlling government decision-makers while making

13 real people sick. They may provide a few jobs along

14 the way, but this is not government for the people,

15 of the people, and by the people. I oppose the

16 permitting of Pinon Ridge mill until CDPHE and Energy

17 Fuels can prove its safety, preferably using the

18 precautionary principle which means they must prove

19 no harm, not wait for people to be harmed.


21 HEARING OFFICER: Randy Parker.

22 MR. PARKER: Good morning. My name is

23 Randy Parker, and I'm a full-time resident of Ouray

24 County, and I oppose the granting of this license.

25 I'll limit my comments to two points. One, the



1062

1 inadequacy of the risk assessment being relied upon,

2 and two, the woefully inadequate bond to cover the

3 cost of financial cleanup. First, in my opinion, the

4 risk assessment which is being relied upon by the

5 Colorado Department of Health and Environment fails

6 to adequately consider the more than half century of

7 boom/bust uranium mining and milling in this region,

8 including the well documented history of

9 contamination. Colorado regulators have consistently

10 failed to prevent this contamination which has

11 required Colorado taxpayers to spend more than a

12 billion dollars cleaning up uranium mills.

13 It's my understanding that the cost of

14 cleanup at the nearby Naturita mill is approximately

15 85 million. And the Uravan mill is now designated a

16 Superfund site, and the cost for that cleanup is

17 120 million. Across the Uravan Mineral District, a

18 significant number of uranium companies have gone

19 bankrupt, leaving the communities in this region in a

20 worse position than before they began their

21 operation. If the Pinon Ridge mill follows this

22 historic pattern and operates only intermittently, it

23 is likely that large stockpiles of uranium ore will

24 be stored on-site for years, releasing radioactive

25 material into the environment.



1063

1 The history of this industry in our region

2 tells us that when the uranium market is at its

3 weakest, the risk to our environment is significantly

4 higher. Regular maintenance may be deferred because

5 of lack of revenue in these periods. Secondary

6 containment systems may begin to be neglected. And

7 all of this could be occurring when there are fewer

8 people present to monitor these systems. This

9 economic reality in my opinion was not adequately

10 considered when the mill's environmental assessment

11 impact was done, and therefore that assessment is

12 inadequate and should be a basis for denying the

13 issuance of this license.

14 I believe that the proposed $11 million

15 bond for the final cleanup is inadequate.

16 Apparently, arguably, even the applicant recognized

17 this was inadequate. And when San Miguel County

18 settled with them, they proposed to increase the bond

19 to 15 million. I'm concerned that if the operator of

20 the mill, whoever that might be, goes out of business

21 that the bond will not be sufficient to pay for the

22 actual decontamination and decommissioning costs and

23 will not cover the cost of long-term monitoring and

24 care for the mill site. If the history of uranium

25 milling in Colorado is an accurate predictor, it



1064

1 seems likely that the owner or operator of the mill

2 will walk away and leave you and I, the taxpayers,

3 responsible for paying the bulk of these costs.

4 While I recognize that the Department of

5 Health may feel constrained by certain formulas in

6 its regulations with respect to the bonding, I

7 believe that their mission of protecting your health

8 and my health and the environment of this region and

9 the state of Colorado should take precedence. If

10 they feel constrained by those current regulations,

11 they should delay the application until a formula can

12 be developed that adequately protects the taxpayers

13 and residents of the state of Colorado.

14 Thank you for taking the time to listen.

15 And please consider this application carefully and

16 either deny it in its entirety or impose sufficient

17 conditions that will protect both the environment of

18 our state and the health of those of us who live

19 here. Thank you.

20 HEARING OFFICER: Thank you. Jennifer

21 Thurston.

22 MS. THURSTON: Good morning. I want to

23 just start out by saying thank you, Mr. Dana, and

24 just express how pleased I am to have the opportunity

25 to comment. I really feel that when we're talking



1065

1 about a uranium mill and the type of facility that it

2 is and the return of mining to the Uravan Mineral

3 District, we must have an absolute transparent and

4 open process. And I have, in the past, felt

5 frustrated with the Colorado Department of Public

6 Health and Environment's record on transparency and

7 openness. But I feel grateful, by reason of Court

8 order, to have the opportunity to speak today.

9 One thing that I feel very strongly is

10 that the State Health Department needs the consent of

11 the people in order to issue a license, and I don't

12 feel that that consent has been achieved, something

13 that will be expressed in greater detail in written

14 comments that will be submitted to you behalf of the

15 organization that I work for, The Information Network

16 for Responsible Mining, and many other regional

17 conservation groups in this area that are not parties

18 to this process but are still fully in support of the

19 parties and are opposed to the licensing of the mill.

20 I want to talk to you, however, from the

21 perspective of a private citizen, my personal

22 comments and my deep history in this region as a

23 resident of San Miguel County. I grew up here. I am

24 deeply distressed by the fact that there are already

25 social impacts here, and the mill has not even been



1066

1 licensed or built. We used to be friends and

2 neighbors, all up and down the San Miguel River, and

3 today we're divided. We are already feeling it.

4 Just the idea of this mill has ripped into our social

5 fabric.

6 One of the problems with that is that the

7 mill is entirely speculative. I don't really believe

8 that we should be building a facility of this type

9 based purely on speculation. Ultimately I don't

10 think that the market's going to allow for the

11 development and the active use of this mill. I think

12 Energy Fuels is going to have to turn to waste

13 processing. And in fact, they already have. They

14 made a big announcement in October, perhaps you're

15 aware, of closing down the remaining mines in this

16 region and turning its focus towards processing

17 alternate waste at the White Mesa mill in Blanding,

18 which it acquired June 29th, this summer.

19 That's a major shift in business, and I do

20 think it's one of the flaws in the state's analysis.

21 It has not really been updated over the past couple

22 of years and most recently, in the past few months,

23 looked at the really significant developments of

24 Energy Fuels. It is not the same company that it was

25 when it submitted this application in 2009. It's now



1067

1 the largest uranium producer, conventional uranium

2 producer in the Western United States. It owns many

3 more properties. And the white elephant in the room,

4 of course, is that it owns another mill, and that

5 really decreases the need for the Pinon Ridge mill.

6 None of these issues were really updated in the

7 State's analysis, and I think that's a great flaw of

8 the process.

9 Energy Fuels has also made a big shift in

10 its mining emphasis and is now directing its efforts

11 towards developing its very much higher grade ore

12 deposits in Northern Arizona. But they're smaller,

13 and they're essentially the lower hanging fruit, and

14 that's their focus now. I don't believe that it ever

15 has been or will be the mines in Western Colorado.

16 One of the other major problems with the

17 socioeconomic analysis undertaken by the state was

18 the failure to recognize the boom and bust nature and

19 the intermittent nature of operations and to analyze

20 the socioeconomic benefits of the mill while assuming

21 that it would run 24/7 over a lifetime of 40 years,

22 despite the lessons of history that show us that

23 that's never happened and unlikely to occur again.

24 Another problem I think is with the

25 cumulative environmental analysis that's been taken.



1068

1 Adjacent to the mill site there's an open pit mine

2 that is exempt from all federal regulations for radon

3 emissions. Directly above the mill site there's six

4 Department of Energy lease tracts that converge. And

5 should the mill open, those lease tracts are likely

6 to become productive again. And those mines are also

7 exempt from radon emissions at the federal level. So

8 none of these cumulative impacts have been taken into

9 consideration.

10 Another reason why I feel that it's flawed

11 is the final construction designs for the Pinon Ridge

12 mill have not been submitted. I wonder if they're to

13 be approved later how the public is going to

14 participate in looking at those. I feel that the

15 public participation aspect of it is extraordinarily

16 important because, again, I believe strongly that the

17 state must have permission of the people in order to

18 license a facility of this type.

19 I think that it's often beneficial to

20 compare what happens at the other operating mills. I

21 realize that there's not a requirement in the

22 Colorado Radiation Control Act that says that we

23 should take the broad view and examine the record of

24 what's going on in these other places. In Canon City

25 we know that it is a very troubled mill, and the



1069

1 State's oversight is deeply flawed. There is a

2 difficult and entrenched and fraught relationship

3 with the citizens of that community that have been

4 affected by that mill. And the situation, despite

5 20 years of effort, seems to have only gotten worse

6 in terms of the environmental impact and impact to

7 people.

8 At the White Mesa mill in Blanding, they

9 had an unreported air release that sent up a dark

10 orange plume above the mill in March of this year.

11 It was several months before Energy Fuels took over

12 ownership of the facility. But the management of the

13 facility has not changed. And that air release,

14 whatever it was, was not reported to the state

15 authorities in Utah, and it's still under

16 investigation.

17 Since Energy Fuels did take over the White

18 Mesa mill there's been one inspection by MSHA, the

19 Mine Safety and Health Administration, that occurred

20 on August 28th of this year. There were nine

21 citations. That's typical. There were frequently

22 citations when it was still just the Denison mill.

23 Those citations that racked up $13,000 in fines

24 included violations of occupational laws to protect

25 the safety and health of workers including violations



1070

1 for clean and orderly conditions, safety of high

2 pressure hoses, functioning of safety equipment on

3 mobile equipment and trucks, safety defects in

4 machinery, electrical conduits, electrical equipment,

5 and junction boxes.

6 Unfortunately, the pattern of letting the

7 small stuff go is really why we have the uranium

8 legacy that we have today in Colorado. So I would

9 submit that the pattern seems to be repeating itself

10 and not much has changed. I want to keep my remarks

11 brief, but just in closing I want to say that

12 unfortunately, as citizens we cannot really count on

13 enforcement of the law. We cannot count on the

14 Colorado Department of Public Health and Environment

15 to protect us, and we can't count on a corporation

16 that's subject to a need to make a profit and is

17 pressured by the market to protect us. Thank you.

18 HEARING OFFICER: Sue Husch.

19 MS. HUSCH: Thank you. My name Sue Husch,

20 I live in Ridgway, and I own a small business there.

21 But I lived in Moab, Utah in the late 1909s. I

22 learned quite a bit about uranium and uranium

23 tailings in my years in Moab. The Atlas uranium mill

24 tailings pile began to be deposited in the mid 1950s

25 and ended when the mill closed in 1984. After many



1071

1 years of requests, research, and planning, the

2 cleanup finally began in 2009. Because of what I've

3 learned about Atlas, I'm very concerned about the

4 Energy Fuels application. The main areas of interest

5 for me are the environment and jobs. Energy Fuels of

6 Canada is not a local company. They will come here

7 to take resources, make money, and leave. They have

8 no concern about what's left behind because they

9 won't be here. And they will not be available to

10 address the future health and welfare of the

11 employees who helped them make that money.

12 The current bond required of Energy Fuels

13 is a fraction of what potential cleanup costs would

14 be. Too times we've seen these companies leave town

15 or, worse, shut their doors completely, leaving the

16 local ones to deal with the aftermath. The leftover

17 hazardous material is only one portion of my concern.

18 The transporting of nuclear materials affects all of

19 us in this region as the trucks pass near rivers and

20 residences through several cities and counties

21 en route to their final designations.

22 Because I don't write nearly as well as a

23 songwriter, I'd like to submit the lyrics from Cosy

24 Sheridan's song written about the Atlas tailings pile

25 called "Don't Go in the Water" as part of my



1072

1 comments. But I'd like to highlight a few lines for

2 you here: "They closed the mine in this town. It

3 made uranium. They left the tailings in a pile where

4 the river bends. Now the Colorado curves in a

5 poisonous smile. Don't go in the water down below

6 the pile."

7 It goes to say: "Take a big, long drink

8 of this acceptable risk. You're down below the

9 bottom line of their cost analysis. It costs too

10 much to clean, too much to move it. It's somebody's

11 fault, but it costs too much to prove it. So we'll

12 cover it up, hope it goes away in a while with the

13 water down below the pile."

14 As we see currently in our local area,

15 these tailings do not go away. They must be dealt

16 with safely and permanently by skilled workers under

17 strict conditions as airborne and water borne

18 particles can be more dangerous than leaving

19 materials in place.

20 I understand that more than 100 well

21 paying jobs could be created by putting local

22 residents to work cleaning up the existing nuclear

23 waste in this area. If reclaimed land can be used to

24 erect solar farms, even more clean, permanent energy

25 jobs will be created, and more unpolluted land can be



1073

1 saved for other uses. To me these options would be

2 much more of an investment in our collective future,

3 as well as allowing the creation of private industry

4 jobs, than making more waste. I hope to leave a

5 legacy of productive farmland, beautiful, scenic

6 areas, clean water and clean air. I am not

7 comfortable with telling the kids and grandkids of

8 this region it's their responsibility to figure out

9 how to clean up the tailings, that it's up to them to

10 assume the health risks, whether stored or moved, of

11 these wastes, and that they must pay for it all, too.

12 Please deny Energy Fuels' application.

13 They and we all, including CDPHE, must have better

14 plans in place before anything like this is allowed

15 to move forward. Thank you so much for your time and

16 attention during this important process.

17 HEARING OFFICER: Mr. Rogers. What's your

18 first name, Mr. Rogers?

19 MR. ROGERS: Don.

20 HEARING OFFICER: I'm just having a little

21 trouble with your handwriting.

22 MR. ROGERS: Good morning, Your Honor and

23 everyone. Thanks for listening and considering

24 everyone's comments here today. I want to start off

25 by saying I'm really aware of the need for jobs in



1074

1 this area. And there's a lot of expertise in the

2 uranium industry here so my hope would be that jobs

3 could be created in the remediation area rather than

4 creating more toxic waste to be dealt with down the

5 line. And I oppose the Pinon Ridge mill for several

6 reasons. Among the many concerns I have about this

7 proposed mill is the almost certain toxic effects of

8 any uranium mill on the water supply. First, the

9 water that will be required to operate the mill.

10 According to the hydrogeologic report from

11 Golder Associates in 2009, the mill will require

12 144 gallons per minute to sustain operations,

13 including 3 gallons a minute of potable water. The

14 only water sources available in the immediate area

15 are the Chinle-Moenkopi aquifer underlying the site

16 and the San Miguel River near Naturita. Although

17 Golder Associates has stated the on-site aquifer is

18 estimated to be capable of delivering 100 to

19 175 gallons per minute sustainability, this estimate

20 appears really overly optimistic due to the low

21 recharge of this aquifer. And there's some technical

22 reasons why that recharge is low, and I think you

23 probably have seen that information so I won't go

24 into that.

25 It appears that Energy Fuels and their



1075

1 contractor, Golder Associates, have not adequately

2 addressed questions of the water supply over the

3 proposed 40-year life of the mill. It's not

4 unreasonable to assume that due to the low recharge

5 rate, this aquifer will provide only a fraction of

6 the nonpotable water requirement for the mill. If

7 this is the case, more water will be needed to be

8 obtained than the proposed 104 gallons per minute

9 contingency water supply from the San Miguel River

10 at Naturita. Obtaining this necessary water may

11 become problematic, especially in times of drought

12 conditions, and of course considering senior water

13 rights on the Naturita. And that would lead us to be

14 worried about how things would be cleaned up when the

15 water supply got tight.

16 And then second is the contamination to

17 the water due to the mill operations. The mill, of

18 course, is 6 or 7 miles from the Delores River, and

19 the Delores River base is just a treasured landscape

20 in Western Colorado. It would be criminal to pollute

21 this area, and no sane person would risk

22 contaminating this treasure forever with a high risk

23 scheme to make some money. You would only do that if

24 you didn't live here.

25 Undeniably, contaminated shallow



1076

1 groundwater is a common occurrence at mill sites.

2 Even if tailings impoundments and evaporation ponds

3 are lined. Energy Fuels has not acknowledged this

4 fact in their proposal, and they have not designed

5 any site-wide leak detection and confinement systems.

6 Based on the history of other mill sites, containment

7 leaking and releases are a certainty at this mill.

8 Also, we still don't know the design of

9 the tailings containments at this mill, and the CDPHE

10 is apparently willing to permit the mill without this

11 information. It is likely that if the designs prove

12 to be faulty, as many of the existing cells are, the

13 DOE will not take title to these materials, and the

14 maintenance responsibilities and all the costs

15 associated with them will translate by title to the

16 State of Colorado, meaning the taxpayers of this

17 state would be paying for the cleanup. This is a

18 fairly certain ending for this.

19 And I'm also greatly concerned that any

20 groundwater contamination from the proposed tailings

21 piles will eventually flow to the Delores and

22 Colorado Rivers. And this, of course, will

23 contaminate drinking water downstream essentially

24 forever. And I don't know what lawsuits that might

25 bring to the State of Colorado, but I would assume



1077

1 many. And, of course, this will affect the people

2 both in Colorado and that are neighbors across the

3 border downstream forever.

4 And so I think this is a badly planned

5 mill, with a faultily assessed licensing process, and

6 I would urge you to not just ask for changes but to

7 deny the operation of the mill at all. Thank you.

8 HEARING OFFICER: Katie Kemper.

9 MS. KEMPER: My name is Katie Kemper.

10 Today I am going to read into the record a letter

11 that my life partner, Robyn Cascade, wrote. And she

12 says, I am a resident and homeowner in Ridgway,

13 Colorado located west of the proposed Pinon Ridge

14 uranium mill. I am deeply concerned about the likely

15 negative impact to human health and the natural

16 environment if this project is approved. Scientific

17 data shows that water and soils in the vicinity of

18 uranium development in the West End and in Canon City

19 are contaminated. Both the Uravan Superfund site and

20 the Bull Canyon Mines southwest of Naturita continue

21 to release hazardous materials. The Delores River is

22 already contaminated due to these operations, and the

23 Bull Canyon Mine is currently in violation of state

24 and federal clean water standards.

25 The Cotter uranium mill Superfund site is



1078

1 yet another example of poor management of hazardous

2 waste and an inadequate cleanup process. To this

3 date, taxpayers have already paid over $1.1 billion

4 attempting to clean up uranium mills in Colorado. I

5 am unequivocally opposed to new uranium development

6 when the record of current and past operations is so

7 dismal and distressing.

8 Furthermore, the CDPHE's approach to

9 regulating and monitoring these mining and mill

10 operations has been totally inadequate. Why license

11 new facilities when corporations, owners, and

12 regulatory agencies have yet to clean up the existing

13 polluted sites or determine ways to operate that

14 ensure protection of natural resources and human

15 health? Those of us who live in this region are well

16 aware of the wind patterns in our mountains. Every

17 winter and spring we see the red rock dust from the

18 west descend on our snowcapped peaks. Our

19 observations are supported by scientific evidence.

20 Any airborne hazardous particles from Pinon Ridge

21 mill -- and there will be some -- will travel with

22 these winds and deposit hazardous particulate matter

23 in our mountains whose water and snow melt is our

24 source of drinking water.

25 I moved to this region in the second



1079

1 half-century of my life because of the healthy

2 environment and natural beauty. I am gravely

3 concerned about the possible effects of the Pinon

4 Ridge mill on our region's potable waters and the

5 waters that irrigate our farms and support our

6 ecosystems. It is not acceptable to me that human

7 health and the health of our natural resources be

8 jeopardized for the extraction and processing of a

9 product that has marginal economic advantage in a

10 region that has prospered from local businesses and

11 industries promoting recreation, tourism,

12 sustainability, and local economies.

13 Judge Dana, there are so many more

14 arguments against licensing Pinon Ridge mill, among

15 them the transportation of hazardous materials to and

16 from the mill such as sulfuric acid and uranium ore

17 and yellowcake; the risk of Pinon Ridge accepting

18 radioactive waste from other sites since the

19 prohibition of this activity expires in 2014 and

20 since history of such operations has proven that

21 uranium mills are not profitable unless they process

22 alternate feed material; the excessive use of

23 300 gallons of water per minute from the Delores

24 River to process ore when our western region has been

25 suffering from extreme drought and extensive



1080

1 wildfires; and the proposed 80 acres of tailings and

2 evaporation ponds that will remain radioactive for

3 800,000 years and be separated from the environment

4 by two thin layers of plastic that history has proven

5 are insufficient methods of containment over time.

6 Every mill that has operated in Colorado

7 has a documented record of contamination, and state

8 regulators have failed in every instance to prevent

9 or remedy it. The real and proven legacy of uranium

10 is one of human devastation, environmental

11 contamination, and economic collapse. We on the

12 Western Slope know we have better alternatives for

13 our land, water, and communities. I urge you to do

14 everything within your authority to stop the process

15 that would lead to the licensing of the Pinon Ridge

16 mill. Thank you so much for your consideration and

17 service. Respectfully, Robyn Cascade.

18 HEARING OFFICER: Tom McKenner.

19 MR. McKENNER: Good morning, Your Honor.

20 I appreciate this opportunity. I wish I had your

21 job.

22 HEARING OFFICER: So do I.

23 MR. McKENNER: I'd like to talk to you

24 this morning about the logic that eludes me. And

25 this has nothing to do with my written statement.



1081

1 This is just one single part of that written

2 statement. I'm going to couch this in three separate

3 concepts with a conclusion. The number one concept

4 is risk analysis. Risk analysis should cover the

5 length of the potential risk. When society and man

6 have a very serious risk, they usually talk in terms

7 of, well, what are the potential problems in

8 100 years, in 100-year occurrences. Well, it just so

9 turns out that uranium has a life of approximately

10 800,000 years, which a little math will tell you

11 means that there are 8,000 100-year risks to look at.

12 And I'm not sure when we start looking at uranium

13 like any other metal, base metals, gold, silver,

14 zinc, lead, other things that we deal with, it's not

15 the same animal.

16 Number two is arc of devastation. Arc of

17 devastation is the amount of land that's disturbed.

18 And I'd like to just list a sliver of that arc of

19 devastation. Uravan, Union Carbide; Canon City,

20 Cotter Corporation; Moab and Mexican Hat, Atlas

21 Metals; Durango, Vanadium Corporation; Lay and May

22 Bell, Union Carbide, Shattuck in Denver. These are

23 just milling and -- milling things that are the

24 result of milling operations. This is not to mention

25 hundreds -- it might be thousands, but I know



1082

1 hundreds is true -- hundreds of mines. This is just

2 a small snapshot of our historic footprint.

3 Number three is the advancement in

4 technology. Technology is making current best

5 practices obsolete in almost every science and

6 industry today. And as time moves on, this becomes

7 faster and faster. Changes are rapid. This permit

8 application is three years old right now. I have no

9 idea when, if this application is going to be acted

10 upon, a mill is going to be built. You know,

11 assuming it might be several years from now -- you

12 know, technology has changed in the past three years.

13 And I promise you that we, as logical people, have to

14 admit that in three, five, seven years, 10 years,

15 whatever it is, it's going to go farther yet. I

16 think that we like the mill designed and based on the

17 best practices and the highest technology of the time

18 that this mill is actually built and started to be

19 operating.

20 And finally, the logic that eludes me.

21 There is no indication that this mill is needed. The

22 demand is down. The price is down. We have a mill.

23 It is not at capacity. It is not being run by best

24 practices nor any state of the art. I am asking that

25 the application be denied until four things happen:



1083

1 Number one, until adequate alternatives have been

2 looked at, which I do not believe is in the

3 application. I don't think that the application

4 should be considered until White Mesa is running at

5 capacity and in a state-of-the-art and best practices

6 manner. That's number two.

7 Number three, I think we need to wait

8 until we know who exactly is making the application

9 for this. Three years ago -- I don't think that the

10 company that is here today is the same company that

11 was here three years ago. And I'm totally confused,

12 as a member of the public, who -- is it Energy Fuels,

13 Denison International Uranium, Energy Fuels

14 Incorporated, Energy Fuels Resources? It's not clear

15 to me, and I think that before this application would

16 even be considered that we should know who it is and

17 what the corporate structure is.

18 And the other final thing is I ask that

19 this application be denied and not considered until

20 it's ready to be built and we know what that state of

21 the art is. Thank you.

22 HEARING OFFICER: Just so you-all

23 understand, it's much easier for the court reporter

24 if she has your written comments to then go back and

25 try to make sure she got down what you said orally



1084

1 correctly.

2 Marvin Ballantyne.

3 MR. BALLANTYNE: You already have a copy

4 of my written report, and I have a copy that's much

5 bigger print. My name is Marv Ballantyne. I'm from

6 Montrose. And thank you, Judge Dana, for allowing us

7 time to speak here today. I am sensitive to the lack

8 of jobs in the Nucla/Naturita area, but there have

9 been no uranium milling jobs and few mining jobs here

10 since about 1980. There have been jobs in

11 reclamation, and there's more opportunity in that

12 area. But people should not hold out for uranium

13 mining or milling jobs because it may never come.

14 According to experts and as stated by

15 Energy Fuels, the market for uranium is too low for a

16 mill to be profitable at this time. The outlook for

17 the future looks like demand for uranium may even go

18 lower. And there are other places in the world on

19 this continent and in the United States where higher

20 grade uranium deposits are available and can be mined

21 and milled at a much lower cost than here. Also,

22 uranium for power plants can be replaced by thorium,

23 which is much less dangerous, not to mention solar

24 power and wind power.

25 Paradox is a beautiful place. I think I'm



1085

1 missing a page here. Here it is. The Paradox Valley

2 is the wrong place for a uranium mill. No railroad

3 is available. The Pinon Ridge site would be accessed

4 by narrow highways, winding along streams and rivers.

5 The highways here have a high rate of accidents for

6 the amount of traffic, and risk of contamination in

7 waterways is high not only for yellowcake but also

8 for acids and other chemicals which would be trucked

9 here.

10 Paradox is a beautiful place which would

11 be intolerably degraded by a uranium mill. While the

12 mill may bring a few permanent jobs but no stable

13 jobs to the area, the mill would damage opportunities

14 for a growing tourism, recreation, and agricultural

15 economy that now exists. The stigma of a uranium

16 mill could severely damage property values in the

17 region. Dust from spills and from normal operations

18 could pollute air, water, and soil for dozens of

19 miles, contaminating the Ophir, Telluride, Ridgway,

20 and Montrose areas.

21 I attended hearings in Montrose where the

22 county was asked for a special use permit to allow

23 the mill as industrial use in agricultural zoning.

24 Many of us were extremely aggrieved that the special

25 use permit was approved, but we were somewhat



1086

1 appeased when several conditions were applied to the

2 permit. Among the 19 conditions I would like to draw

3 your attention to three in particular. Condition

4 No. 7, which is on Page 3 of the document, states

5 that the permit should become null and void if

6 processing of ore has not commenced within seven

7 years of the county commissioner approval. That

8 would be September 30, 2016, which is less than four

9 years from today.

10 Since Energy Fuels has stated that they

11 are closing some mines in the area and will use the

12 White Mesa mill instead and they have announced that

13 they will not start construction on the Pinon Ridge

14 mill until the uranium market improves, it appears

15 that the September 2016 deadline for production is

16 unlikely to be met. By that time there will likely

17 be new federal regulations in place including new EPA

18 regulations for air quality which are now being

19 determined. Therefore, this permit application

20 should be denied so that when and if built, the mill

21 would at least be confirming to regulations current

22 at the time of construction.

23 Condition No. 10 requires that only raw,

24 unprocessed ore may be processed at the mill and that

25 no other feedstock or waste shall be processed or



1087

1 disposed of at the facility. I understand that

2 Mr. Tarlton of the CDPHE has already suggested that

3 the state would like to invite Energy Fuels to

4 process alternate feedstocks, especially, quote,

5 water treatment residues at the mill. This would be

6 an affront to Montrose County citizens who are

7 relying on the conditions imposed by their county

8 board of commissioners. The raw ore requirement

9 should be upheld.

10 Condition No. 18 limits processing of ore

11 to 500 tons per day on an annual average. The permit

12 application and statements by Montrose county

13 commissioners have suggested near-term plans to

14 increase production to a thousand tons a day. And I

15 believe the facility design is intended to allow

16 production at a rate much higher than 500 tons on a

17 single day. That would exacerbate the boom/bust

18 nature of the plant by allowing higher daily

19 production when uranium prices are relatively high,

20 then shutting down as prices decline, while

21 maintaining an average daily rate of 500 tons per

22 day. The CDPHE should limit the design of the plant

23 to allow production of only 500 tons on any given

24 day, not an annual average.

25 I think one of the most important reasons



1088

1 for denying the permit at this time is that the mill

2 is very unlikely to be built in the near future. I

3 think the only reason Energy Fuels is pursuing the

4 permit now is to enhance their corporate stock and

5 possibly to extend the life of their own jobs as

6 promotors. If the permit is issued, the stigma of a

7 uranium mill continues to detract from economic

8 drivers in the region and diminishes the value of

9 living here. It also erroneously encourages

10 residents of the Nucla/Naturita area to wait around

11 for a job related to mining or milling.

12 Something that aggravates me immensely is

13 that in anticipation of the mill, Montrose county

14 commissioners have already spent over $1,100,000 of

15 taxpayer money to obtain conditional water rights.

16 According to their statements, the water rights will

17 be used to provide for as much as a thousand tons per

18 day processing at the Pinon Ridge mill and something

19 like 4,000 tons in other mills, plus allowing for

20 other commercial, industrial, and population growth

21 in the area which they think would be sure to follow.

22 One final thing that I must say is that I

23 am dismayed by the process in which the CDPHE

24 considers and improves applications such as this.

25 The state employees work side by side with the



1089

1 applicant -- in this case, I believe for a few

2 years -- until they work out a permit application

3 they think they can defend. Because of the

4 relationship that developed over time, it is probably

5 human nature to become friends with employees of

6 Energy Fuels. Then a favorable bias sneaks into the

7 process of permit approval. Also, moving a permit

8 along through the process to construction and

9 operation actually would help ensure employment of

10 the very people who have the obligation to deny

11 inadequate or inappropriate permitting.

12 HEARING OFFICER: Jennifer Parker.

13 MS. PARKER: My name is Jennifer Parker,

14 and I'm a full-time resident of Ridgway, Colorado. I

15 appreciate the opportunity to speak to you today,

16 Judge, and I also appreciate the remarks of those who

17 have come before me, as they make it possible to make

18 my remarks briefer. I believe that the Energy Fuels

19 application is inadequate. I understand the

20 importance of this mill and its jobs to many people

21 here. I respect that need, but I also know that the

22 mission statement of the CDPHE is to protect and

23 preserve the health and environment of the state and

24 the people of Colorado. I do not believe that all of

25 the threats to our health, the environment, and the



1090

1 concern for our safety have been fully addressed by

2 the CDPHE.

3 Of further concern to me is the cost of

4 cleanup, should this mill fail. It is my

5 understanding that as long go as 1974, according to

6 the Nuclear Regulation Commission, that the average

7 cost of cleanup of a uranium operation was

8 $143 million. With a bond to cover the mitigation of

9 this mill set at 11 million and later amended to

10 15 million, I can only say this makes no sense to me.

11 I strongly urge that you recommend that this

12 application be denied. And you have my letter

13 already.

14 HEARING OFFICER: Okay. I have it in the

15 written comments, don't I?

16 MS. PARKER: Yes.

17 HEARING OFFICER: Okay. So for the

18 benefit of counsel, I have a number of written

19 comments I've received over time from a number of the

20 people who have either previously or anticipate

21 giving me oral comments. And you can get those when

22 I get it finished.

23 Lois Dunn.

24 MS. DUNN: Good morning, Judge, and

25 everyone here. Thank you for holding this hearing in



1091

1 Western Colorado. There have been a number of

2 opportunities for public input in the last few years.

3 I respectfully ask that you review yet again the

4 findings of the Colorado Department of Public Health

5 and Environment. This department worked closely with

6 Energy Fuels throughout the process to assure an

7 updated, safe project that does not harm air, water,

8 or quality of life in Colorado. This site in Paradox

9 Valley assures no groundwater will be harmed.

10 The process Energy Fuels seeks to use is a

11 far and distant change from the milling of the '50s

12 and '60s. As in every area in the United States,

13 great strides have been made in technology and

14 safety. Great stress is placed on not harming

15 citizens and not harming the environment.

16 Energy Fuels has agreed to a $15 million

17 bond for the final cleanup of Pinon Ridge mill.

18 There can be no comparison of this updated technology

19 to that of the past that caused the cost of cleanup

20 of mill tailings and waste in Western Colorado and

21 Eastern Utah. There won't be seepage of waste into

22 the groundwater, the rivers, and soils. Awareness,

23 plus sealing techniques, are much greater.

24 The Pinon Ridge mill will soon be

25 economical when the USA's supplies of uranium from



1092

1 Russia are no longer available. With 20 percent of

2 our energy from nuclear plants, we will soon find the

3 need for a domestic supply. There are currently four

4 new nuclear plants coming online in the United

5 States. Our production from one domestic mill is now

6 4 tons per year, while the demand is for 50 tons per

7 year. Once a nuclear plant is online, it is the

8 cleanest and most reasonable source of power. Being

9 in litigation for years before allowing a mill or

10 nuclear plant to be built is a huge driver in making

11 the cost astronomical.

12 From Western Colorado we look forward to

13 the approximate 85 jobs at the mill, two to three

14 hundred jobs in mining, and even more during the

15 construction period. A new process called ablation

16 is in early development. This process will remove

17 most of the unwanted material from uranium. The

18 process is done with water and sands. No acid or

19 other chemicals are needed. This enables processing

20 of low grade materials and makes the entire milling

21 process much more economical, plus much less material

22 to transport to mills.

23 We hear the words biodiversity with

24 respect to quality of life for people. I

25 respectfully submit that jobs and the economy for a



1093

1 clean, well planned energy source is also quality of

2 life for us all. I'm a native of Western Colorado, I

3 live and work in the Grand Junction area, and I ask

4 that you consider the permit to be reinstated. Thank

5 you.

6 HEARING OFFICER: Wayne Quade.

7 MR. QUADE: I just have a few comments I

8 might like to add, just for the record. I've just

9 got a few notes here for your consideration. The

10 main concerns that I might bring up are that we

11 use -- revolve around best practices and ecosystem

12 shift. In regard to best practices, we want to make

13 sure that they're continually updated and not locked

14 in by past requirements, so if we could get some

15 language that requires it to be updated regularly to

16 include the best current practices.

17 And then as far as ecosystem shift, I have

18 a concern, that being how water availability is

19 always going to be a big problem. As ecosystem shift

20 changes and starts shifting northerly, this is going

21 to be more and more of a dry area, and water will

22 continually be a problem. And maybe related to that,

23 too, as things dry up in states like Texas and

24 California, more folks probably will be moving to

25 where there's -- up to this area, and water will



1094

1 continually be a further problem.

2 And then also I have a concern with more

3 winds due to climate change. As climate changes,

4 we're seeing more dynamics in the atmosphere, and

5 we're going to see more effects of wind. And that

6 could have a -- that should be a consideration. And

7 then also the law of thermodynamics -- and this is

8 down the road -- requires that -- it states that any

9 energy released adds to the global warming. And so

10 that's where we need to work, with natural systems,

11 rather than releasing energy that's already locked

12 up. Thanks.

13 HEARING OFFICER: Karen Sjoberg.

14 MS. SJOBERG: I have been following the

15 development of the proposed Pinon Ridge uranium mill

16 for four years now, I think. Based on the high risk

17 factors the project presents, I urge you, Judge Dana,

18 to recommend that CDPHE deny Energy Fuels'

19 application. I've lived in Colorado all my life and

20 currently reside in Grand Junction. I love the

21 state, and part of the reason I'm here is because I

22 care for the future of this beautiful place. I've

23 watched as communities argued and fought over water

24 use and preservation issues. This past year's

25 drought brought home just how precious this resource



1095

1 is to our lives.

2 My understanding is that Energy Fuels has

3 not properly addressed pressing questions about

4 whether there is enough water to both process uranium

5 and keep the dust from tailings piles in check from

6 the communities downwind. Since we cannot predict

7 future rainwater amounts, it seems intrinsically

8 wrong to me that vast amounts of water are being

9 proposed for use at the proposed mill unless we can

10 receive an absolute guarantee that there will be

11 enough clean, safe drinking water for us and for our

12 children.

13 Only a denial of Energy Fuels' license is

14 in the interest of public safety, which should be the

15 foremost consideration in a department that's name

16 indicates public safety and environment as its

17 primary objective. Water is just one of the many

18 questions being raised surrounding the mill. If

19 scientists and experts in the field are seriously

20 questioning the regulatory procedures regarding the

21 licensing of this mill, how can the CDPHE go forward?

22 Why did the CDPHE deem a public hearing was not

23 necessary in the first place, when this is a required

24 procedure? I believe the CDPHE ought to have the

25 utmost regard for public input as they consider the



1096

1 application of a project that will for thousands of

2 years leave its mark on our irreplaceable water,

3 land, air, human health, and wildlife. Thank you.

4 HEARING OFFICER: Bob Roberts.

5 MR. ROBERTS: Your Honor, ladies and

6 gentlemen, thank you. This refers to some of the

7 stuff that happened on Saturday. There was a

8 question about retention ponds that goes into water

9 usage, aquifers, et cetera. Now, a retention pond --

10 the subject came up about it being an environment.

11 It's a man-made environment. It would be regulated

12 according to CDPHE regs, et cetera, as to how it was

13 built, how it was created, how it was maintained.

14 It's not a naturally occurring thing. The retention

15 pond would also be used as a portion of the milling

16 process, which means there wouldn't be as much raw

17 water being brought up from the aquifer, from the

18 rivers, and it would be reprocessed on a regular

19 basis. There would be a minimal amount of water

20 coming back into the system.

21 Let's see. As far as the negative effects

22 of any radiation or exposure, it's a given fact that

23 radiation, except in certain instances, requires

24 long-term exposure for health effects. There is

25 radioactive contamination present naturally



1097

1 everywhere in Colorado water at one level or another.

2 So it doesn't matter where you live. You're going to

3 get some. And I think that Energy Fuels and history,

4 in particular, has given Energy Fuels enough

5 information on how to protect that resource from

6 being contaminated. They'll make sure it's clean

7 when it leaves the plant.

8 Now, the safety issues, I would assume

9 that all the safety requirements as indicated by law

10 have been met in the permitting process by Energy

11 Fuels. Otherwise, the permit wouldn't have even

12 gotten this far.

13 I personally feel there's been a little

14 bit too many segues into politically motivated issues

15 as far as the comments have been so far. People have

16 come here from all over the area, all over

17 Southwestern Colorado to speak out against this mill.

18 And in the majority of cases, it doesn't have any

19 direct impact on them. It's the people that live

20 here that are going to feel the impact. We do agree,

21 we do understand, that yes, this is a boom/bust type

22 of enterprise. We also realize that it could be in

23 three months or it could be in 18 months that this

24 mill begins construction. We are willing to wait.

25 We're not here waiting for the mill. We're not stuck



1098

1 here, hoping that the mill's going to start so that

2 we can have jobs.

3 We work. We love the area. That's why

4 we're here. We trust Energy Fuels to maintain the

5 safety and health standards that have been imposed

6 upon them by the EPA, by CDPHE, by the Department of

7 Energy, by the people in the area that say, you know,

8 we really want this, but we don't want to end up like

9 we did in the past. We don't want people getting

10 sick because of this. And I think we'd be more

11 against it if we felt that Energy Fuels was not

12 complying with standards and updating safety

13 regulations on a regular basis.

14 Now, evolving safety considerations --

15 there have to be evolving safety considerations as

16 time goes on and new information is gathered on how

17 to more adequately maintain safety. For instance,

18 the EPA, there was discussion just a minute ago about

19 the 100-year plan on safety for the uranium tailings

20 piles or for the processing or for just the health of

21 the land. It's my understanding that EPA has a

22 1,000-year plan, which I'm sure none of us are going

23 to be here to see the end of. But this is based on

24 history, not personal feelings, but actual scientific

25 study.



1099

1 There's been a whole lot of discussion

2 about how there's a history of bad things happening

3 with uranium mills throughout the state, throughout

4 the country, throughout the world, whatever. The

5 point is, we learn from history. Those who do not

6 study history are doomed to repeat it, period. So

7 isn't it logical that they would take all of the bad

8 things that happened and ask, how do we prevent that

9 from happening again?

10 There was a statement made about various

11 areas surrounding the mill site being exempted from

12 federal regulations. There's some specificity there.

13 They've been exempted from federal regulations, which

14 means the state has recourse. They are the ones that

15 can go in and say, No, you can't do that. That's

16 where CDPHE comes in, and I'm sure that they have

17 looked into it.

18 A statement was made about a marginal

19 economical advantage of having uranium processing

20 here. Uranium and various radioactive isotopes from

21 the radioactive ore processing are used in all kinds

22 of -- for instance, medical purposes such as radio

23 imaging, x-rays, MRIs, et cetera. They use

24 radioactive isotopes in cancer treatment. Think of

25 all the peripheral jobs this one mill will create.



1100

1 They're not going to end up just having uranium ore.

2 They're not going to end up just having yellowcake.

3 I'm sure there's a market for some of the other

4 materials that are gained through the processing.

5 I'd also like to know -- although it's

6 really not my right to ask -- how many of the people

7 present that are actually giving these statements

8 have a background or are professionals or experts in

9 milling of any type. How many are experts in

10 processing anything requiring milling of this type?

11 All this is opinion. It's all based on what you find

12 on the Internet, what people tell you. You need to

13 investigate this as widely as possible. Don't just

14 take what you read or what you hear at face value.

15 Talk to Energy Fuels. Talk to them in person. Ask

16 them, What are you doing. Ask CDPHE, What are you

17 doing. Don't just go on hearsay.

18 A question came up about clean energy,

19 wind farms, solar farms, et cetera, et cetera. Yes,

20 those are clean energy. No, they're not economical.

21 Nuclear energy is economical because it takes less

22 fuel to create more energy in a contained

23 environment. There was a discussion of jobs, work in

24 the area again. Everybody's coming here and trying

25 to shoot down the mill saying it's not going to



1101

1 create enough jobs, it's going to destroy the

2 environment. I have yet to see any of the folks here

3 or anybody from their area bringing anything into

4 this community, Nucla or Naturita, making

5 investments, bringing in businesses, coming down and

6 talking to people and saying, Hey, let us help you

7 create an industry.

8 I see folks coming down here and

9 complaining about this, how it's going to destroy the

10 environment. And yet a large percentage of the

11 people in this room live in communities that ship

12 their trash to a site about eight miles from us. One

13 community in particular sends the solid waste from

14 their sewage, for lack of better words, out to a

15 location just north of us to spread out on the

16 ground. I don't hear any complaints about that.

17 That seems a little bit more toxic than some dirt out

18 of the ground, guys.

19 The dump out there, that's not all going

20 to go away in under a hundred years. A lot of it's

21 not going to go away in a thousand years. And guess

22 what. It's going to keep on growing, and it didn't

23 start here to begin with. So if you want to complain

24 about polluting the environment, why don't you figure

25 out a better way for you guys to get rid of your



1102

1 trash and sewage than dumping it on us.

2 I appreciate everybody's opinions,

3 everybody's comments. I do support the mill. I

4 believe in free enterprise. I believe that this is

5 one way to help this community prosper. It did in

6 the past, and it will in the future. I believe that

7 the safety considerations that have been brought up

8 by CDPHE by history are what is going to control

9 Energy Fuels in the future as far as how they run

10 their mill. And I guess that's going to end my

11 statement, Your Honor. Thank you, ladies and

12 gentlemen. Have a good day.

13 HEARING OFFICER: Betsy Bair.

14 MS. BAIR: Thanks, Your Honor. I'm Betsy

15 Bair. I'm with the Grand Junction Area Chamber of

16 Commerce. We have about a thousand business members

17 with the chamber, and 80 percent of them are small

18 employers, with 10 employees or less. And our board

19 is a cross representation of our membership, and they

20 have created a resolution in support of the Pinon

21 Ridge mill. And they've done that for quite a few

22 reasons. I'm only going to highlight a few for time

23 constraints today.

24 Our board understands that worldwide

25 demand for uranium is expected to rise quickly as



1103

1 countries around the world construct facilities that

2 will produce clean, low-carbon, nuclear energy.

3 Currently 20 percent of the United States' energy

4 comes nuclear energy. And we have a demand for

5 clean, base-load fuels, and so we need to look at

6 those as we move forward. Several new U.S. reactors

7 are in various stages of planning and permitting

8 currently in the U.S. Mesa County contains large,

9 valuable deposits of uranium ore, but there are few

10 uranium facilities where this ore can now be

11 processed. Part of that modern technology and

12 stringent federal, state, and local regulations

13 ensure that uranium mining, processing, and

14 transportation can occur without causing any

15 detrimental impact to mill workers, members of the

16 public, or the environment, including water, air, and

17 wildlife.

18 And further, we have 9 percent

19 unemployment in Western Colorado right now. That's

20 huge. A renewed uranium industry in Western Colorado

21 will produce a number of important direct and

22 indirect economic benefits for Grand Junction, Mesa

23 County, and the Western Slope, including business

24 development, substantial new sources of local and

25 state tax revenues, job creation, including many high



1104

1 salaries, direct careers with benefits. We estimate

2 that about a thousand jobs will come to the Western

3 Slope if the Pinon Ridge mill is approved; not just

4 local jobs, but secondary jobs, as well. And that

5 has a great financial impact and economic benefit for

6 our region.

7 We keep hearing that jobs are not that

8 important. Current best practices show that this can

9 be done in a manner that shows that Energy Fuels are

10 good stewards over the land. But these jobs are just

11 so important to our region, and the economic benefit

12 is tenfold. For every $1 that comes, $3 will stay

13 and be generated in our local economy. And we ask

14 that you look at all of those reasons to approve the

15 mill. We have comments that we've submitted, written

16 comments, but you're welcome to my notes if you'd

17 like them. Thanks for allowing us to be here.

18 HEARING OFFICER: Janet Johnson.

19 MS. JOHNSON: Thank you, Your Honor. I

20 deeply appreciate the opportunity to be here. It's a

21 wonderful opportunity and a rare opportunity when the

22 public really has -- the stakeholders really have a

23 chance to come together and work with this issue.

24 The proposed Pinon Ridge uranium mill

25 could easily harm our water, our air, our lands. And



1105

1 our quality of life that's developed regionally since

2 the last uranium bust 35 years ago. I feel every

3 Coloradan has the right and the responsibility to

4 protect all of our critical resources. I will admit

5 that my perceptions about the proposal are based on a

6 layperson's lived experience with the uranium

7 industry and a common sense approach. I grew up in

8 Grand Junction, Colorado during what we call the

9 uranium boom, but really it was a government

10 procurement program, likely never to be repeated

11 again.

12 The price of uranium was fixed by the

13 government's need for uranium for the Cold War

14 effort. Even as a child, I understood that. It was

15 not a market commodity at that time. The real legacy

16 as we found of the Cold War driven uranium

17 procurement program and the subsequent bust has been

18 one of human devastation, serious radioactive

19 environmental contamination, economic collapse, and

20 continued public financial responsibility for a

21 deadly industry. I will admit that when I was

22 growing up in Grand Junction, I attended schools that

23 had uranium tailings in the schools. I graduated

24 from Grand Junction High School when they were taking

25 the tailings out from under the high school.



1106

1 Subsequently I learned to put the puzzle

2 pieces together. We all have from our class. By the

3 time of our tenth reunion, we had classmates with

4 children born with leukemia who were dead by that

5 time, classmates with children born with birth

6 defects. These children were not born in Grand

7 Junction, but the parents had lived there. I will

8 admit also that my brother worked three summers on

9 John Brown Mesa at the mine. He was supposed to be a

10 gofer, but these were summers between law school.

11 And he died when he was 53 years old of an illness

12 that would be compensated through the RECA

13 compensation, were he alive today.

14 In the past we saw the former mills on the

15 Uravan Mineral Belt destroyed and buried, but the

16 soils were not completely reclaimed for unrestricted

17 use as described in Section 18.8.6 of the rules and

18 regulations pertaining to radiation control of the

19 CDPHE. The waters at each site were not cleaned but

20 placed on a 100-year natural attenuation plan. The

21 reclamation efforts at the mills cost Colorado

22 taxpayers over $1 billion, and they were really just

23 base costs. Because as we knows, these costs are

24 continuous to the present, and they promise to remain

25 with us into the future.



1107

1 Most of the uranium mill owners completely

2 defaulted. The Naturita mill cost the taxpayers.

3 $86 million to reclaim, and the soils are still

4 dangerously hot. And also, according to the DOE

5 monitoring report, there are radioactive water

6 emissions into the San Miguel River. The Grand

7 Junction uranium mill was also a complete default

8 costing taxpayers $504 million to reclaim, and the

9 waters were not cleaned at that site.

10 The uranium bust following the end of the

11 procurement program and brief financial boom and bust

12 in the early 1980s has left some areas in the region

13 broken economically, while other towns have been able

14 to recover and move on mainly because of radioactive

15 reclamation efforts and diversification in their

16 economies. Our uranium past in many ways is our

17 present as we see massive amounts of waste either at

18 the 1,300 unremediated mine sites on the Uravan

19 Mineral Belt, at our former mill sites, and in our

20 radioactive storage sites. Our waters are

21 contaminated as the DOE is now experimenting with

22 methods for cleanup rather than the natural

23 attenuation that has failed.

24 We're witnessing at present the gross

25 inadequacies in the industry and regulatory agencies



1108

1 at the Cotter mill closure in Canon City. We have

2 seen patterns of illness in towns line Monticello and

3 towns like Uravan that no longer exist, including

4 many cancer patients in our former uranium mill,

5 mine, and transport workers. In Grand Junction we

6 passed billboards this morning when we left town and

7 we see newspaper advertisements asking for folks to

8 come forward to see if they qualify for help.

9 Killian and Davis in Grand Junction, which

10 is probably one of the most notable firms helping

11 folks receive compensation, has a list of 1,000

12 claimants on their books right now, and it's growing

13 continuously. Many of these pre 1971 folks are

14 qualified for the RECA compensation, and now many

15 others are receiving another compensation program for

16 nuclear reactor workers and other types of radiation

17 exposures. The taxpayer costs on these programs will

18 also continue to mount as more people are making

19 claims.

20 We ache for the folks in this region who

21 would again work in the uranium industry just because

22 there has not been enough economic development to

23 build sustainable income opportunities for them. The

24 costs for all those impacts keep mounting, and they

25 are borne by the public sector and not the companies



1109

1 that long ago were protected by the Price Anderson

2 Act and allowed to move on.

3 Another perplexing situation to the public

4 is that in some areas the soils like at Uravan, the

5 Uravan site, Umetco is now trying to decommission

6 that site and finish up their decommissioning. The

7 soils there in some places have been found to be very

8 hot. They would not meet the lower standard created

9 by the NRC so they asked the NRC for a variance to

10 that standard, an alternate to that standard,

11 increasing the standard so they could go ahead and

12 close their project with some bonding money saved to

13 them. And then the site will be turned over by the

14 state of Colorado to the DOE. Common sense tells me

15 and all of us that that's not a real protection to

16 the environment or a long-term solution to the

17 problem.

18 There is a stigma surrounding our web of

19 radioactive mill, mine, and waste sites that's a

20 reality to the folks in Colorado. We understand that

21 not only is it a perception, but it's an actual

22 physical danger and an economic deal breaker. In

23 Grand Junction it is still possible to purchase a

24 home with mill tailings, unaware of the danger unless

25 your Realtor decides to disclose.



1110

1 Two years ago there was a case in Grand

2 Junction where a family had moved in, had no idea of

3 the uranium industry there, discovered later, as the

4 woman was taking a real estate course, that their

5 home, indeed, had tailings that had not been

6 remediated. At that time they went to the listing

7 agent, the Realtor who had sold them the home. That

8 person had not done the simple step of going to the

9 office in Grand Junction, submitting the address, and

10 asking about the history of the tailings. They had

11 not done that. That's not a law in the state of

12 Colorado. You do not have to disclose it. But the

13 selling agent from another real estate company had

14 not gone down and checked that out either. It is on

15 an honor system with the Realtors in the state,

16 actually. And if they decide to do it, that's

17 important, and the information is passed on.

18 At any rate, the people did sue, and they

19 settled just for the compensation for the actual

20 repair of their home. But they signed a

21 nondisclosure clause. That tells me that the

22 business community in Grand Junction knows very well

23 about the stigma of uranium.

24 In Canon City it is also still possible to

25 buy a property with a radioactively tainted well



1111

1 without disclosure. I understand that in the state

2 of Virginia there's a very, very rich deposit of

3 uranium, which they're hoping to mine. There has

4 been a very long ban against uranium mining in

5 Virginia. So there were stigmas when I was looking

6 into this. There were socioeconomic studies, and

7 they dealt with stigmas. Three of the studies came

8 back saying that people understood that there was a

9 stigma associated and a reality associated with the

10 radioactive industries. Two of them came back not

11 saying that.

12 Three studies that I know of have been

13 done in Colorado where we have much, much experience

14 with the radioactive industry, with nuclear waste,

15 and with nuclear industries. The one in Canon City

16 proved that there would be -- it said 71 percent of

17 the people in Colorado do not want to live in a

18 county where there is a radioactive industry.

19 The Sonoran Institute study provided by

20 Gateway Canyons -- commissioned by Gateway Canyons

21 Resort explained -- or came to the conclusion that --

22 and Gateway Canyons Resort is in Mesa County. It

23 said if uranium mining and milling were to pick up

24 again in this Uravan Mineral Belt, it would indeed

25 hurt their millions of dollars investment. And the



1112

1 Powers report done on behalf of Sheep Mountain

2 Alliance also corroborates that information.

3 In Grand Junction, too, a year ago in the

4 summer, there were 400 truckloads of radioactive

5 waste coming from the Navajo Reservation at Tuba

6 City, Arizona. The Grand Junction tailings site is

7 still open until, I believe, 2017, something like

8 that. Nothing was said. We read nothing about it.

9 It was signed off on by our city and county officials

10 that the DOE would be doing that, making that

11 transfer. But they opened our site to accept waste

12 from another place. I understand very well what that

13 does to a town if we were to know that. It makes us

14 a radioactive waste site.

15 As we know now, the things that we're

16 calling cumulative impact here, the impact in this

17 industry, actually become collateral damage. I would

18 like to look at the Pinon Ridge mill application.

19 But looking from a citizen's perspective at the Pinon

20 Ridge mill application, I would use a quote from

21 Dr. Karl Morgan, an international authority on

22 radioactive induced illnesses of workers on the

23 Manhattan Project. He worked for them for 28 years,

24 and he testified at the Rocky Flats hearings. He

25 said there is no safe level of radiation exposure.



1113

1 There is no such thing as a permissible dose of

2 radiation in a susceptible human. The slightest

3 quantity can be enough to cause cancer. So the

4 question is not what is a safe level. The question

5 is how great is the risk.

6 When we examine Energy Fuels' application

7 and the necessary interaction with CDPHE to regulate

8 and monitor that project, we are considering the risk

9 assessment of the proposal to the potential workers

10 and the public health, environment, transportation,

11 system, and economy. The application to CDPHE seems

12 inadequate when we know that one of the largest risks

13 at a uranium mill are the contamination of air,

14 water, and soils with radioactive particles which can

15 be inhaled, eaten, or drunk and cause internal

16 exposure which can remain active for decades.

17 Safeguards in all areas must be used. The new

18 regulations that we're speaking about, the new

19 safeguards that we're talking about have to be part

20 of the equation.

21 The application is very incomplete without

22 plans to cover the handling of ore stockpile sites,

23 which are significant exposure pathways for windblown

24 particles. At this time there's no evidence in the

25 application of the covering of those. And we know



1114

1 that ore stockpiles can be siting there for quite a

2 while because they do fluctuate with the price of

3 uranium and the product that they're trying to

4 produce.

5 We don't see any provision for

6 stormwaters, and that's a very important part of

7 leaching. It's a very important part of pathways,

8 that the water in the Paradox Valley could become

9 contaminated. We also know from the testimony that

10 we've been hearing in the last few days there's not

11 enough water for the processing of uranium, enough

12 permitted water for the processing of uranium and

13 dust suppression, which is important in this process.

14 The bonding rate is shockingly inadequate

15 for the potential risks involved. And in the first

16 place, the design submitted in the application is

17 incomplete as far as the tailings pond design goes.

18 It would seem impossible to set a financial surety

19 rate on something that is not clearly defined. A

20 geologist explained to me that the formula used to

21 set the bonding rate is an outmoded formula for hard

22 rock mining. This places the taxpayers in the state

23 of Colorado at great financial risk.

24 I think as a citizen that probably the

25 most interesting -- or one of the places that caught



1115

1 my eye on the CDPHE Web site, looking at the Pinon

2 Ridge mill application, was a place called Frequently

3 Asked Questions. Energy Fuels' application and

4 interaction with CDPHE as a result of reading those

5 is very confusing to me, and I have concerns from the

6 CDPHE Web site on the frequently asked questions

7 page. The first question was, What role does the

8 federal government play in this license application

9 process?

10 The answer was, None. Through an

11 agreement with the Nuclear Regulatory Commission, the

12 State of Colorado has sole responsibility for

13 reviewing and approving or denying the license

14 application. I am wondering, then, as a result of

15 that answer, why does the NRC review the state's work

16 if there's no interaction. Is it not reviewed

17 according to federal regulations also? My question

18 would be also why would this exempt the state from

19 federal rules and regulations concerning the

20 radioactive materials. If the state is following its

21 own rules and regulations pertaining to -- the rules

22 and regulations pertaining to the radiation control,

23 why would they completely disregard Section 18.6.1

24 for public meetings? The public has repeatedly ended

25 up paying the bills for mistakes in decision-making



1116

1 when companies have defaulted and should be given

2 status as stakeholders.

3 The next question is, Is an environmental

4 impact statement required?

5 The answer is, No, this is not a federal

6 project. The state will thoroughly review the

7 environmental report contained in the application

8 package to ensure the project is protective of public

9 health and the environment.

10 My question is, the state regulations in

11 Section 18.4.3 say the environmental impact analysis

12 or any part thereof should be compared directly by

13 the department, or the department shall utilize the

14 third-party method set forth in Section 3.13. The

15 EIA seems to be completely based on Energy Fuels'

16 information, from my perspective, and I would like to

17 see what are the examples of the department's work or

18 third-party, independent work on the environmental

19 impact assessment. It appears that the purpose of

20 the analysis is to inform the public about the

21 project and to help CDPHE make a better informed

22 decision on the application. From trying to read it,

23 it appears cursory and incomplete.

24 The next question is, Why isn't the




1117

1 considering the impact of uranium mining and other

2 potential milling operations in this region?

3 The answer is, The CDPHE regulates only

4 the milling process and has no authority over active

5 mines which are regulated by the Division of

6 Reclamation, Mining and Safety. There is no single

7 agency responsible for determining impacts on a

8 regional level. If other radioactive materials

9 applications for mills are received, they will be

10 evaluated individually.

11 I feel like the answer is incongruent to

12 the CDPHE's overall mission statement that says the

13 CDPHE is committed to protecting and preserving the

14 health and environment of the people of Colorado.

15 The role of the department staff is to serve the

16 people of Colorado by providing high quality, cost

17 effective public health and environmental protection

18 services. Past uranium industry impacts and

19 pollution have taught us this mill site is not an

20 island, and the company consistently shouts about the

21 regional impacts it have. It's not comforting to

22 think that CDPHE is not taking many aspects of this

23 application, direct and indirect, into consideration.

24 Next question: Will the mill be allowed

25 to process radioactive waste? Will the mill be



1118

1 allowed to become a disposal site for imported

2 radioactive waste?

3 Answer, No and no. The application

4 specifies that the mill feedstock will be uranium ore

5 and produced water from Energy Fuels' mines. If the

6 application is approved, the mill will not be

7 licensed to process radioactive waste. If approved,

8 the mill will include an on-site disposal facility

9 for waste generated by its operation. The license

10 application does not seek to import outside

11 radioactive materials for disposal.

12 I have listened in on the telephone

13 connection, and I've appreciated that very much. And

14 I question why Mr. Tarlton commented at the hearing

15 the other day, We would like to be able to send water

16 treatment residues to that site. They can be

17 processed the same.

18 He did not want to discuss that Energy

19 Fuels had not applied for that. And yet he did not

20 acknowledge that Montrose County has a condition

21 against that. We know that the Whirlwind mine is

22 full of water at this point, and the water will have

23 to be treated and released into the Delores River.

24 However, I do not think that that is produced water.

25 Mr. Tarlton did not state where the produced water



1119

1 would come from he was referring to.

2 The next question, Who makes the decision

3 to approve or disprove the application?

4 The answer is -- and I could tell that the

5 site is outdated: Phil Egidi will compile the

6 technical review to create the decision document.

7 The recommendation will come from Steve Tarlton,

8 radioactive materials unit leader, and Jennifer Opila

9 for concurrence.

10 I know that Mr. Egidi is no longer with

11 CDPHE. I do not know who his replacement is. It has

12 appeared to us, living in Grand Junction, and to the

13 members of the public that Mr. Egidi had worked with

14 Energy Fuels, walking them through the application

15 process at many points. And I would question that

16 his position as technical reviewer would have been

17 difficult. I think it would have been difficult in

18 an analysis. Why wouldn't other department heads at

19 CDPHE be a part of the team to technically review

20 their aspect of the application and help make

21 recommendations?

22 A uranium mill is an eternal commitment

23 and an indelible impact on the lands, waters,

24 peoples, and economy of an area. It should be an

25 undertaking given the utmost consideration and



1120

1 considerable attention to detail on the part of the

2 applicant and the regulator. The public has not seen

3 this level of professionalism given to this

4 application or its regulatory review. I respectfully

5 request that you recommend the denial of the Pinon

6 Ridge uranium mill application based on the lack of

7 thoroughness of the information and the difficulties

8 of the Colorado Department of Public Health and

9 Environment in processing the application correctly,

10 especially in regards to an adequate EIA and

11 inclusion of the citizens of Colorado. Thank you.

12 HEARING OFFICER: We've been at this for

13 about an hour and 45 minutes. My rear end and the

14 reporter's fingers are both wearing out. We're going

15 to take a 10-minute break.

16 (Recess from 10:26 a.m. to 10:42 a.m.)

17 HEARING OFFICER: John Metcalf.

18 MR. METCALF: My name is John Metcalf. I

19 live in Ridgway, Colorado. We sympathize with those

20 who live in the immediate vicinity who need uranium

21 jobs, but those jobs put our health and environment

22 and economy at risk. The first priority and

23 responsibility of the Colorado Department of Public

24 Health and Environment is public health and safety.

25 Almost everyone is aware of the danger of uranium to



1121

1 and health and human life. Madam Marie Curie, who

2 discovered radioactivity, died of aplastic anemia

3 from exposure to radioactivity. Today men, women,

4 and children who live near or walk on mining lands

5 die of bone, liver, and breast cancer.

6 Since 1990 the United States Department of

7 Justice has paid $1-1/2 billion in compensation to

8 uranium miners, millers, ore transporters and

9 downwinders of nuclear testing. There is not enough

10 money to clean up the contaminated mining lands. The

11 cost of cleaning up just the mills in Colorado ranges

12 from 50 million to 500 million dollars per mill.

13 Today the U.S. government, under the Tri-Party

14 Agreement, spends over $2 billion each and every year

15 cleaning up the Hanford nuclear site in Washington

16 State. Despite these efforts, the underground

17 nuclear contamination is expected to soon reach the

18 Columbia River. That $2 billion annually is our

19 taxpayer money.

20 The health and economic consequences of

21 the uranium industry have been quantified and are

22 staggering. Many members of the public are unaware

23 of all the facts involved. The Colorado Department

24 of Public Health and Environment is charged with

25 knowing the facts and taking the responsibility of



1122

1 protecting the public. They have been negligent.

2 The CDPHE, with all its expertise, has knowingly and

3 intentionally failed in its duties to protect the

4 safety and health of the public. CDPHE has issued a

5 permit to Energy Fuels without requiring any baseline

6 study or monitoring of the radiation that has blown

7 onto our croplands in Paradox Valley, Montrose,

8 Olathe, Delta, Hotchkiss, Paonia, and other areas.

9 We eat those crops.

10 CDPHE's bond requirement for the Energy

11 Fuels mills is wholly inadequate. Liner systems that

12 are known to leak and even designed with the

13 expectation of leaking were approved. The cost of

14 monitoring and the risk of cleanup and remediation

15 over thousands of years cannot be covered by an

16 $11 million bond. The cost to the citizens and

17 taxpayers just for monitoring the Uravan site is

18 $1 million dollar this year. In the event of needing

19 to contain leaks downhill towards the Delores and

20 Colorado Rivers, the costs could easily exceed the

21 bond and would need to be borne by us, the taxpayers.

22 Accidents, man-made and natural, do

23 happen. Witness the two hundred-year events, two of

24 them, that occurred in just the last two years, each

25 flooding parts of the New York City subways and



1123

1 underground. The distance from Fukushima to Tokyo is

2 150 miles. If the wind had happened to have been

3 blowing towards Tokyo at 50 miles per hour, the

4 radiation would have reached Tokyo in just 10 hours.

5 Tokyo, a population area of 35 million people, would

6 have had to have been evacuated and would have been

7 left uninhabitable effectively forever.

8 The United States cannot risk such an

9 accident. It is in the interest of national security

10 to stop nuclear power and this mill. It is in the

11 interest of public health and economic safety to not

12 approve this mill. I thank you for your time.

13 HEARING OFFICER: Jon Esty.

14 MR. ESTY: Good morning, Judge Dana. My

15 name is Jon Esty. I live in Ridgway, and I am here

16 because of my concerns as a resident of Ridgway

17 regarding this Pinon Ridge mill. The mill as built

18 has a potential impact not only on the Paradox Valley

19 but also our community, which is downwind from the

20 mill. I believe that the plan does not adequately

21 protect the Ridgway community from radioactive dust

22 which would be blown in our direction by the

23 prevailing winds from the plant area. Owing to the

24 ongoing low market price of uranium, Energy Fuels

25 tells us that it would process and stockpile the



1124

1 yellowcake ore on its property until such time as the

2 price rises. It is also my understanding that it is

3 possible that the mill could also receive waste

4 uranium from elsewhere around the country which would

5 also be stockpiled on the property to await

6 processing. Evaporation ponds would be used to treat

7 wastewater. And if by some chance water is not

8 available these ponds could also, in turn, be a

9 source of dust.

10 Westerly winds in Ridgway and Ouray County

11 are an almost daily occurrence and are particularly

12 strong in the fall and spring. We have experienced

13 repeated dust storms from the west in the county for

14 over the past four years that I have resided there.

15 Energy Fuels' plan does not adequately address how

16 the yellowcake ore, mine tailings, and the

17 radioactive waste from other sources will be

18 protected from those strong winds. The company needs

19 to provide more specific information to you and to

20 the public as to how it will mitigate the problem and

21 monitor it in coming years during the mill's

22 operation and after it closes.

23 Let me say something about transportation.

24 There is no transportation plan that I was able to

25 see in the plan. Trucks are to come and go from the



1125

1 mill, but there is no statement about preparing first

2 responders, sheriff's department, law officials, law

3 enforcement officials, health departments, and the

4 Department of Transportation in terms of the

5 transportation of those materials. If there's an

6 accident where there needs to be some response to

7 that accident, the local officials have not been

8 briefed, trained, or informed as to how to proceed

9 with the ore that has been spilled. That needs to be

10 in the plan. That needs to be looked at and examined

11 by the health department and needs to be included in

12 the plan for the mill.

13 The $15 million -- other people have

14 mentioned this. But the $15 million that the company

15 wishes to allocate for reclamation efforts is

16 completely inadequate considering the size of the

17 operation and the amount of ore and recycled

18 materials that the mill would process. The numbers

19 should be four or five to six times as high, and it

20 should be indexed to the rate of inflation over the

21 40-year life of the mill.

22 Finally, I'm concerned about the ability

23 of the company to perform even the most limited site

24 mitigation required in the plan because of its poor

25 level of capitalization. This company has never made



1126

1 a profit. It's never paid a dividend. The shares

2 are speculative, so-called penny stocks that trade on

3 the Toronto Exchange. Its closing price this past

4 Friday was 16 cents a share. Financially it's hardly

5 a company which inspires a lot of confidence, let

6 alone one which must deal with the numerous and

7 potentially expensive environmental issues that would

8 be caused by its operations.

9 I mention this for two reasons. One, the

10 company would be inherently motivated to skimp and to

11 cut corners in terms of the required environmental

12 mitigation and requirements. And the other concern

13 is that because of its poor capitalization, the

14 company possibly would be a good candidate for

15 acquisition by another company that has deeper

16 pockets. In that event, I would ask that the

17 regulations and requirements imposed by the health

18 department, that they be specifically required to

19 include any further mine ownership, mill ownership of

20 that property, that it not simply end with Energy

21 Fuels. But a company that has deeper pockets and has

22 the capitalization ability to actually build the mill

23 and operate the mill, that they also be subject to

24 the same rules and regulations that are established

25 in the plan and elsewhere. Thank you.



1127

1 HEARING OFFICER: Kathryn Christianson.

2 MS. CHRISTIAN: My name is Kathryn

3 Christian.

4 HEARING OFFICER: I'm sorry. I

5 mispronounced it.

6 MS. CHRISTIAN: That's fine. I came up

7 from Grand Junction this morning, where I have lived

8 for most of my life. I'll just say briefly I have no

9 notes to hand you so I'll try to speak clearly so you

10 can get it all. I have to say that I am in agreement

11 and sympathy with the concerns that have been

12 expressed here about the state regulatory agency's

13 role in this whole procedure -- it seems a little

14 confused about what its actual role is -- and the

15 incompleteness of the application, too, the lack of

16 definition. So I think the whole process has been

17 premature, actually, and that maybe they ought to all

18 stop and wait until they're actually ready to go into

19 business to make this application.

20 I came here mostly to relay a personal

21 anecdote about this whole thing, growing up in Grand

22 Junction. It was in 1963, January of 1963, when our

23 family moved into our brand-new house in the

24 Redlands, my father's pride and joy that he was able

25 to build this place for his family. And a few years



1128

1 later it became known that uranium tailings had been

2 in the fill dirt for the foundation of this house.

3 And my father, who was a medical physician, became

4 alarmed right away. And we went through the tailings

5 removal process once, and later readings determined

6 that it was still very hot, very hot under there. So

7 another excavation took place, and then a few years

8 later the readings said it was still very hot. And

9 so three separate removal processes were undertaken

10 in that house, and it's still hot.

11 Subsequent owners of that house, the

12 husbands, both of whom were geologists, actually --

13 the first couple that bought the house, the husband,

14 who was a geologist, retired from Union Carbide, I

15 believe, died of cancer in that house. The second

16 couple who bought the house, he also was a retired

17 geologist. And his wife has not succumbed to cancer,

18 but she has been battling it for some time. And he

19 says that the house will always be hot, and there's

20 just no way around that.

21 My older brother at the age of 50 years

22 old died of cancer also. My father experienced some

23 minor cancers, and my mother more recently succumbed

24 to Alzheimer's. I don't know what the radiation

25 readings of that house might have had on her. She



1129

1 was the one who spent the most time in the house,

2 though. So I don't know, but I think the concerns

3 that have been expressed should be very seriously

4 taken. And I thank you.

5 HEARING OFFICER: Angela Hawse.

6 MS. HAWSE: That's a hard one to follow.

7 Thank you, Honorable Judge, for sitting here for so

8 many days and enabling us to speak our perspectives

9 of this. I would like to speak in opposition to the

10 permit for the uranium mill. I believe it poses

11 public health, safety, and environmental concerns far

12 beyond this valley. I live and work in the San Juan

13 Mountains. My home is in Ridgway. I'm a

14 professional mountain and ski guide and make my

15 living here because the area is special, unique, and

16 unrivaled in what it offers. People from all over

17 the world travel here to enjoy the mountains, and the

18 communities benefit from good tourism dollars. And

19 I'm very concerned that the presence of a uranium

20 mill will drive a lot of those people that come here

21 away.

22 I'm intimately involved in our snowpack.

23 I study it as a snow safety professional and guide

24 throughout each winter season. The snowpack I also

25 recognize as a water source that is vital to our



1130

1 region and our western nation's vitality. Every

2 season we experience episodes of dust layers on the

3 snow surface. These dust layers come directly from

4 the fetch area, which is to our west where the

5 prevailing winds blow from. The fetch area includes

6 the Paradox Basin and the proposed site of the

7 uranium mill.

8 And I E-mailed you this. I have an E-mail

9 from the Silverton office of the Colorado Avalanche

10 Information Center that was sent on November 10th

11 this year. They're responsible for public safety and

12 monitoring avalanche conditions on the highways for

13 the Colorado Department of Transportation. It's just

14 a short E-mail but it says, Strong winds out there --

15 because this was the first of our winter storms. The

16 new snow has a distinct dusty, graupel layer mid-pack

17 at Molas and Coal Bank and a little dust visible on

18 Red Mountain Pass.

19 The impacts of this mill would extend far

20 greater than the Paradox Basin for the communities of

21 the Western Slope and Colorado River watersheds. I

22 recognize the need for jobs and know that the

23 communities surrounding the Paradox Basin need work.

24 However, with such high stakes, the risks far

25 outweigh the benefits of so few. With all due



1131

1 respect, I ask that you consider the far-reaching

2 consequences of the mill and the people in this

3 unique place. Thank you.

4 HEARING OFFICER: Dana Ivers.

5 MS. IVERS: Thank you, Your Honor, for

6 sitting for so long and listening to us. I live in

7 the Telluride area. I've been there for 30 some odd

8 years in the Four Corners region. And I feel almost

9 like a foreigner here in Nucla from the energy of the

10 people from Nucla. Because I live in the mountains,

11 and I am -- it's not a me against you or a you

12 against me. It's a we. We're all together in this.

13 We all breathe the same air. We drink the same

14 water. We look at the same beautiful scenery. It's

15 not me against you or you against me. It should be

16 us trying to protect this land. We are stewards of

17 this land. And that's basically my main concern,

18 that we are -- that the CDPHE is not doing their job

19 to protect us, our air, and our water, and our land,

20 which I think is supposed to be the main thrust of

21 their jobs.

22 Every time I see the word "contamination"

23 the adjective that seems to preface it is

24 "inevitable" in relationship to radiation. And I

25 think it has been proven that with all of their



1132

1 skill, it's not a historical problem. It is still a

2 present-day problem. There's still four NPL,

3 National Priorities List, radiation sites on record

4 in Colorado. They were originally listed in the

5 1980s, and they're still on this list, 25 years on

6 this list. And I don't consider that historical. I

7 consider that present-day. And they're still not

8 cleaned up, and all of them have contaminated

9 groundwater. And taken from the Department of

10 Energy's legacy management report, the cleanup cost

11 for Uravan was 120 million. It was 119 million for

12 the cleanup of the Rifle mill, 86 million for the

13 Naturita mill, 50 million for the Slick Rock mill.

14 And you're asking -- the CDPHE is asking for

15 11 million for Pinon Ridge, which makes no sense to

16 me.

17 For what we in this area would receive, we

18 certainly wouldn't receive any monetary gain from the

19 uranium because it's going to Canada. According to

20 the Chamber of Commerce lady, there would be a

21 thousand jobs gained here, which I think is fabulous

22 for these people. But I can't hesitate to tell you

23 the number of jobs that would be lost in my region

24 from the ski industry. Even just a rumor that

25 there's uranium radiated dust on the ski slopes would



1133

1 turn, in my opinion, Telluride, Rico, Placerville,

2 Ridgway, into ghost towns. It's hard enough to get

3 to this area as a tourist, and our economy thrives on

4 tourism. It's hard enough to get here for people

5 that want to come here. If they think that we are

6 radiated, the ski area will be -- it will be vacant.

7 I spend time in Telluride, and I have a

8 condo that overlooks Main Street. And I have seen

9 winters when we had very poor quality snow reported

10 in the media, and Main Street was vacant of people.

11 And all it takes is some report getting out to the

12 world that we have radioactive dust on our ski area,

13 and the thousand jobs that are gained here, tenfold

14 will be lost to the tourism industry, which is a much

15 cleaner industry than the scariness of uranium.

16 Just in closing, my family's been in

17 Colorado since 1850. They started in the mining

18 industry and then moved to farming and ranching. And

19 one of the industries that my family had thriving

20 back in the turn of the century was sugar beets, and

21 it became something that was not viable anymore as

22 cultures changed and people came in and subdivisions

23 came in and there were different activities and

24 socioeconomic activities. And perhaps the people of

25 this area should maybe consider the fact that this is



1134

1 a fossil -- no pun intended -- industry that should

2 not exist anymore in this area because we now have so

3 many more people.

4 When it was the heyday of the uranium

5 activity, there were very few people here. There was

6 not much agriculture, not much ranching. And perhaps

7 these people that really want the mining and the

8 milling should look at their neighbors and at

9 themselves and their children and their grandchildren

10 and consider it an industry that should be left in

11 the ground. The yellow monster, Leetso, as the

12 Navajos call it, should never be taken from the

13 ground. Thank you.

14 HEARING OFFICER: Reed Mitchell.

15 MR. MITCHELL: Good morning. Good turnout

16 today. My name's Reed Mitchell, as you introduced

17 me. I'm a commercial Realtor. I have a residence

18 here. I moved here in 1999. And I had five or six

19 wonderful years among these folks but found it

20 difficult to earn a living. So now I live in Grand

21 Junction, but I kept my home here and move back and

22 forth.

23 I have to say this is kind of like déjà vu

24 all over again. It seems like I stood in front of --

25 I don't know if it was you, but a lot of judges for



1135

1 several hearings a few years ago. I think this whole

2 mill's been beaten to death a few times, and it's

3 still struggling to get down the road. What I have

4 to say is I think CDPHE looked very thoroughly at the

5 original application. There was a tremendous amount

6 of opposition from a lot of folks who didn't take a

7 great deal of time to study what was going on. I

8 think if you equate what's going on today in the

9 mining and milling industry and try to compare that

10 to what happened around here in the '40s and '50s and

11 spread the blanket of doom over our future that

12 occurred as a result of what those goings-ons were,

13 those unregulated goings-on back then, I think you'd

14 have a hard time making a valid comparison.

15 Because this mill, these people, they're

16 going to be scrutinized upside down and inside out as

17 long as they operate, and I think they're going to do

18 a good job. I know these people. Actually, I'm the

19 Realtor that sold them the mill site. When we found

20 the site, we talked to a gentleman from the CDPHE

21 that told us if you can't build it here, you can't

22 build it anywhere in the United States.

23 It's a good site. There's no groundwater

24 issues to deal with. The air's been studied to

25 death. And so anyway I'm not going to filibuster up



1136

1 here. I just want to say that I come out in favor of

2 it. These people want it. The people who live here

3 around it want it. And some folks that come from

4 other places don't have such a high opinion of it,

5 but I guess they're entitled to that. So I hope you

6 have a great deal, and thanks for your time.

7 HEARING OFFICER: Dale Beede.

8 MR. BEEDE: You've had some very eloquent

9 people here. I'm not one of those. I live in Grand

10 Junction. I own some land 2 to 3 miles down the road

11 here. I'm here in front of you just to ask, let

12 Energy Fuels build the mill in the Paradox Valley.

13 Energy Fuels has provided for the state everything

14 that has been asked of them. It modified their

15 existing plans to help alleviate the fears of some of

16 the public over blowing dust, water mitigation, truck

17 traffic, et cetera. They've spent millions of

18 dollars to engineer this mill and now to fight the

19 roadblocks placed in front of them by just a few.

20 The West End needs the construction jobs, the mining

21 jobs, the engineering jobs, the plant operator jobs,

22 the truck driving jobs, and other jobs that will

23 emanate from the construction of the mill. Please

24 approve this mill and let this valley get back to

25 work. Thank you very much.



1137

1 HEARING OFFICER: Joel Dyar.

2 MR. STILLS: Your Honor, can I just have a

3 second? I didn't catch that gentleman's name.

4 HEARING OFFICER: The one before?

5 MR. STILLS: The one that just spoke.

6 HEARING OFFICER: Dale Beede, B-e-e-d-e.

7 MR. STILLS: Okay. Thank you.

8 MR. DYAR: For the record, it's Dyar.

9 HEARING OFFICER: Dyar. Sorry about that.

10 MR. DYAR: No worries. Thank you for the

11 opportunity to speak with you today. I'd like to

12 echo the sentiment this woman expressed that I'm

13 happy that we're able to have this conversation.

14 Thanks for everyone who came out. I'd like to speak

15 to the economic impact of this proposal. And

16 specifically, to use a little metaphor here, we

17 shouldn't burn the furniture to heat the house. For

18 the first time in generations we are seeing a

19 reversal of the outmigration that has depopulated and

20 devastated world communities and economies.

21 Americans, from boomer retirees to young people tired

22 of the mini-mall wastelands of our cities, are voting

23 with their feet and moving back to rural America.

24 From Appalachia to the heartland to the intermountain

25 west, rural areas which offer so-called amenities --



1138

1 landscapes, open land, clean environments, quiet,

2 recreational opportunities, and affordable land for

3 young people interested in farming again -- are

4 growing in both population and economic terms.

5 Migrants to areas like the Western Slope

6 bring purchasing power, they bring talent, education,

7 and expertise in both thriving and emerging

8 industries. And increasingly they bring external

9 salaries with them. Last year over 25 percent of the

10 U.S. workforce performed some work through

11 telecommunication from their home. Over 10 percent

12 telecommuted entirely. These shifting work patterns

13 present opportunities for rural re-invigoration,

14 revival, and economic growth.

15 What these people are not looking for is

16 degraded landscapes, toxic winds, toxic waters, and

17 toxic soils. Even the presence of the possibility of

18 radioactive contamination is enough to disadvantage

19 and spoil an area's ability to capitalize on these

20 emerging trends and make sure that they play a role

21 in our economic developmental strategies and the

22 diversification of those strategies. Western

23 Colorado is blessed with exceptional natural assets

24 with which to develop economically by attracting this

25 new human capital. Unlike the dangerous assets we



1139

1 can remove from the ground here, our amenities, if

2 protected, will never run out. Thank you very much.

3 HEARING OFFICER: Ben Williams.

4 MR. WILLIAMS: Good morning. Thank you

5 for being here, and thanks for hosting this dialog

6 for the past several days, from what I understand.

7 I'm a Norwood resident. My name, again, is Ben

8 Williams. I have a bachelor of science in natural

9 resources management. I've worked for the USDA as a

10 soils scientist, and I'm currently a registered

11 patent agent.

12 I am disappointed with Energy Fuels' level

13 of disclosure throughout this process. I'm not

14 speaking with any notes so I apologize. But

15 essentially, there's been a number of what I feel

16 have been disingenuous statements made. And one of

17 the ones that I would like to discuss today was up at

18 the Norwood Town Hall several years ago when one of

19 the experts that Energy Fuels had brought in stood up

20 and told the people there, You would get 10 times the

21 level of radiation flying on an airplane than you

22 will from this mill.

23 And then he sat down, and everybody seemed

24 to agree. You know, I put my hand up and said, Wait

25 a second. You know, that's not entirely true. It



1140

1 kind of depends on what type of radiation we're

2 discussing here. If you're talking simply wave forms

3 of radiation, then yes. But we're most concerned

4 about alpha emitting radiation, most ionizing form of

5 radiation. It's not very penetrating, but hence the

6 fugitive dust issue.

7 And all he simply said was, Well, that's

8 true.

9 And what I feel is, you know, it's okay to

10 get a C. It's okay to get a passing grade. But when

11 billions of dollars are at stake, when billions of

12 people's -- well, thousands of people's livelihoods

13 are at stake, I think Energy Fuels should surpass.

14 It should strive for excellence. It should inform

15 the public so that they are able to make an informed

16 decision. I don't feel that anybody is capable of

17 really making an informed decision.

18 When you look at the jobs issue, we're

19 talking about a flash in the pan. If this was the

20 boom, the economic boom for this area that these

21 people promise us, how come we're all unemployed now.

22 The uranium business had a seat here for couple of

23 decades at least. Yet we're all out of work. It's a

24 flash in the pan.

25 I refuse to believe that the great spirit



1141

1 of American enterprise is dictated by seeking

2 employment in a Canadian company. I believe the

3 great spirit of American enterprise touches upon

4 developing small business concerns, upon the local

5 area, the assets that we have that, as that gentleman

6 presented earlier, have a long and sustainable

7 future. Twenty years of grinding 100 tons of uranium

8 a day may make a Canadian company and its

9 subsidiaries and a few gentlemen a lot of money. But

10 the legacy that it will leave will cost the taxpayers

11 for generations to come.

12 The reality is that the half-life of the

13 tailings of the milled uranium lasts so long that the

14 very mountains in which we seek to contain them have

15 not existed for less than a thousandth of a percent

16 of that time. What I'm trying to say is the attempt

17 to safely house these sediments is the same as

18 building a sand castle in a river. The very

19 structures in which they will be housed cannot exist

20 as long as the decay of these radionuclides.

21 What I propose is that Energy Fuels seeks

22 to accurately inform and surpass the minimum

23 requirements that the state imposed upon their

24 industry. First of all, I've been told that they

25 have done a very wide-sweeping wind study that



1142

1 demonstrates and models effectively the potential

2 distribution of the fugitive dust that most of us are

3 concerned about around the state. When I drive down

4 through Energy Fuels' 880 acre parcel, I see simply

5 two anemometers, two weather stations that are, at

6 most -- and I'm probably erring on their side here --

7 20 feet above the ground. You cannot generate a

8 statistically relevant wind study with that

9 equipment, two anemometers on 880 acres at 20 feet.

10 If you were to develop a wind study

11 seeking investment for wind power, you would at least

12 need an anemometer that is 100 feet high. You cannot

13 garner the investment dollars. But it seems in the

14 uranium industry you get more investment when the

15 scientific equipment is below the regular standards

16 applied to other industries.

17 The last thing I'd like to say is, I'm not

18 saying that it's deliberately dishonest by Energy

19 Fuels. But I am saying that is, at best, artful and

20 disingenuous and, at worst, irresponsible. I am

21 reminded of when I saw the heads of big tobacco stand

22 before Congress and each of them swear an oath that

23 they believed that tobacco was not addictive. I see

24 the same mentality. These people have every

25 incentive to develop these -- this equipment with the



1143

1 least amount of costs that they can. They have every

2 incentive to underperform the standards just to get

3 it done. And I don't think that they're in a

4 position where they can objectively review the data.

5 I really don't. And I don't think they're in a

6 position where they want to inform people, as I saw

7 with their expert testimony. I did not see people

8 willing and able to inform people. I saw obfuscation

9 and what appeared to me to be deliberate cloudiness.

10 So with that I thank you again for your

11 time. And thank you again, Your Honor.

12 HEARING OFFICER: DeeAnna Burbridge.

13 MS. BURBRIDGE: My name is DeeAnna

14 Burbridge. I'm a 56-year-old white female who lives

15 12 miles east of the old corporate town of Uravan. I

16 moved here in 1977. I ranch there. My husband that

17 I moved here with was a uranium miner. He worked in

18 the JD5 mine out in Paradox. I work in San Miguel

19 County right now as the fair grounds manager. I

20 worked in Uravan for Umetco. I was part of the

21 UMITRA cleanup. Actually, one of my responsibilities

22 was to check the dosimeters of the people that worked

23 there and track those uranium exposure records.

24 I'm not an expert in uranium things. I

25 recently read a book that Tom Zoellner wrote called



1144

1 "Uranium: The Rock That Changed the World." And

2 there's a lot of energy in that little rock. And up

3 until this point in time in the United States, we've

4 tried to figure out how we could use that energy in

5 that little rock. And maybe we didn't do it right

6 before, but we're at a point in time where we've got

7 to figure it out. It's just as bad to fall flat on

8 your face as it is the back of your head. And

9 decisions based in fear are never a good decision.

10 So I support the mill. The local populace

11 here is educated both by experience and technology.

12 I raised my kids here. I watched all of the things

13 that have happened since 1977. When I was in the --

14 I think I was six years old, and I was watching

15 Mickey Mouse on TV. And they talked about this place

16 in the United States called Colorado, specifically

17 this area, and that there was a stuff called uranium

18 where they could do all sorts of wonderful things

19 with this uranium. Well, that's kind of changed

20 somewhat, that aspect from the 1960s. But I also

21 know that if we don't get our ducks in a row and

22 figure it out sooner than some other people figure it

23 out, we're going to be left behind. And we need to

24 figure it out in a responsible, educated manner.

25 I think Energy Fuels has put their hat in



1145

1 the ring and said, Okay, let's start figuring this

2 out. So we need to figure it out. And I don't envy

3 any of the people who are the experts because they're

4 the ones that we're depending on to figure this out

5 for us. So we've got to start finding balance

6 somewhere, and that's why I'm in support of the mill.

7 Thank you.

8 HEARING OFFICER: Dianna Reams.

9 MS. REAMS: My name is Dianna Reams. I'm

10 here today as the president of the Chamber of

11 Commerce for Nucla and Naturita and also as a

12 resident of Naturita. In 2009, about the time that

13 these hearings were starting, the Chamber of Commerce

14 conducted a consumer survey. In that survey there

15 was a simple question: Do you support the Pinon

16 Ridge mill? And this was for our residents here.

17 72 percent said positively yes; 9 percent said yes, I

18 think so; 9 percent could go either way; and 7

19 percent said absolutely not, with one person

20 undecided. That gives us a clear 81 percent support

21 of our residents. I have seen no change in the last

22 three years to that.

23 Yes, this area has been economically

24 depressed for over 30 years. One of the reasons --

25 one of the reasons is because of the loss of the



1146

1 uranium and vanadium industry, both mining and

2 milling. When that industry started here back in the

3 '30s and '40s, it was for vanadium. Uranium was a

4 byproduct. Vanadium also, I believe personally, is

5 going to be the driving ore for this area because it

6 is a primary constituent as a steel hardener as well

7 as vanadium redox batteries, which the renewable

8 energy industry is finding as the only source of

9 long-term storage for solar and wind power. If

10 uranium is again a byproduct I say, Okay. That's

11 fine with me.

12 I don't seem to have a problem with

13 uranium or the nuclear industry. We have nuclear

14 medicine. It does, in fact, help and cure cancers

15 and the things that it's also accused of creating. I

16 know that my dad is 84 years old. My uncle is

17 89 years old. Both of them swam in the mill tailings

18 ponds here because it was the only swimming pool

19 available to them. They took trash can lids and

20 sledded down the yellowcake hills. He's 84, lives

21 alone -- or with my mother and still is able to get

22 about, drive, in very good health for 84 and 89 years

23 old. So, yeah, some people had a problem with it,

24 but I don't think it's overarching.

25 Additionally, this area, Nucla and



1147

1 Naturita, is generational. This is part of our

2 history. Those aren't 20-year people. Those are

3 fourth, fifth, sixth generation families. I

4 personally come from Morris Woods who, with two of

5 his brothers, dammed up the Fall Creek and created

6 Woods Lake, a very nice recreational area still up in

7 the Telluride area. That was my great grandfather.

8 They moved from there to Placerville and

9 ran the blacksmith shop where my grandfather, who was

10 born in Vanadium right across the stream from the old

11 Newmar mill site that's been referenced here. He was

12 born there at home. He learned to be a blacksmith,

13 who later turned into a machinist through the

14 technology era and had a shop in both Grand Junction

15 and Uravan, serving the uranium industry.

16 So I'm fourth generation in this area.

17 The ranchers here are fifth and sixth generation,

18 Paradox ranchers that are supportive that are part of

19 our 81 percent in our survey that don't have a

20 problem with the uranium dust because we recognize

21 that radiation and radon is a naturally occurring

22 element in our area, as it is in Telluride.

23 They have a very high radon levels in the

24 ground in Telluride. The uranium ore that was

25 extracted in the Telluride area, in the Placerville



1148

1 area, was richer than it is here. So I don't doubt

2 that they're a little bit more concerned about radon.

3 They should be. Their own homes are built on a

4 hotter area than we have here.

5 Let's see. As far as the job creation,

6 these are our children and our grandchildren that

7 we're looking for jobs for because we want our

8 families to be able to stay here. When my husband

9 graduated from high school here in 1975, he had

10 72 classmates. My daughter that graduated in 2009

11 had 11. We don't have the ability -- they don't have

12 the choice to move here because we have been unable

13 to spur our economy over the last 30 years.

14 I do not blame Telluride, Moab, Grand

15 Junction, or anybody else for this failing. This is

16 our problem to solve. This is one component that we

17 are looking at to try to solve our economic woes. We

18 do not want just any jobs. As I said, these are our

19 children and our grandchildren. We want good, safe

20 jobs. We believe that the regulatory environment is

21 strong enough. Of course there's always new

22 technology. Of course there's also better ideas. Of

23 course things always improve. That's the way we

24 innovate and have historically forever. It's just

25 the only way that you innovate, is to build on prior



1149

1 knowledge.

2 So we're ready. 81 percent of us say yes,

3 we want to see that. We want to see those jobs come;

4 good, safe jobs that are regulated. I can tell you

5 my background is in construction here. I have a

6 bachelor's degree in business from the University of

7 Montana and master's from Regis University. I work

8 on the other side of the table from Mr. Tarlton and

9 Jennifer Opila, and we've had some fairly lively

10 discussions as a result of that regulatory influence

11 on our business. They're quite thorough. They're

12 quite thorough. And yeah, we meet the minimum

13 standards because, in fact, we're a for profit

14 business. The minimum standards are set as a safe

15 standard based on current knowledge. I think that's

16 adequate. 81 percent of our population agrees with

17 me.

18 We want our families to be able to

19 continue to be generational in this area. Montrose

20 Economic Development Corporation confirmed in prior

21 hearings that we could, in fact, expect upwards of

22 140 jobs both directly and indirectly as a result of

23 this. I get that Moab and Telluride are tourism

24 based. We are not. We are not tourist based. You

25 have to have something to come to, a destination.



1150

1 You have to have services and goods. Currently you

2 can't get breakfast every day of the week here, and

3 you can't get supper every day of the week here. And

4 I haven't seen the people that are participating in

5 these hearings having even their lunch here,

6 participating in our economy. And that's fine. It's

7 their choice. That's the free market. That's what

8 we get. We're good with it.

9 But tourism isn't an option for us. And I

10 don't consider it all that green when you figure out

11 the hotel costs, the additional water for laundry,

12 the food waste out of restaurants, the heat, the

13 wildlife habitat degradation by the second, third,

14 fourth, fifth homes of the wealthy and mighty that

15 are in the Telluride/Moab area. I think that those

16 things need to be looked at as more of an overarching

17 footprint. I don't see tourism happening here. Not

18 that we'd turn it down, but it's just not here. The

19 Ray Motel is not the resort of choice for most

20 people.

21 We are forced currently to commute over

22 four mountain roads. I don't know how many of you

23 have gone up and down Norwood Hill in the wintertime,

24 but it's fairly treacherous. We have mudslides in

25 the spring between Telluride and here. Telluride



1151

1 enjoys a commuting base for workers from Montrose,

2 Norwood, Nucla, Naturita, Egnar, Dove Creek, and

3 Delores, all more than 60 miles away. That's not

4 very green to me.

5 If I understand it correctly, the

6 regulations require that hearings are held and you

7 are required to hear from people within a statutory

8 50-mile radius of the affected area. Most of these

9 folks that you've been listening to are outside of

10 that area, although I personally appreciate their

11 comments because it does, in fact, make a safer

12 industry for my children and grandchildren to work

13 in. I appreciate that and welcome their comments.

14 I also serve on the board of directors for

15 Western Small Miners Association. This is a mining

16 group and extraction and resource development

17 association, private, that serves the Western United

18 States: timber, coal, any type of mining, really, oil

19 and gas. We sat down in Cortez a couple years ago

20 with Hillary White, who's the executive director of

21 Sheep Mountain Alliance; Amber Kelly, the executive

22 director for Citizens Alliance out of Cortez; the

23 Delores County Commissioner, Ernie Williams; and the

24 president of Western Small Miners, John Reams, trying

25 to schedule a meeting with Sheep Mountain Alliance to



1152

1 sit down and Citizens Alliance to sit down and

2 discuss our differences, where we have commonalities,

3 where we can collaborate, where we can join forces,

4 and where we simply are going to agree to disagree.

5 We could not get them to come to the table. It was

6 again offered by Craig Pirazzi, a member of Sheep

7 Mountain Alliance that lives in Paradox. He was

8 certain that the board would be happy to sit down

9 with us. Again, no response.

10 We have reached out to Telluride and Moab.

11 We have tried to talk to the people that are having

12 such a difficult time with us trying to run, operate,

13 and grow our own community. It's just not going to

14 happen. So with that, I would like to offer you

15 81 percent of our population supportive of this mill

16 and these comments for your consideration. Thank you

17 so much.

18 HEARING OFFICER: Sam Silkels. Is Sam

19 Silkels here? Todd Beckley?

20 Okay. Do I have others in the room who

21 would like to make oral comments about this process?

22 AUDIENCE MEMBER: Here's another page.

23 HEARING OFFICER: Okay. They keep sliding

24 in on me. Matt Bane.

25 MR. BANE: I'm a former employee of



1153

1 Denison Mines. I worked in Gyp Valley as an

2 electrician. We opened the La Sal Incline mine and

3 started working there in December of '09. This mine

4 had sat for approximately 20 years, 25 years,

5 building up radon. We worked in the exhaust of this

6 mine. Denison was supposed to do air samples of

7 this. They never did for approximately four months.

8 When they finally did take an air sample, it was

9 twice as high as radon levels was supposed to be.

10 There was guys about this time that was fed up with

11 what Denison Mines was doing. They reported them to

12 MSHA. MSHA did show up and cited Denison Mines for

13 working guys in high radon. Subsequently these guys

14 were laid off. Denison Mines said it was a work

15 reduction layoff.

16 I know from working in the uranium

17 industry that safety and environmental issues don't

18 exist compared to the costs of operation. Denison

19 Mines ignored all safety regulations concerning that.

20 One of them was, we had transformers and switchgear

21 that was from the '50s and '60s. They were supposed

22 to be tested for -- PCB testing. It was a direct

23 order from the top of the mining deal in Dove Creek,

24 to pour this stuff out and put the stickers on

25 without checking it. I personally did this so I know



1154

1 that they will contaminate the environment.

2 I've been diagnosed with -- I have brain

3 damage. I have nerve damage. It affects my cardiac

4 system, pulmonary system, endocrine system, and GI

5 tract. This is new. This was in '09 that this

6 happened. This is not pre '70s, but they run the

7 thing just like it was pre '70s. We have the

8 regulations and rules in place. I'm not for or

9 against this mill. But I believe that somebody has

10 to monitor this really closely and not depend on the

11 government to do it because they won't. MSHA has a

12 long list of fining these guys for high radon, high

13 CO2, high diesel particulate, just one after the

14 other. And it never did ever make them do anything.

15 If they do build the mill here and mining, we need to

16 monitor it extremely close so there won't be guys

17 like me.

18 HEARING OFFICER: Barclay Daranyi.

19 MS. DARANYI: Dear Judge Dana, thank you

20 for the opportunity to comment on Energy Fuels'

21 proposed Pinon Ridge uranium mill in Paradox Valley,

22 Colorado. My husband and I are farmers on Wrights

23 Mesa outside of Norwood, Colorado. Our farm is

24 located approximately 35 miles downwind from the

25 proposed uranium mill. We produce freshly grown,



1155

1 organically grown vegetables for more than 200

2 regional residents through our 68-household CSA

3 Program. And CSA stands for Community Supported

4 Agriculture. We also serve customers at the

5 Telluride and Norwood Farmers Market. We grow a wide

6 assortment of produce. We operate a state-approved

7 processing plant for poultry. We graze grass-fed

8 broilers, turkeys, egg-layers, hogs, goats, and

9 horses.

10 The farm leases 60 of our 100 acres of

11 irrigated pasture to a neighboring rancher for hay

12 and pasture. We've also integrated a bakery into

13 operation, and we're known for our fresh breads and

14 granola. In addition to providing employment for the

15 two of us, my husband and myself, the farm and bakery

16 has an extensive internship program where we train

17 future farmers and hire three full-time employees.

18 We also have eight members of the community that work

19 at the farm in exchange for food on a weekly basis.

20 We have a proven track record of local

21 food production after 10 plus years of operation and

22 have become an integral player in the regional

23 economy. And by regional economy, I think there's a

24 growing economy for local food production. There is

25 nationwide and also statewide. It's been shown that



1156

1 there's more and more of an awareness of where our

2 food comes from, how it's grown, and supporting local

3 farmers like ourselves.

4 We rely on clean air, we rely on clean

5 water, and we're dependent on clean soil to

6 successfully grow healthy food. And I want to

7 emphasize the soil there, too. It's our intention

8 that when we die, we leave our farm and our soil in

9 better shape than how we found it. We want to grow

10 soil, not deplete it.

11 Our sustainability is also dependent on a

12 healthy regional economy and stable regional

13 communities. Put simply, because of serious

14 environmental concerns and uranium's boom/bust

15 legacy, the proposed uranium mill puts at risk the

16 long-term sustainability and resiliency of our farm

17 and bakery. The environmental risks and the negative

18 socioeconomic impacts make this mill a possible

19 threat to our survival.

20 Environmental concerns: Primarily we're

21 concerned about contamination to the air, water, and

22 our soils as a result of uranium milling. Ongoing

23 studies have shown that airborne particulates travel

24 from as far away as 200 miles. In the wintertime

25 dust layers from these airborne particulates can



1157

1 easily be found in the mountain snowpacks. Most of

2 our water, as an aside, for our operation is entirely

3 dependent on snow melt. So we get all of our

4 irrigation through reservoirs that are supplied by

5 the snow melt off the Cone, the Lone Cone Mountain.

6 Uranium radiation has a half-life of

7 thousands of years. If contamination would occur, it

8 cannot be successfully remediated. Our ability to

9 grow food would be crippled in the event of a major

10 wind event, the contamination of our high Alpine

11 basin water sources, or from a catastrophic onsite or

12 transportation accident.

13 Upwind enterprises have no right

14 contaminating the air, water, and soils of downwind

15 neighbors. This is unAmerican and against every

16 citizen's constitutional protections. In practice,

17 contamination from an outgoing source can be

18 considered trespassing on downwind neighbors.

19 Unfortunately, there's little or no recourse for

20 those affected. The legacy of contaminated mining

21 sites in the West is for taxpayers to foot the

22 cleanup bill once the mining companies have declared

23 bankruptcy and moved on.

24 At the same time, we have little

25 confidence in the ability of the Colorado Department



1158

1 of Public Health and Environment to enforce existing

2 rules and regulations with regards to uranium

3 production and milling. History has shown us that

4 the CDPHE is also deficient in providing a thorough

5 review of existing applications, taking into account

6 all of the risks inherent in uranium milling. The

7 record is clear. Uranium is best left in the ground

8 and out of human hands. The Pinon Ridge uranium mill

9 application should be rejected out of hand. Once

10 contamination occurs, it cannot be remediated no

11 matter how stringent the enforcement measures.

12 Socioeconomic concerns: Uranium milling

13 and mining has a legacy of injecting short-term

14 economic gains followed by abandonment when volatile

15 economic conditions turn sour. The long-term

16 economic success of our farm and bakery is dependent

17 on the strength of rural communities and, in

18 particular, our hometown of Norwood. In Norwood this

19 economic strength comes from agriculture. Many of

20 the ranching operations in the mesa have been in

21 existence for over a hundred years. Meanwhile, the

22 regional economy has found strength through tourism.

23 The risk of uranium's environmental contamination and

24 the inherent unstable economic impacts of mining and

25 milling are a real threat to the region's overall



1159

1 economic stability.

2 As taxpayers and American citizens, we

3 believe that the mining and milling of uranium should

4 stand on its own as a viable economic enterprise.

5 Historic records show otherwise. Every aspect of

6 uranium, from milling to mining to nuclear energy

7 production, has relied on taxpayer subsidies for its

8 existence. There's a reason private insurance

9 companies will not insure nuclear power plants.

10 They're rated too dangerous. Uranium is best left in

11 the ground.

12 Moreover, the long-term cleanup costs are

13 always borne by taxpayers. This is another

14 government handout. A direct subsidy to operators of

15 uranium mining, milling, and their employees and

16 subcontractors. CDPHE has required only an

17 $11 million cleanup bond for Energy Fuels' proposed

18 mill. This is laughable. It's far short of the

19 typical price tag for mill cleanup. The nearby

20 Naturita mill cost 85 million. Grand Junction rose

21 above 500 million, and the current estimate to close

22 the Canon City mill is 43 million, which doesn't

23 address groundwater contamination. In sum, Colorado

24 taxpayers have paid over $1 billion for mining and

25 milling cleanups.



1160

1 In summary, every Colorado citizen has a

2 right to clean air, water, and soil. Our farm and

3 bakery is also dependent on a strong regional economy

4 and a clean environment. The proposed Pinon Ridge

5 uranium mill with its inherent boom/bust legacy and

6 its associated environmental risk is anathema to our

7 long-term sustainability. Our ability to grow food

8 for our regional residents is in jeopardy, as is our

9 livelihood. Energy Fuels has no right to trespass on

10 our clean air, water, and soil. Truly, there is no

11 effective way for a regulator to oversee uranium

12 milling. At the same time, taxpayers should not be

13 asked to subsidize the economic foundation upon which

14 the uranium mining and milling industry is dependent.

15 There's no compelling reason to approve the permit

16 for this proposed uranium mill. Thank you for your

17 time and attention to this matter.

18 HEARING OFFICER: Michael Saffler.

19 MR. SAFFLER: My name is Michael Saffler.

20 I've been a resident of this region for almost

21 40 years, and I have attended quite a few of the

22 hearings that have been conducted on the subject in

23 the past. I have not had the time to attend the

24 hearings up until now that are being conducted right

25 now.



1161

1 I found the testimony of the speaker who

2 was up here just prior to Barclay who had actually

3 had experience in this industry to be particularly

4 telling. I have talked to a lot of people in this

5 region over the years and tried to determine whether

6 or not there really is a healthy way to conduct

7 mining and milling of uranium. I've never really

8 been given an answer that there is. In fact, the

9 answer that I typically get is, Well, we have new

10 regulations. And the implication there is that the

11 old regulations did not work. The implications are

12 that, yes, there were some problems in the past, but

13 somehow we're going to do something different that's

14 going to be safer, and that ultimately is going to

15 result in an environment that we all can live in.

16 But that's really not what I am hearing in

17 talking to people, and that's certainly not what the

18 previous testimony said. In fact, it said that the

19 industry does everything that they can to try to

20 minimize the amount that they adhere to their

21 requirements for enforcement and that, in fact, there

22 are definite outcomes that are debilitating to one's

23 health. And those outcomes are not immediately

24 evident. In fact, they can reveal themselves many

25 years down the road.



1162

1 Well, I would like to protect my family

2 from that outcome. And I've never really been given

3 the impression from any elected officials or any of

4 the state agency representatives that I have any way

5 of doing that. In fact, most of the discussion that

6 I've heard and the remediation that has been

7 suggested is that after the fact I may have an

8 opportunity to monitor and discover what radioactive

9 particles have found their way into my air, my water,

10 my food, my environment. And that seems grossly

11 inadequate. That seems to me like the damage has

12 been done. And at best, we can come in after the

13 fact and measure how that damage was done, where that

14 material might have originated, how much of it was in

15 our air or soil, and thereby what? What do we do at

16 that point? How do we protect ourselves? It's too

17 late.

18 People can die, especially children.

19 Children are susceptible to even a single particle.

20 And I'm sure you've heard this a dozen times during

21 this testimony, but even a single particle can get

22 into the lungs of a young person and can metastasize

23 to the point where it kills them. And that's scary

24 to me. Maybe the people on this side of our state

25 feel that that's an acceptable risk, but it's not to



1163

1 me. It's something that scares the daylights out of

2 me. And having lived here for 40 years, I never

3 really considered leaving. I never really considered

4 that I would pick up and take my family out of here.

5 This is the first time. And that's very

6 disappointing because I always thought this was going

7 to be my home until the day that I died because I

8 really do like this region. I really do feel

9 attached to it.

10 And I have tried in very many ways to try

11 to come up with other ways that we can view the

12 economies of this region. And I know that the people

13 who have spoken in favor of this mill who live over

14 here feel like these are the best jobs that are

15 available to them, but they're not the only jobs.

16 And I know they said it's their legacy, but it's not

17 really their original legacy. The original legacy

18 was cooperative farming. Those are the people who

19 settled this valley. Those are the people who lived

20 here. Those are the people who really found this to

21 be an acceptable place. And it was suitable for

22 farming. In fact, it was a good spot for farming.

23 But that's not going to be possible now. As you

24 heard from Barclay, she's very concerned about how

25 she's going to be able to continue to farm in this



1164

1 day and age. And her farm does support a lot of

2 people. It does provide food for an awful lot of

3 people. And those people are probably going to

4 question whether or not they really want to buy food

5 that has been grown out here.

6 The socioeconomic aspect, the Telluride

7 region, San Miguel County, has done a lot to try to

8 not publicize this too much because we are concerned

9 that the world is going to discover that 25 years or

10 more of resistance by communities all over this

11 country to the idea of putting a mill into their

12 community was never found to be an appropriate or

13 appealing way for them to conduct their business to

14 promote their economy. Now this area out here has

15 decided that it is appropriate. This is the one area

16 in this country that has said, okay, we'll take it.

17 But why did those other communities say

18 no? Why has there not been another mill that's

19 cropped up in this country? Why are the Indian

20 reservations having to deal with so much sickness?

21 All those people that were exposed to all that

22 uranium for all those years are now devastated. I

23 mean, you look around, you talk to any of the tribes

24 south of us who have had to deal with uranium, there

25 is sickness throughout and death throughout their



1165

1 communities. And I know some of the elders have been

2 convinced that there might be some economic benefit

3 to them, and there's even been some suggestion that

4 they might allow something like this into their

5 communities. But when I talk to the individuals,

6 talk to the tribe members, they're all frightened to

7 death that this might start up again. They're all

8 frightened that they might be subjected to another

9 round of exposure.

10 As much as I'd love to sympathize with the

11 economic needs of the West End, I just don't see how

12 we can afford to do this again. Uravan was right

13 here. Uravan was a Superfund cleanup site. The

14 people of the United States of America decided that

15 we had problems in this country with environmental

16 pollution. And by an act of Congress -- both houses

17 of Congress when Congress used to talk to each

18 other -- the President signed off on legislation

19 called the Clean Air Act and the Clean Water Act.

20 Those were meant to say to small communities like us,

21 that you can't be run over by large corporations. In

22 fact, we, the federal government, will watch over

23 your environment for you. We will make sure that

24 that doesn't happen again, that your rivers don't

25 ignite and you don't see burning rivers floating by



1166

1 your homes and you don't see Love Canal and you don't

2 see these things again. And they set up agencies

3 that were designed to protect us, including the EPA

4 and the DOE and a lot of the agencies that come into

5 play with this approval.

6 Well, the State of Colorado decided in its

7 questionable wisdom that they wanted to be the

8 enforcers of those regulations. And the State of

9 Colorado gave the authority to the Colorado

10 Department of Public Health and Environment. And


12 has taken on the role that was supposed to have been

13 the role of the Environmental Protection Agency.

14 When I came to initial hearings what I was

15 hearing was the CDPHE was acting as if they were an

16 advocate for the mill. They really weren't

17 addressing the environmental issues that were brought

18 up by the majority of the testimony that was

19 presented to them at that time. I went to

20 Washington, D.C. I talked to people in the EPA. I

21 said, What do we do?

22 They said, You have a problem.

23 I said, Yes, we do have a problem. How do

24 we address it?

25 They said, Well, we really can't talk to



1167

1 you in our offices.

2 I said, You can't talk to me in your

3 offices? What do you mean?

4 They said, We'll meet you after work.

5 So one person who was willing to meet with

6 me actually did. She met with me after work, and she

7 said, You are absolutely correct. There is a problem

8 with the enforcement of the Clean Air Act and the

9 Clean Water Act when it gets down to the local

10 levels. And one of the biggest problems is the

11 states that have taken on this -- have become these

12 agreement states.

13 And I said, Well, what do we do?

14 She said, Well, you have to sue us.

15 I said, Sue you to do your job?

16 She said, Yes.

17 And I said, Well, how do we sue you?

18 She said, Well, I'm not exactly sure

19 either. You have to find some attorneys who are

20 willing to do that.

21 And so I started talking to attorneys.

22 And all the attorneys were concerned about that

23 because a lot of them deal with the state agencies,

24 and they deal with the parties that are supposed to

25 be making these decisions, and they didn't want to go



1168

1 above their heads. And ultimately I guess the NRC

2 got brought into this, which is the reason why you're

3 here today; is that correct?

4 HEARING OFFICER: No. I was selected -- I

5 don't know who nominated me. I was selected I think

6 by agreement of the CDPHE and Energy Fuels. I don't

7 know if Sheep Mountain was in that conversation or

8 not.

9 MR. STILLS: I think it was left to CDPHE,

10 and we were good with that choice.

11 MR. SAFFLER: But I wonder if, in fact,

12 there is -- it was my impression that there was some

13 federal intervention that took place here.

14 HEARING OFFICER: Not for me.

15 MR. SAFFLER: Okay. And who determined

16 that there was an inadequacy of the original

17 hearings?

18 HEARING OFFICER: There was a decision and

19 a lawsuit filed I think by Sheep Mountain Alliance,

20 with Judge McMullen in the Denver District Court,

21 which is where one goes to appeal the state

22 regulatory decision that said, in summary, there had

23 been an inadequate hearing. And so they mandated a

24 public hearing, at which point I received a phone

25 call from CDPHE asking if I would be available to do



1169

1 this hearing. And I do it, candidly, at the expense

2 of Energy Fuels, but that's because the applicant

3 pays the expenses.

4 MR. SAFFLER: I see.

5 HEARING OFFICER: I have to send my bill

6 to Energy Fuels.

7 MR. SAFFLER: And that was a part of the

8 process that seemed a little bit askew to me in the

9 first place. And I didn't realize it was continuing

10 on to today where, in fact, the applicant is the one

11 who pays for the hearings which are supposed to be, I

12 thought, impartial hearings and give an opportunity

13 for the public to express their concerns. And yet

14 the people who the concerns are being expressed to

15 are being paid by the applicant, who is intending to

16 ultimately get an approval. That seems like an

17 imbalance to me. It seems like that's a biased

18 process.

19 HEARING OFFICER: Well, Mr. Saffler, I'm

20 not willing to admit that I come to this with a

21 predisposition because of who's paying my bill.

22 Because I will issue the decision as I see fit to

23 issue the decision. And Energy Fuels will still be

24 expected to pay it, whatever that decision may be.

25 MR. SAFFLER: And I appreciate hearing



1170

1 that from you. And I've been told that about you,

2 and that's the reason why I'm here today despite the

3 fact that I have been concerned about the process all

4 along.

5 HEARING OFFICER: Point taken.

6 MR. SAFFLER: I still don't know what we

7 are supposed to do. I still don't know if we have a

8 legitimate concern about the mill, how we can stop

9 the mill. I still don't know how we can protect our

10 children. I still don't know how, if we have a

11 legitimate case, at the end of the day what that

12 brings about. What outcome we can hope for from

13 presenting our case properly? Is there something

14 that you can do? I've been told that you will make a

15 recommendation back to the CDPHE, and then the CDPHE

16 will have an opportunity to reissue the license. Is

17 that correct?

18 HEARING OFFICER: I'm trying to be very

19 careful not to predispose myself to any particular

20 answer until I've heard all of the evidence.

21 MR. SAFFLER: I understand.

22 HEARING OFFICER: But it seems to me

23 apparent, having heard this now for four days, that I

24 need to do a bit of a civics lesson in how this

25 process works, how it comes about, what gives rise to



1171

1 it, how one can affect it. And when I write a

2 decision, it's probably got to include that. And I'm

3 making notes to that effect as we go along, which is

4 not to say everybody in the room will be happy about

5 it. But it seems to me I need to do some explaining,

6 at least in my opinion about how it works, and then

7 CDPHE will do what it does. And I will tell you

8 candidly, I think the chances of that surviving

9 without another appeal to the Denver District Court

10 is probably about less than 1 percent. I think

11 that's inevitable. So I'm here as a part of the

12 regulatory process, and then it's going to get looked

13 at by the judicial process, if that answers your

14 question.

15 MR. SAFFLER: It does. And I'd like to

16 make another point or two, if I may.

17 HEARING OFFICER: Go right ahead.

18 MR. SAFFLER: It's been brought to my

19 attention that -- I believe it's the Nuclear

20 Regulatory Commission is in the process of

21 reevaluating their standards for not only nuclear

22 power plants but also for uranium mining and mills.

23 And that process has been ongoing for quite a number

24 of years and was ongoing when this application was

25 started. And it seems to me like that should have



1172

1 been an opportunity for the local decision-makers,

2 especially at the state level, to say, well, maybe we

3 should slow down a little bit so that we get the

4 benefit of the bargain with the new regulations which

5 are being considered.

6 And yet it seems just the opposite. It

7 seems like the process was rushed so that those

8 regulations would not be applied toward this mill.

9 And it seems like there's even a national movement

10 that's saying we have problems in the industry, and

11 yet they're basically being shined on. And that

12 really disturbs me because, you know, there are some

13 very smart, very dedicated people who are trying to

14 come up with those new regulations, and they may not

15 even be applicable here.

16 Thank you for your time.

17 HEARING OFFICER: Jolana Vanek.

18 While Ms. Vanek is speaking, is there

19 anybody else in the room -- and I've not yet called

20 on the folks on the telephone -- who wish to make an

21 oral public comment in this process that has not had

22 an opportunity to do so? There's sign-up sheets back

23 by the door.

24 MS. VANEK: I'm Jolana Vanek. I live in

25 San Miguel County, and I have lived here for about



1173

1 18 years. And thank you, Your Honor, for holding

2 these hearings in a proper way because for those of

3 us who have come and spent a lot of our time coming

4 to these meetings, it was very interesting because we

5 were cut always down to three minutes. And we

6 couldn't even -- maybe one person has a minute, and

7 another one would take more. There was none of that,

8 so this is wonderful. I thank you for doing this

9 process in a way that is giving people a chance to

10 give a little more of a background.

11 First of all, I have lived in two

12 continents. I have lived in Europe and here in the

13 United States. And I'd like to address the dear

14 people that I have worked with, people from Nucla,

15 Naturita, from these communities, people from

16 Montrose, as well. We're not always being told the

17 whole truth by those who want to sell us a project.

18 We are not. I recall through my over 3,000 hours

19 that I have spent studying, researching, until 2:00,

20 3:00 o'clock at night, I came across congressional

21 hearing results where a gentleman who was a mining

22 inspector had to testify in front of Congress that he

23 was asked to lie to the employees of the mines he was

24 inspecting in order to obtain access to these mines

25 on private lands.



1174

1 One of the reasons here I was very

2 concerned is because I care about and I work with

3 people who lost their relatives in Uravan. And some

4 of them lost their relatives in the mines. I have a

5 scientific mind. I have scientific training. And my

6 brain works in a way that it holds pieces of info and

7 puts them like a jigsaw puzzle together over many

8 months. And I work with people who would say to me,

9 Four of my relatives are dead through Uravan. Four

10 of my relatives are dead through Uravan.

11 And then I would come to a hearing, and I

12 would hear that absolutely there is no risk from

13 uranium tailings. That was quite puzzling to me. I

14 like math. This just didn't figure out. You hear

15 this is harmless. And then through the Montrose

16 planning process we heard a lot of time spent on

17 chiseling into the rules of the Montrose County

18 decision about who gets compensated and how, when,

19 and if they get contaminated in Paradox Valley.

20 So if there is no contamination -- and

21 actually, I have a gift. If there is no

22 contamination from the substance called yellowcake,

23 it's safe as food, as we have all been told, would

24 anybody like to share some of this (indicating)?

25 It's wonderful. It's just perfect. It's safe. So



1175

1 that's what we are being told. But then we see

2 people being paid by RECA, being compensated for --

3 what is in the professional language -- restitution

4 for working in the industry. So where is the safety

5 in it?

6 So then I started to understand that

7 perhaps when people live near it and they are harmed,

8 they get compensated. But if we live a little bit

9 downwind, how come we are called outsiders? So I

10 would like to offer the good people of Nucla and

11 Naturita -- I have helped people with a ranching

12 operation in another part of the state -- to figure

13 out how to bring tourists and let them tour their

14 cabin industry, you know, results and how to pay for

15 it. I mean, if you keep doing for 30 years what you

16 have been doing and you are still miserable and

17 unsuccessful and unproductive by doing what you have

18 been doing, it might just not be a forever heaven.

19 It might be another boom and a bust. And what then?

20 Another 30 years? Meanwhile, we have people

21 contaminated. We have a whole part of Western

22 Colorado having this dirty industry which really

23 repels tourism from everywhere.

24 So uranium causes genetic damage. It's

25 been known. And I don't know, Your Honor, if you



1176

1 have been privy to a reading, a Uravan case a couple

2 years ago when there was a Uravan case, lawsuit, the

3 Court determined that it could clearly see genetic

4 damage there. But genetic damage under current U.S.

5 laws is not considered a personal injury. So these

6 people were not successful in closing out on what

7 they were suing for. However, what does genetic

8 damage mean? What does it do for us? Birth defects,

9 cancer, inability to learn from one's mistakes, all

10 these are known effects of genetic damage. So when

11 people -- whether they're close to a project or

12 further away, they are subjected to it. It's a real

13 injury to their lifestyle and to their health.

14 Now to this particular process of the

15 Energy Fuels application, and then I will wrap it up.

16 When I came to the very first hearing in the Montrose

17 planning process, I heard from a Frank Filas of

18 Energy Fuels that they now have new state-of-the-art

19 technology that will work differently and also that

20 they have these new leak-proof liners. At the next

21 meeting when the public brought up that these liners

22 leak at the White Mesa mill just across the border in

23 Utah, Frank Filas said verbatim, Of course they leak.

24 They all leak. The big leaks get fixed, and the

25 small ones don't matter.



1177

1 And when the public asked about the small

2 leaks -- because we are always told through the

3 drought, please fix the small leaks on your water

4 tap. It's a hundred gallons a day -- the public was

5 waved to sit down. So there was a very interesting

6 situation.

7 Another member of the public was held by

8 the elbow until they sat down, and this was done by a

9 Montrose police officer. I've never seen anything

10 like that in my life. And it should be on somebody's

11 film. So now we are being told that there is going

12 to be a rigorous, competent oversight by CDPHE. And

13 even though I think that the CDPHE employees are

14 lovely and personable, I have several concerns from

15 the conduct I have witnessed. I have learned that

16 small lack of attention to details often reflect on

17 the whole operation. The noticing process -- which

18 we are here because of lack of proper conduct -- the

19 first announcement of the Energy Fuels process being

20 reviewed, the application being reviewed, a small

21 postcard came in. And there was a wrong link to sign

22 up for automatic notification for all the hearings.

23 So I called up CDPHE and I was told, Oh,

24 it's Murphy Law, wrong link.

25 I understood that. That's normal in life.



1178

1 Sometimes things happen. But I was very concerned

2 when the second postcard that came had the same

3 nonworking link. Why? That was a month later. So

4 when we finally received the E-mail notification,

5 wouldn't you expect that it would say something like

6 CDPHE, Pinon Ridge mill, Energy Fuels? It said, from

7 Deb Shaw about a meeting. I still remember the

8 morning when I sat by my in box and I kept looking at

9 it thinking, Spam. Let's get rid of it. And

10 something in me just said, Maybe I should click on

11 this. And here it was, Energy Fuels conducting a

12 meeting in Montrose, the first of the process.

13 So if we keep hearing about the rigorous

14 oversight, how does this reflect for you, Your Honor,

15 who deals with details in the courtroom all your

16 life? Where are the guaranties?

17 The same thing when I called the very

18 first time CDPHE to inquire about the side effects of

19 uranium tailings, which I have already researched.

20 And Edgar Ethington, who is one of the members of the

21 CDPHE team which is dealing with this application, he

22 very sweetly said to me, Dear, you couldn't find it

23 on our Web site because it doesn't exist. There are

24 no side effects to tailings left over from milling

25 yellowcake.



1179

1 I somehow didn't feel comfortable because

2 my research stated otherwise. I didn't know exactly

3 who this Mr. Edgar Ethington was. I thought he was

4 just an administrator there. I didn't know he was a

5 powerful oversight man. So I went back online, and I

6 researched, and I found a whole page of this. The

7 particles that we are concerned about are the

8 particles that carry by air and the particles that

9 can be breathed in. We are always being patronized

10 and patted on the head by Energy Fuels

11 representatives who say, Oh, this will be safer than

12 flying in an airplane. This will be safer than the

13 fire alarm on your ceiling.

14 I don't breathe the airplane flight.

15 That's a different kind of radiation. So I was very

16 concerned that this information was not known to the

17 person who is now charged with reviewing the

18 application and future oversight. And I was even

19 more concerned when I discovered that that link no

20 longer exists for the Web site. It's been removed.

21 Why? Just because we could learn that there are side

22 effects?

23 All I have to do is read the Montrose

24 paper and find out that there's free healthcare for

25 those who were exposed professionally to uranium. I



1180

1 can drive by Cortez on the back roads and see a giant

2 billboard promoting the same thing. So this, called

3 yellowcake to put everybody into feeling happy,

4 grandma, salivating yellowcake, it's really uranium

5 oxide. And why do we call these mills? They're

6 factories that make uranium oxide. So thank you so

7 much.

8 Sulfuric acid, which is also a part of the

9 pyramid, do you know what that does to the trees that

10 are dying in Colorado right now, the Aspens? It

11 kills trees. And the community in the White Mesa

12 mill has a major problem with their tourism with

13 this. And one of the electricians who worked down

14 there a couple times, he said every piece of metal,

15 hinges, et cetera, is rusted in that area because of

16 the sulfuric acid vapor. And what happens to the

17 people who breathe it?

18 Somewhere in there, in the application, is

19 also a huge amount of radionuclides being permitted

20 to be put into the atmosphere. And radon attaches to

21 uranium clouds. If you can study that, it is in my

22 E-mail. I have actually handed in a full testimony.

23 And if you Google radon attaching to rain clouds,

24 it's amazing what you find. So all of us downwind

25 are subject to this, and we are not outsiders. And



1181

1 I'd be happy to work with anyone from Nucla who wants

2 help with their business because I've done that for

3 30 years.

4 HEARING OFFICER: Is Sam Silkels in the

5 room? Is Todd Beckley in the room? Skip Edwards?

6 MR. EDWARDS: My name is Skip Edwards, and

7 I have lived in the Telluride, Moab, and Durango area

8 since 1981. I originally came from back East and

9 Florida and have found these years to be probably the

10 best years of my life, especially in the line of work

11 I have been in out here, which has been as a BLM

12 river ranger for about 18 years and a river guide,

13 et cetera, et cetera. So I've been in the outdoors,

14 and I totally have loved the pristineness of this

15 area.

16 I also, from my age, I think as the

17 gentleman who testified earlier, having worked in the

18 mines -- I think when we look at these issues, the

19 experience of people and their work, their line of

20 work and what they have learned during those periods

21 of work, it can play a big part in understanding how

22 laws and regulations actually work on the ground. I

23 started out back in -- well, in the '60s and '70s I

24 ended up as a pilot on a C141 for the United States

25 Air Force during the Vietnam days. And I flew as a



1182

1 pilot. I had -- my claim to fame, I think, at least

2 in my memories, was flying to the Soviet Union into

3 Moscow in 1972 as part of the entourage that

4 accompanied Richard Nixon to Moscow for the

5 antiballistic missile talks and the SALT I, Strategic

6 Arms Limitation Talks. That was 1972.

7 And from that I look back and I go,

8 starting back in those years, we were trying to get

9 rid of nuclear weapons. We were trying to bring some

10 sanity into the world. I also worked in a missile

11 silo after I got out of flying at the end of Vietnam

12 and actually had my hands on the keys with another

13 guy of 10 missiles. And with a couple other guys, we

14 could have launched 50 nuclear missiles to the Soviet

15 Union. And the reason I bring this up is not to try

16 to scare people about bombs, which we all should be

17 afraid of them, but to look at what really happens

18 with yellowcake.

19 And from everything that I've been able to

20 learn, reading about uranium, it really -- the value

21 in uranium, the real value, started from basically

22 the nuclear bombs that allowed us in some way or

23 another to end World War II. As a result of that,

24 there was some spinoff that went into nuclear power

25 plants. And people have tried to use the idea that



1183

1 nuclear power plants were going to save the world.

2 And that was said in some testimony earlier, that it

3 was sold to us as the power that was going to be so

4 cheap that we couldn't even meter it. So to me,

5 those are really the two values.

6 Now, there are medical values and other

7 scientific studies about some other uses. But I

8 don't think that without these two big uses that we

9 would even be having a conversation here about mining

10 uranium. These types of weapons didn't end with

11 World War II in the end and going into the arms race

12 we had with the Soviet Union for a long period of my

13 life, most of it. We now have gotten involved in two

14 major -- I hesitate to call these wars because they

15 really are undeclared wars, but they are -- there's a

16 lot of -- there's conflict going on both in Iraq and

17 Iran.

18 Both of these are being stirred up as a

19 fear that another country in the world is going to

20 get yellowcake or have some capacity through nuclear

21 power to enrich uranium to make bombs which will

22 directly threaten the United States of America. So

23 this product that we're talking about from a

24 worldwide and generational issue has been going on

25 forever. But having been here for pretty much the



1184

1 entire time Wednesday, Thursday, Friday, Saturday,

2 and now today and listening to testimony, listening

3 to examination of witnesses, listening to

4 cross-examination of witnesses, listening to some

5 public comment, there are a lot of questions to be

6 answered, really, I think, about this uranium mine.

7 But I'd like to go -- I mentioned

8 experience. So the other '50s and '60s and '70s and

9 '80s, we came up with a lot if -- it was kind of the

10 chemistry age, the age of the atom. Science was just

11 going nuts back in those days. We were told that our

12 life was going to be incredibly better. And quite

13 honestly, our life has gotten a lot better from the

14 technology advances, scientific advances that we've

15 had over those years. But everything comes with a

16 price. And as a result of all of these advances

17 we've had, as a result of population increases in the

18 world and many other things, we have introduced a lot

19 of chemicals and a lot of things into our world which

20 people with vision were looking forward and saying,

21 hey, we can't continue in this direction.

22 As a result of that, we had a lot of laws

23 and regulations which were passed in the '60s and

24 '70s and into the early '80s, a lot of environmental

25 laws, the National Environmental Policy Act which



1185

1 requires environmental impact statements and analyses

2 and EIAs, et cetera, et cetera, to look at the

3 possible harm that could happen to the country and

4 the world as a result of certain advances. It

5 doesn't say you can't do it. It doesn't say you have

6 to do it. It just says we need to look at what could

7 happen.

8 During that same time period we have -- as

9 has been mentioned, we've had the Clean Air Act, the

10 Clean Water Act. We've had the Safe Food Act. We've

11 had the Wild Scenic Rivers Act, the Wilderness Act

12 all kinds of various acts and regulations to try to

13 determine how we're going to use these laws that have

14 been passed by Congress to our benefit. I want to,

15 you know, go back. We have stacks and stacks and

16 stacks of laws and regulations, but how do we

17 enforce -- how are these laws and regulations really

18 enforced? Are they there to protect us, or are they

19 there to be obstacles in front of people who just

20 want to make a living and create a business,

21 et cetera? Those are questions that we're trying to

22 answer every day.

23 But on the ground and over my lifetime,

24 I've found and seen that -- I've found and seen that

25 a lot of times people that are supposed to be



1186

1 enforcing these laws for the benefit of society and

2 people actually take shortcuts to do that, don't do

3 it at all, or interpret those laws in a way that

4 weren't meant to be. And I go back to -- all the way

5 back to when I flew that C141 into Vietnam. We

6 always stopped in Japan, got a briefing about what

7 was happening in that particular war. And it didn't

8 look good in the briefings, as a flight crew member,

9 going into the country.

10 And this might come as a shock to you

11 guys. But when I went to the Soviet Union and got to

12 read newspapers in the Soviet Union, English-speaking

13 newspapers, the Russians at the time were pretty much

14 telling the truth as to what I was seeing in these

15 briefings that I would get. We weren't winning

16 anything. We had little spots, a lot like we have in

17 Afghanistan and Iraq at times. So I started looking

18 at and questioning that what we read and see and

19 think here in our country might not be interpreted

20 that way in another instance.

21 I remember when I first got my job at BLM.

22 I was a river ranger, but I got ahold of a little

23 recorder because I like to, you know, think out loud.

24 And I was thinking, okay, in my job as a river

25 ranger, going down the river, running shuttles, or



1187

1 looking at the land, I would like to, you know, make

2 comments to myself so I could write these notes down

3 later. And I'll never forget picking up this

4 recorder, and there was a range comm voice, a man

5 that I knew -- I believe he was a range comm. But he

6 was out looking at the field over in the Moab area

7 out on the desert, actually, and there was a gas

8 well. And you could hear the frustration in this

9 guy's voice, in that he had seen a mess on the

10 ground. And he goes, I reported this to the office

11 three times. Nothing ever gets done. I don't know

12 what I'll do about it.

13 We had regulations, but were the

14 regulations actually being enforced? And I have

15 examples going on -- I think we have -- well, I'll

16 come to that in just a minute. But over my lifespan,

17 working in government agencies -- and I sometimes

18 wonder. I've seen a lot of really good people in the

19 field with good intentions and seen things done that

20 I don't think those people would normally do. I've

21 always been sort of a ground level person. I never

22 have been in the upper echelons. I don't know where

23 the impetus is to try to shortcut regulations that

24 were put in place to protect us. But sometimes the

25 protections just aren't there, and that's what really



1188

1 concerns me with what I have seen and witnessed

2 during the last few days.

3 I think we first have to ask ourselves the

4 question is this mill in this day and time really

5 necessary other than as a profit-making, a

6 profit-allowing enterprise for certain businesses --

7 nothing wrong with profit, nothing wrong with

8 business -- and also to create some jobs. Those have

9 been two of the big -- the real pushing things, is do

10 we need the uranium, do we need this product. If

11 we're going to continue, as we say we are, to reduce

12 the number of weapons and to really take a hard look

13 at uranium, how expensive it is to the taxpayer, how

14 expensive it is even when you pay your electric bill

15 at home.

16 We're seen -- every one of us remembers

17 Fukushima. Some of us, looking around the room --

18 well, probably all of us remember Chernobyl, and

19 probably the rest of us remember Three Mile Island

20 and what can happen as an end result of a product

21 which we're being made to think is such an innocuous

22 product here in this area to create jobs. Where does

23 this product actually go, and what is it going to be

24 used for? I think these are really large

25 considerations in the larger scale.



1189

1 But let's bring it back to the scale that

2 we have here in Naturita and Nucla, Paradox Valley,

3 Telluride, all the people that will be affected by a

4 material which has never, ever been proven in any way

5 to be safe in perpetuity. That's a long time out

6 there. We heard testimony the other day, the last

7 few days, regarding this particular plan that has

8 been put together by -- I don't know all of the --

9 where it actually starts, but Energy Fuels has put

10 together an environmental, I guess, impact analysis,

11 or they put together their plan to do their business

12 safely according to the rules and regulations that

13 have been passed by Congress and states, et cetera.

14 And then we have the Colorado Department

15 of Public Health and Environment that has to review

16 these plans and say that, yes, Energy Fuels did a

17 good job or not putting this together. Are these --

18 is this plant going to use the best possible means to

19 protect all the citizens, not only here -- and I

20 think we have to remember that this uranium mill will

21 be on private lands. But once these products leave

22 that particular site, they become all of our problem.

23 It's no longer a private problem or a private land

24 rights problem. It becomes what all the federal laws

25 and regulations are supposed to do. It becomes a



1190

1 national problem, maybe even an international

2 problem.

3 So during the -- you know, I'm not a

4 lawyer. A lot of -- most of the people here are not

5 lawyers. We're here to give our opinion on how this

6 mill will affect each and every one of us and do it

7 the best we can from our experience in life and

8 living in certain areas. But from what I heard,

9 there were some real questions about this particular

10 plan and how it will protect society. There's some

11 real questions. And I think there was some questions

12 on exactly how the monitoring went for air quality.

13 I think one of the people has already talked a lot

14 about that and just the couple of units that they

15 have out there to collect data.

16 But, you know, one of the things that

17 really bothered me was, Connie -- and I have to --

18 Travers, I guess, when she was up talking about

19 water. Water issues are huge in the West; talking

20 about the studies that went into how this plant is

21 going to get the amount of water that -- I think it

22 was 141 gallons per minute over the life of the mill

23 at 500-tons-per-day production. And this study that

24 Energy Fuels came up with talked about -- it only

25 covered five years. And the information that Connie



1191

1 has -- and I think she has excellent credentials,

2 both for business and for agencies, protecting

3 agencies -- says that this water is pretty much going

4 to be gone in five years. So we have that issue, how

5 large is the aquifer.

6 How do we have a 40-year license with only

7 five years' worth of water? Naturita has said they

8 will give the water. How prepared is Naturita,

9 looking at the future, to give the total amount of

10 water that will be needed over the 40-year lifespan

11 of this mill and whatever water is needed to keep it

12 going into perpetuity? So I think that's a huge

13 question.

14 John Weisheit, when he gave testimony,

15 Living Rivers from Moab, when he gave testimony he

16 talked about the Colorado River and the

17 overallocation of the Colorado River at this point

18 right now. Well, Naturita has to be getting their

19 water -- possibly from their wells, but I'm sure a

20 lot of it comes out of the feeder streams that go

21 into the Colorado River. So we're talking about more

22 water promised being, you know, promised to somebody

23 when the water really isn't there, especially if

24 you're looking at the droughts in the future.

25 But, you know, one of the things that



1192

1 really -- it almost maybe slid by. But when Connie

2 was talking about the potential for leakage from the

3 plant, not down to this aquifer some thousand feet

4 down or 800 or whatever it is, but 20 or 30 feet and

5 the leakage -- which every tailings ponds I think

6 that we can imagine has had leakage -- and I have

7 some examples here in a minute. But, you know, at

8 some point -- perpetuity is a long way out there,

9 guys. It's beyond what most of us can even imagine.

10 You look at the stars at night, and you try to figure

11 out infinity, well, that's what it is. Perpetuity is

12 just that.

13 So if this water leaks and goes down 15,

14 20 feet, hits these clay layers or these impermeable

15 layers that she described in her diagram, slides

16 across and goes out into what she called -- I think

17 it was an interesting term -- daylights. It

18 daylights. This water is now no longer subsurface.

19 It's at the surface, and it's out there in perpetuity

20 to be rinsed, washed, flooded into at some point a

21 river, the rivers nearby.

22 We look at it. Maybe it's a small amount.

23 Do you ever really think about how the Colorado River

24 forms? It doesn't form all of a sudden one huge

25 river that we can dilute all this stuff out into.



1193

1 What happens is, it starts as rainwater running down

2 into gullies, which feed into other gullies, which

3 feed into the river. It comes from snow melt doing

4 the same thing. It comes from tiny, little springs,

5 little trickles, little trickles, little trickles

6 until we have the Colorado River. We have the

7 Mississippi River. We have the Amazon River. We

8 have all these rivers, and they start with little

9 trickles.

10 And when we look at the poisons and we

11 look at the radiation and all the other things that

12 we are putting out on the ground without even

13 thinking just a little amount and these things

14 slowly, slowly, slowly, slowly add up until we have,

15 you know, real environmental degradation and a

16 real -- a real threat to humanity and other life in

17 the world. And, you know, we're at that age right

18 now where -- we're on the fence where, you know, from

19 our earlier days, things have become a lot more

20 complicated and a lot more -- how would I say it?

21 More threatening, I guess. I don't know. You know,

22 the things we took for granted, now the nice things

23 have now become threats to us. And we really don't

24 know how to handle all this.

25 I just looked online, and I went through



1194

1 to kind of look at some of the things that I remember

2 becoming aware of as a result of this hearing we're

3 having and how we continue to say that we can contain

4 and control the emissions, the air emissions, the

5 water quality, from all these plants and mining

6 activities, et cetera. We have -- of course, the one

7 that's more recent, the Shattuck plant up in Denver,

8 the Shattuck Company, the one that moved their

9 millings, their waste down into this area to Uravan.

10 We have that. And that Uravan mill has been

11 contained. But again, there are still some problems

12 with it, and we're still look at perpetuity.

13 We have Canon City, of course. That's

14 been over again and again. We have White Mesa with

15 some radiation offsite there that's spreading. And

16 we don't know how -- you know, it's not a lot, I

17 guess, at this particular time, but it's adding. I

18 should -- okay. We have Summitville. Remember

19 Summitville, the gold mine was supposed to -- it

20 totally -- it's been a mess.

21 The one that really gets me, Libby,

22 Montana, the vermiculite mine in Libby, Montana, with

23 the asbestos. In 1966 this company knew that they

24 were poisoning and killing people with asbestos. And

25 they ran the thing until 1990 before they were made



1195

1 to shut that down. We have spent in Colorado over a

2 billion dollars cleaning up sites.

3 Bringing this back -- I got a little off

4 track there. But with the particular permitting

5 processing here, we had other issues besides water

6 and air. We had socioeconomic issues which Dr. Power

7 brought up and how this data has been treated to the

8 point where he thought a lot of the information and

9 data which is showing we're going to have all these

10 jobs is just -- frankly, if you really look at the

11 data, it's not true. It wasn't taken very seriously,

12 is what he said, by the people putting together the

13 EIA. And he was asked directly, I believe, if he

14 felt like that absence of good data should negate

15 this whole license, that it should go back. And I

16 believe his answer was, Yes, we should stop right

17 here because they failed in filling out and taking

18 seriously one of the big parts of the EIA.

19 One other thing I'd like to -- one other

20 point I'd like to make on that was what I thought was

21 pretty stunning. But I believe it was when

22 Mr. Tarlton was up there, and this is where I come

23 from, back in my experience with BLM. When he was

24 asked directly, Do you have enough people in the

25 office in the state, CDPHE, to actually undertake and



1196

1 do an analysis or review of an analysis or a

2 licensing procedure, do you have enough people to do

3 this with all the other work you guys have, are there

4 enough people to do this in a good manner, with very

5 little hesitation he looked up and said, No.

6 And I could see the frustration, just like

7 I see the frustration with some of the people I

8 worked with at BLM, where they are just slammed with

9 all these gas and oil wells without the people to

10 really look at it to protect the values of society.

11 But they have to rely on the industry, which is in

12 the business to do the profit and a lot of times

13 shortcutting things. And they have those same -- I

14 saw the same look. I saw the same look of, We're

15 overworked, and we're not able to do it.

16 So I guess I'll try to end real quick here

17 and I'll say, we really need to look. Do we need

18 this right now? We have the DOE over here that's

19 taking the uranium -- the Uravan Mineral Belt and has

20 put this whole leasing process on hold because DOE

21 didn't do the EIS as it should have done for all the

22 re-licensing and the approvals of the mining,

23 whatever's taking place over there. DOE is an

24 example in our local area that didn't do it right.

25 We have a person that went to prison, Tim



1197

1 DeChristopher, to try to stop a well or gas and oil

2 leases on public lands in our area. He went to

3 prison for two years. And when he went to prison, we

4 found out about the studies. The EISs had not been

5 done probably by the BLM because they're under such

6 pressure to get the gas and oil out of there. And

7 this is a different issue, of course, but it all

8 comes back down to regulations. How are they

9 enforced? Do we have enough people in the offices

10 that would like to do the job that they should be

11 doing?

12 And I think the answer has been proven

13 time and again in the last decade that we don't have

14 that. As Troker Norphis (phonetic) said, we're going

15 to shrink the federal government. The agencies that

16 are in there, the people who work -- the good people

17 who work to protect us from the unknown in the

18 future, and we're going to shrink this down to the

19 size where we can drown it in a bathtub. And that's

20 where we stand in this country right now. This

21 license, if it needs to go back and be done again,

22 what's the hurry? We're talking about environmental

23 issues that are here in perpetuity. What is the rush

24 to get this through other than there are a lot of

25 people who put in a lot of time and work and effort,



1198

1 Energy Fuels, et cetera. But the bottom line is,

2 it's the health, the safety, and the environment, and

3 that is what the State of Colorado is obligated to do

4 for us, the people and citizens. And I thank you for

5 letting me speak out.

6 HEARING OFFICER: 15 minutes for lunch,

7 folks, and then we're coming back.

8 (Recess from 12:51 p.m. to 1:16 p.m.)

9 HEARING OFFICER: Benita Phillips.

10 MS. PHILLIPS: My name is Benita Phillips.

11 I'm the president of Western Colorado Congress of

12 Mesa County, but I'm actually here as an RN. And I

13 wanted to just -- throughout these hearings, one of

14 the things that I've noticed is that we haven't

15 really focused in on the singular person, meaning the

16 patient. And uranium is kind of an odd thing, in

17 that people do not react to radiation in the same

18 manner. Two people can be standing in an area that

19 is contaminated. One will get very sick maybe

20 20 years down the road, and the other one will not

21 have any effect at all. So that's always made

22 uranium, well, just radiation, an enigma medically.

23 I have a little schematic drawing here,

24 and I'll give this to you because it was put together

25 by the Tribal People's Survival. And, of course,



1199

1 this is in regards to the Navajos, who have had a lot

2 of trouble in terms of uranium and radiation

3 sicknesses. And a couple things I want to tell you

4 is, there are several particles that are called --

5 one's call alpha, one's called beta, and one is

6 called gamma. They each have different properties,

7 and they each attack a different part of the body.

8 What we have failed to talk about here is

9 that when you are mining uranium, you have other

10 highly radioactive materials that are also

11 accompanying that mining process. Just for example,

12 women seem to be more susceptible to radiation

13 sicknesses that have to do with their reproductive

14 organs. For example, iodine, will attack the

15 thyroid. Cobalt will attack the ovaries; krypton,

16 ruthenium, zinc, barium, potassium, cesium,

17 plutonium, which is probably the most deadly of all

18 the radiations.

19 Then you have women also who have problems

20 with bones because as we get older, women tend to

21 have more osteoporosis than men and so we become more

22 susceptible to small particle radiations: radium,

23 strontium, yttrium, promethium, barium, thorium,

24 phosphorus, carbon. These all have a radiation level

25 that can affect the body; not just women, but men,



1200

1 too. And I think that's an important thing to think

2 about because when you have a worker who is in the

3 mine, it's not like the old days where they take a

4 pickaxe and go in and they chop the side of the wall

5 and the ore falls down or the rock containing the ore

6 falls down.

7 These people will have to be highly

8 trained hazmat workers. CDL drivers will have to

9 have a hazmat rating. I've worked in industrial

10 nursing before, in oil and gas, and hazmat training

11 is very intense. And so when these people around

12 here who barely -- some of them barely have a high

13 school education think that they're going to jump in

14 there with their pickaxe, that's not what's going to

15 happen. Hazmat requires deep training and personal

16 protection equipment, respirators, and then how to

17 dispose of that equipment once you're done with it.

18 It's very intense. And not that the people here

19 can't learn that, but it's not like it was 30 years

20 ago.

21 One of the things that's going to happen,

22 though, is with the new Care Act, these workers will

23 either be seeking energy -- Energy Fuels will be

24 seeking insurance for their workers either through

25 the exchanges, or possibly they have an insurance



1201

1 policy that's private or self-insured. I don't know.

2 But down the line, if there's only -- if a worker

3 makes just one mistake with his PPE, he could inhale

4 the uranium down into his lungs and it may not show

5 itself for at least 20 to 30 years. As of right now

6 we're still discovering people who worked in the

7 industry years ago and who are now still coming up

8 sick.

9 And if you don't dispose of things that

10 have radioactive material on it properly, it can be

11 taken home to the families. And, of course, the

12 children are the most susceptible of them all. So

13 this is a big thing with the Affordable Healthcare

14 Act. The taxpayers, who are part of the exchanges,

15 all of us, are going to pay for those workers'

16 insurance down the road once again, only in a

17 different form.

18 Recently there was a program that was

19 given in Grand Junction by Headwaters Economics.

20 It's a nonpartisan economic job analysis organization

21 out of Montana. They were talking about how many

22 percent of jobs Colorado has. Only 1 percent of the

23 total jobs in Colorado now are extraction jobs.

24 2.2 percent of Colorado's total jobs now are in

25 alternative energies. Now, this is a real



1202

1 interesting point to be made here because what we are

2 looking at is we're watching the energy situation

3 morph.

4 When I was a kid I lived downwind from the

5 Hanford area in Spokane, Washington. My mother had

6 thyroid cancer and had her thyroid taken out. My

7 grandmother had her thyroid taken out. She had all

8 of her female organs removed. Almost everybody that

9 I knew in my neighborhood, the women had thyroid

10 problems or female problems that had to be removed at

11 a fairly young age. So Hanford has a tremendous

12 amount of history where things have gone wrong for

13 women. And I'm not just here to be a women's

14 advocate, but that's really what I'm sounding like.

15 What's going to happen in this area, I

16 predict, is that the women who are nearing

17 childbearing age now, if this mine is opened up and

18 if there's any of the radioactive material that is

19 caught by the wind, either inhaled, or in some cases

20 like the beta will actually go through the skin. It

21 will go to the -- it could go to their female organs,

22 and they'll become sterile or they'll have to be

23 sterilized because of cancers. The exact cause and

24 effect is really difficult to prove. But we know by

25 anecdotal years of studying this that when people who



1203

1 are susceptible to this are exposed to radiation,

2 this is what happens to them.

3 I think we have to stop and think about

4 patient advocacy. We have to think about the

5 individual person. I've taken care of a lot of -- my

6 last job, actually, was in the Veterans Hospital.

7 And a lot of those guys came back from World War II,

8 from the Korean War, and from the Vietnam War, and

9 they were exposed to, especially the guys in Vietnam

10 were exposed to horrendous things like Agent Orange.

11 And I don't know if at that time they were using

12 depleted uranium munitions, but we know that that's

13 happening in Iraq. And these people are coming back,

14 and we have to care for these veterans. And there's

15 nothing that is more profound than to have the honor

16 to care for somebody who is in such need that their

17 next breath is so hard for them to take that all you

18 can do is just stand there and put pillows under them

19 and say, okay, breathe deep. And sometimes that's

20 all that gets them through to the next breath.

21 I think we have a responsibility here not

22 just to Energy Fuels, not just through the CDPHE who

23 actually make the statement that they're here to

24 serve the people. We have to make sure that if we do

25 these kinds of things, that they are totally



1204

1 contained. I personally am against opening this

2 mine. That's not up to me to decide. But I know

3 what it's like to care for people who have been

4 exposed and have gone through the horrendous lifetime

5 work of trying just to stay alive.

6 HEARING OFFICER: Is Eric Niederkruger in

7 the room?

8 MR. NIEDERKRUGER: Hello, everybody. I

9 hope all of you are well and healthy. I appreciate

10 people taking the time to come out and talk and

11 hopefully listen. A lot of my remarks are going to

12 be hopefully absorbed by the people of Nucla as well

13 as yourself, as you make a difficult decision.

14 I live in Grand Junction. I was raised as

15 an Air Force brat. I don't have any actual hometown

16 because I moved all over the country and literally

17 all over the world. I live in Grand Junction because

18 I love it, not because I have to. And I'm sure that

19 most of the people in Nucla can understand loving

20 where you live. I'm also a disabled American

21 veteran. I don't care much for my disability, but I

22 accept it. An unintended benefit is that it

23 sometimes gives me time to work on issues that are

24 important to me such as uranium mining and milling.

25 The point is, I'm not just some long haired, bearded,



1205

1 can't-get-a-job, out-of-town troublemaker. I'm a

2 human being, and so is everybody here. All too often

3 we forget this humanity. Please accept my humble and

4 clumsy attempt to discuss this issue with dignity and

5 respect.

6 Most of my mom's family worked in the

7 Pacific Northwest as loggers. Most of them now live

8 in very economically distressed towns with very high

9 unemployment. Their jobs are gone, virtually

10 forever. The jobs did not disappear because of

11 hippies or the spotted owl or even the EPA. They did

12 because major companies like Weyerhaeuser and Boise

13 Cascade clear-cut all the forests. There are no more

14 big trees to cut. And years before that the millers

15 got fired because Japanese ships developed the

16 technology to take raw logs in the U.S. and deliver

17 milled lumber in Japan.

18 I'm just making the point with the

19 connection of a similar issue. Their jobs are not

20 gone because of outsiders. They're gone because of

21 the disrespect and the company's greed. I used to

22 argue with my uncles and nephews about clear-cutting.

23 They knew they were destroying the forest, but they

24 also knew that their small town life offered few

25 other opportunities. They were caught between a rock



1206

1 and a hard place. And they're not stupid, either.

2 They really resented the squeeze. Nowadays they're

3 in real desperate times because who wants to vacation

4 or recreate in a clear-cut.

5 So today I'm in Nucla talking about

6 uranium. What do we know about uranium, in general?

7 We know that uranium will kill some miners and

8 millers with a slow, suffocating disease which only

9 deteriorates with time. Nobody knows more about this

10 than the old-timers in the area: cancers, leukemia,

11 birth defects. As I said, you know it better than

12 most people. Everybody in the room knows about the

13 serious medical problems. Anybody who says they

14 don't is in denial or is ill informed.

15 Another thing you all know is that mining

16 companies don't stick around through the hard times.

17 From what I understand, Nucla understands hard times

18 when the mining industry pulls out. Make no mistake

19 that when this company pulls out, they will find

20 there's not enough money to be made on uranium and

21 they'll leave. Uranium is already a hard dollar.

22 This Canadian company is already in danger of running

23 out of time on their permit. Some suspect this

24 company just wants to build a mill and turn around

25 and try to sell it right away.



1207

1 Mining companies are notoriously fickle.

2 Reality is made up of those things that don't go away

3 just because you don't like them. The reality is

4 that the vast majority of Americans do not want to

5 live or recreate around a place that has radioactive

6 material around. I believe many West Enders would

7 actually prefer not to live intimately with radiation

8 either. I understand how difficult it is, though, to

9 watch virtually your whole graduating class disappear

10 for lack of employment just because there's no jobs.

11 So I understand, after seeing the clear-cuts also,

12 that tourists and retirees go away and don't come

13 back.

14 I just want to say good luck to everybody

15 here. It's a difficult decision that you're making.

16 I hope everybody from Nucla and all the concerned

17 people and yourself, Your Honor, are guided by all

18 the things you have heard so far. Thank you very

19 much, and God bless.

20 HEARING OFFICER: Robyn Parker.

21 MS. PARKER: Hello. Thank you for the

22 opportunity to speak today. I grew up in Canon City.

23 For a few years, my mom was a teacher at my

24 elementary school. Fortunately for her, she

25 transferred to a different school on the other side



1208

1 of town after just a short time. Every one of my

2 teachers who spent several years at that school got

3 cancer, and most are dead now. As you know, Canon

4 City is home of the Cotter uranium mill, which has

5 been a Superfund site for 36 years. And after all

6 this time, no one knows how to go about cleaning up

7 my old community.

8 I am here today as a concerned citizen but

9 mostly just as a mother. My generation and those

10 before me have taken and taken from our children and

11 grandchildren. We are leaving them with a legacy of

12 polluted water, polluted food, polluted air, and

13 polluted land. We have destroyed so much that we

14 have even altered the climate.

15 HEARING OFFICER: Slow down just a little

16 bit.

17 MS. PARKER: None of us can do anything

18 about any of that. It's the responsibility of future

19 generations. We have an opportunity now to give our

20 children reason to hope. Uranium is used to make

21 bombs and unsustainable, destructive power plants.

22 We don't need it. It serves no purpose other than to

23 harm people and the environment. Saying no to the

24 uranium mill tells future generations that we do care

25 and are willing to take personal responsibility for



1209

1 our actions and our energy needs. We've taken so

2 much, too much, from our children. And the very

3 least we can do is -- surely the very least we can do

4 is to say no to uranium development and leave our

5 children with cause for hope. Thank you.

6 HEARING OFFICER: Is there anybody else in

7 the room that hasn't made a comment that wishes to

8 make a comment this afternoon? And I will reopen

9 this at some point.

10 Can I get you to sign up.

11 MS. ROBERTS: I've already signed up back

12 there.

13 HEARING OFFICER: Let me walk back there

14 and get it. Sorry about that.

15 Margo Roberts. Go right ahead.

16 MS. ROBERTS: My name is Margo Roberts,

17 and I am a Naturita town board member. I'm not here

18 representing our town board. I'm here based on the

19 experience that I go through every day of having to

20 explain to people what's going on with our mill.

21 People are concerned. They want jobs. I was a

22 reporter during the Umetco hearings. I had to

23 investigate both sides of the story. I spoke with

24 people who were for and against, and I had to get an

25 education on how uranium was cleaned up at that time.



1210

1 I've heard many people express concern on how uranium

2 is transported. As I understand it, uranium is

3 packed in a ceramic-lined, steel drum within cement

4 blocks so there's no risk of a hazardous waste spill

5 in transportation.

6 I have to say it upsets me greatly when

7 people get up here and disparage the intelligence of

8 our residents by insinuating that we don't have

9 educations. I have worked as a journalist. I have

10 worked as a substitute teacher. I have managed large

11 corporations and amusement parks. I do whatever I

12 have to do to make a living, as does the rest of the

13 residents of this community. And it upsets us when

14 people look down at us like we don't know what we

15 want for ourselves.

16 The people in this community are also the

17 same families that were here during the mining prior,

18 30 some years ago. We do know the dangers of mining

19 uranium. However, we're also aware this is the first

20 mill to be built in 30 years. There's going to be

21 new regulations that were not in place 30 years ago.

22 This is a new mill, not an old mill that's been in

23 business for decades. They're starting out with a

24 clean slate. I understand the Energy Fuels is

25 willing to meet all the requirements.



1211

1 Let me go over my notes here real quick.

2 I've heard suggestions on what we should do. And I

3 guess the people that make suggestions of what we

4 should do haven't spent more than 15 minutes in our

5 community. They're not aware that the same people

6 that are trying to fight this mill are also fighting

7 our water use. It's very hard to farm when you don't

8 have access to water. I have a home that I own in

9 Naturita, and I can't even have a yard because I

10 can't afford the water, and I can't take it out of

11 the river.

12 Farming has changed a great deal in the

13 last decade. Children are not allowed to work under

14 the age of 18 on family farms. That hurts our

15 community. We don't have the money. It takes money

16 to start a farming business. Tourism? The only

17 tourism that we seem to be getting these days is

18 protesters. We would like to build our community.

19 As a town board member, we encourage businesses to

20 come in all the time. As a matter of fact, that's

21 one of the first questions we ask a business: Are

22 you coming in hopes that the mill may open because we

23 don't even know if we can expect that.

24 I've watched this community dwindle in the

25 last 20 years. My husband and I were married here in



1212

1 1988 at the Assembly of God Church right down the

2 road. We have watched people leave. We've watched

3 entire families disappear. It's not the community it

4 used to be. It's very tiny, and we're suffocating.

5 We're trying to succeed here, and we're doing

6 whatever we can to make that happen. And we just

7 feel like people have sat against us to stop us from

8 succeeding.

9 We are not building a nuclear power plant.

10 I just would love people to understand that. Uranium

11 has other uses. I personally have lost two members

12 of my family who are not from this area, born and

13 raised in California, that both died of cancer.

14 Without uranium, without radioactive materials,

15 cancer cannot be diagnosed, and it cannot be treated.

16 Thyroid cancer specifically, they use radioactive

17 iodine in the imaging.

18 Let me go over my notes here. Our present

19 revenue sources are seasonal. We have hunting, which

20 only occurs in the fall and some in the spring. We

21 have our road and power crews. We have our coal

22 mine. We have our power plants for the time being.

23 We have Waste Management, which is the dump, and we

24 have our schools. We don't want to become the next

25 Gateway. We don't want to be a resort community



1213

1 ghost town. Because people are only coming through

2 this town to get to the resorts. All I hear is

3 recreation, recreation, recreation. We have very few

4 things to offer in the way of recreation. We have

5 agricultural, which is our cattle and our hay.

6 I'm just going to sum this up and say in

7 my opinion, I feel these advocacy groups are using

8 fear mongering based on ignorance to alarm the public

9 regarding our uranium mill. I think their

10 information is outdated and has no bearing on the

11 safety measures required for this permit. And I want

12 to thank you for your time.

13 HEARING OFFICER: Anybody else in the room

14 who hasn't signed up who wishes to offer public

15 comment?

16 AUDIENCE MEMBER: I haven't signed up yet.

17 HEARING OFFICER: There's sign-up sheets

18 by the door.

19 Are there individuals on the telephone who

20 wish to offer public comments?

21 MS. HEAD-DYLLA (via phone): Yes, sir.

22 HEARING OFFICER: Can I get your name.

23 MS. HEAD-DYLLA (via phone): Candace

24 Head-Dylla with Bluewater Downstream Alliance.

25 HEARING OFFICER: What's your last name,



1214

1 again?

2 MS. HEAD-DYLLA (via phone):

3 H-e-a-d hyphen D-y-l-l-a.

4 HEARING OFFICER: Anybody else?

5 MS. CUNNINGHAM (via phone): Sharon

6 Cunningham from Canon City for Colorado Citizens

7 Against Toxic Waste.

8 HEARING OFFICER: Anybody else? All

9 right. Ms. Head-Dylla, is that how you say it?

10 MS. HEAD-DYLLA (via phone): Head,

11 H-e-a-d, like the head on your shoulders, Dylla yeah.

12 HEARING OFFICER: Okay. Go ahead.

13 MS. HEAD-DYLLA (via phone): Thank you,

14 sir. We're sending these comments electronically to

15 Judge Dana so you'll receive a copy of these. Again,

16 my name is Candace Head-Dylla. I live near the

17 Homestake/Barrick gold Superfund site near Milan,

18 New Mexico. About half the uranium that was ever

19 extracted in the U.S. in the last hundred years was

20 mined and milled in New Mexico, much of it in the

21 region north of Grants, where I live. We were

22 previously known for our carrot crops. But this once

23 fertile valley has become one of the most

24 contaminated areas in New Mexico.

25 Residents of Murray Acres, where I live,



1215

1 Broadview Acres, Felice Acres, Valle Verde, and

2 La Siembra Estates, we all moved to the valley to

3 pursue agricultural and rural lifestyles. But we've

4 been exposed to unsafe drinking water, windblown

5 contamination. And we've watched as industries

6 promises us to clean the contamination have been

7 broken, resulting in plummeting property values and

8 ongoing health concerns. And we fear the same is

9 about to happen to this very beautiful area if the

10 Pinon Ridge uranium mill is built in Western Montrose

11 County in Colorado.

12 I spent a lot of important summers of my

13 childhood nearby in a little town called Olathe, and

14 I do care about your part of the country. What we

15 found is that we've watched a very fertile and

16 industrious agricultural community where I live --

17 it's fast becoming a wasteland because one aquifer

18 after another has been contaminated with pollutions

19 from a uranium mill tailings site located nearby.

20 Generations of our farmers and ranchers are losing

21 their ability to continue their lifestyle as a result

22 of not only the contamination but also the radon that

23 continues to soak our homes.

24 And we really believe that a mill in

25 Paradox Valley is going to change your community



1216

1 forever. We're a small, working class community. We

2 can assure your folks in Paradox Valley that when

3 they find out that the company's promises were lies

4 and when the jobs play out and they're left with just

5 the contamination, there won't be any government, no

6 regulators, no one willing to hold these corporations

7 accountable. We have fought this problem for over

8 50 years. And no matter who's in office, from

9 conservatives to the so-called progressives, no one's

10 willing to stand against the army of lawyers that

11 these companies can and will throw at you.

12 We looked at the analysis by the Colorado

13 Department of Public Health and Environment. There

14 seem to be flaws in the application. That's always

15 the case. If permitted these problems will only

16 increase. Our experience shows clearly that the

17 Nuclear Regulatory Commission might as will be an

18 organizational unit within the uranium and nuclear

19 corporation. The state regulators do nothing to

20 protect just ordinary citizens against the technical

21 experts and the attorneys that these companies can

22 amass, and they make the most unreasonable project

23 appear reasonable.

24 One would think that our experience -- we

25 have uranium mill tailings situated in a flood plain



1217

1 near seismic activity. It's over five critical water

2 aquifers. You'd think that would be something of the

3 past. But this proposal we feel like has not been

4 adequately analyzed either for the potential for

5 water contamination and long-term impact. Your

6 community relies on its clean air and water just as

7 ours did. The difference is that you could learn and

8 draw lessons from the experiences that we've had, and

9 you could change the course of your community to a

10 more promising future.

11 We're left right now to struggle with a

12 situation that wasn't our choice and over which we

13 have very little control. No one wants to live in

14 our community. No one wants to visit our community.

15 My daughter recently came to town. She couldn't stay

16 in my house because she's pregnant, and there's a

17 real concern about the level of radiation to which

18 she's be exposed. Many of our friends and neighbors

19 are dead. They're sick, and they're dying as a

20 result of their exposure. And it's just a shame to

21 us that you would even consider this, knowing what

22 we've been through.

23 Many of our members were former uranium

24 miners. Two of them are experienced mine engineers

25 and managers. And all of them agree that the methods



1218

1 have not improved significantly enough to alter the

2 effect of a mill like this on the local community.

3 Our whole county knows what it's like to put all our

4 economic eggs in one basket and then have the market

5 crater and be left with the stigma and the very real

6 contamination problems that now plague our community.

7 The state took the companies' severance

8 taxes, but we can guarantee you that they're not

9 around to help us with cleanup. There's an economic

10 analysis that I'll send in the testimony I send to

11 you. But my dad did a feasibility study for a

12 $124 million mine mill complex in Crownpoint,

13 New Mexico, back in 1980. And at that point gas was

14 60 cents a gallon, and diesel was 50 cents a gallon.

15 In that market the plan required uranium to be

16 running about $35 a pound to make a profit. Gas and

17 diesel are now much higher. And if it takes five to

18 six times more money for some of the major costs of

19 operation, it's going to take considerably higher

20 prices to produce a profit. Five to six times $35

21 means the price of uranium may need to be well above

22 the $100 a pound mark to make mining profitable.

23 We conducted an analysis using some real

24 conservative figures in 2008, and at that time the

25 producer price index showed mining industry prices



1219

1 had increased from 1984 dollars by at least almost

2 three times, which would put the price for a profit

3 at $104 a pound. So what we're saying, basically, is

4 it's not economically feasible at this point. So one

5 of the things that we think is that communities are

6 being sold a bill of goods and that right now the

7 chances of mining uranium are not that great. It's

8 going to need to be well above the $100 a pound mark

9 to make it profitable.

10 But this gets worse because in the 1940s

11 and '70s, there was a large workforce of trained

12 miners. And now few underground mines are still in

13 operation in the U.S., and these miners aren't

14 readily available. This fact and the less stringent

15 environmental regulations in other countries have

16 caused many of the big mining companies to move

17 overseas. To maintain a workforce in the U.S., wages

18 are going to need to be really high to attract

19 workers to what's clearly a dangerous and hazardous

20 job. This increases costs. The other option is to

21 hire guest workers, which may mean taxes, but it

22 certainly doesn't equate to higher paying jobs for

23 Colorado citizens.

24 And another good question that we think is

25 important for this analysis is, is this a job you



1220

1 want for yourself, for your own son or daughter or

2 other family member? And if you think so, then we

3 have a lot of evidence that we could provide you

4 concerning the dangerous and hazardous conditions

5 that were in effect post '71 when the supposedly

6 safer and more enlightened policies took effect in

7 mines. And we think we might change your mind. And

8 that's not even to mention the 112 men that were

9 killed outright in our community from 1949 to 1984 in

10 New Mexico mines.

11 Bluewater Valley Downstream Alliance is a

12 core member of the Mesa Alliance, the Multicultural

13 Alliance for a Safe Environment. We oppose the

14 licensing of the Pinon Ridge mill. Licensing this

15 mill would cause even more pressure for mining in our

16 region where people are already suffering. The full

17 extent of contamination in our region is not yet even

18 known. It's going to take centuries to fully address

19 the associated environmental and health problems.

20 Other groups have shown that the EIA for

21 this proposed site does not meet the basic

22 requirements of Colorado's regulations. Please

23 consider our experiences and understand that if you

24 license the Pinon Ridge uranium mill, there will come

25 a time you bitterly regret this decision; if not you,



1221

1 then future generations who will suffer from your

2 decision and will hold you responsible. Please

3 choose a different legacy for this beautiful valley

4 and for the futures of the people who call it home.

5 Thank you very much.

6 HEARING OFFICER: Mr. Alger.

7 MR. ALGER: I don't claim to be an expert,

8 and I'm not affiliated with any organization either.

9 I'm just a concerned citizen. I live here. I love

10 Colorado. It's my home. Anyway, so one of the

11 places that I looked for my information was the

12 Nuclear Regulatory Committee. And one of the things

13 that they -- well, first I wanted to find out, well,

14 what exactly does a uranium mill do. And so we've

15 gotta truck uranium in. Okay. And it's going to

16 have to go by rivers. And I'm sure you've all heard

17 the testimony that it could fall into those rivers,

18 and then what do we have?

19 So we truck this uranium in, and then it

20 gets pulverized and it gets extracted using a bunch

21 of different chemicals. And a lot of that is toxic

22 waste. Most of the sites, the uranium mills that are

23 in Colorado, are in remediation now, which means

24 they're in the process of being shut down and cleaned

25 up. And one of the things that struck me was, well,



1222

1 why do we want to make another Superfund cleanup

2 site? We're already cleaning up all the rest of

3 them. We've got something like an 800,000 year

4 life-span of this stuff, and it's supposed to be

5 protected with these layers of plastic. Somehow that

6 doesn't seem safe to me. Our country's only been

7 around for less than 250 years, and it's hard for me

8 to imagine 800,000 years. How do we protect

9 ourselves from this?

10 I also think that, yeah, this area has

11 been hit harder than a lot of areas for jobs. But

12 there's a lot of sun out here. Why can't we get some

13 solar power going out here instead of looking into

14 the past for this very toxic stuff? Now, we've

15 already surpassed a billion dollars in cleanup of

16 uranium mills, okay, so far. Now, that's not with

17 building yet another one. This one's supposed to go

18 over a geological fault.

19 I don't know how we're going to keep all

20 the water -- we saw last year the drought that we had

21 that lasted halfway through the summer. And the

22 water's supposed to protect us from this stuff

23 turning back into dust and blowing around, okay,

24 which it does. It turns into dust and blows around.

25 The dust that blows around this area sometimes comes



1223

1 from hundreds of miles. Any tragedy or accident that

2 happens involving this is not going to only -- it's

3 going to cost jobs in the whole region because we're

4 going to have a poisoned area, and tourists aren't

5 going to want to come here.

6 And I know we say, tourists, tourists.

7 Look, I'm a construction worker. I don't make a lot

8 of money, and I'm not immune to unemployment. I've

9 been unemployed for six out of the last 12 months.

10 These hard times, they hit all of us. But we have to

11 look forward. We can't keep looking back. And we

12 don't know. What are we going to do with this stuff?

13 What are we going to do with all the stuff that's

14 already here?

15 Another thing that I found in looking on

16 the Nuclear Regulatory Commission site is, they say

17 the Uranium Mill Tailings Radiation Control Act of

18 1978 was set up to deal with the waste. One of the

19 things it says is, does the DOE, the Department of

20 Energy, or the pertinent state deal with the costs of

21 this. And it's not specified in either place. So

22 then after we get these jobs, are we on the hook for

23 however many millions of dollars, the State of

24 Colorado, for the remediation of this waste?

25 So I just wanted to come and say this is a



1224

1 bad idea. Let's look forward, Colorado. Let's look

2 to a green Colorado, a healthy Colorado. I love my

3 home.

4 HEARING OFFICER: Ms. Cunningham.

5 MS. CUNNINGHAM (via phone): Yes. My name

6 is Sharon Cunningham. I'm from Canon City, And I'm

7 cochair of Colorado Citizens Against Toxic Waste.

8 We've had extensive experience over 10 years, some of

9 our members as many as up to 50 years, studying this

10 industry and radioactivity and how much can go wrong,

11 as we live next to the Cotter uranium mill. The

12 Energy Fuels application is really theory. They're

13 estimating what may happen. And what we've done is

14 live the reality of what can happen at a uranium

15 mill.

16 I've heard many claim that there are new

17 laws and regulations that will result in a new and

18 improved uranium mill in your area. But contrary to

19 that, in the last decade at the Cotter mill we've

20 seen, unfortunately, what we feel is lax regulation

21 enforcement, and we've seen very long delays in

22 identifying contamination and in requiring

23 remediation; in some instances, up to 30 years in

24 delays. We strongly believe this is due to a lack of

25 state resources to provide enough staff to the health



1225

1 department's radiation management unit.

2 Right now in our area, there's an

3 estimated 1 billion gallons of contaminated

4 groundwater and a million tons of contaminated soils

5 where Cotter has proposed very minimal and no active

6 cleanup of groundwater. And they've proposed leaving

7 100 times more uranium in the soil than was left at

8 Uravan. And so far we've not seen an objection by

9 the health department.

10 Unfortunately, problems come after the

11 contamination. Our first comment letter covers these

12 issues, but today I'm just going to speak to a couple

13 of points in Energy Fuels' environmental report and

14 the health department's EIA and will submit a written

15 comment by E-mail. Specifically, Section 7 and.

16 Section 4 of the environmental report on economic and

17 social effects are what we're concerned about.

18 Colorado Statute 25-11-203, Section 2 VI requires an

19 analysis of the benefits of the proposed application

20 against environmental costs and social effects. And

21 it is that area we feel has been covered very

22 deficiently.

23 The economic and social effects that are

24 covered in Energy Fuels' environmental report only

25 consist of six pages. And the health department's



1226

1 EIA covers it with a half page, both claiming that

2 these impacts are hard to quantify. And then they

3 both largely skip over this requirement by statute.

4 These few pages are devoted mainly to monetary and

5 economic benefits and greatly ignore the negative

6 impacts.

7 In contrast, between 2002 and 2005,

8 Cotter's license renewal environmental report was

9 required to address noneconomic impacts, social

10 effects. And that resulted in a real estate study by

11 Cotter and a scientific survey by RFI of Durango and

12 some other studies. The radioactive waste disposal

13 impact to real estate values is largely ignored in

14 this, and it ignores the far future impacts from the

15 Pinon Ridge mill.

16 In Section 4 they really limit any

17 discussion about damage to agriculture framed around

18 only a loss of acreage. And it really ignores any

19 research that's out there on stigma that could impact

20 either organic farming, ranching, or farming in the

21 area. Also in Section 4, the recreation impact was

22 only two to three sentences, and it discussed hunting

23 and fishing, ignoring the impact from stigma, again,

24 to other forms of recreation.

25 And no research was offered in either



1227

1 document to back up these opinions. All of the

2 claims about social effects and noneconomic impacts

3 cite no studies to back up the opinions expressed by

4 Energy Fuels or the health department, though there

5 is a lot of research available.

6 Once the mill is constructed, operating,

7 and disposing of radioactive waste, there will be a

8 permanent stigma impacting future growth in the

9 valley due to the long radioactive life of materials

10 that will remain in the impoundments forever. And

11 despite the claims in these two documents about

12 noneconomic impacts, radioactive waste disposal does

13 have a quantifiable, definitive, and negative impact

14 on property values, tourism, economic development,

15 housing investment, and the psychology of the people

16 and social cohesion in a community.

17 There is a substantial body of research

18 and information that should have been used in EF's

19 assessment and the health department's EIA, but it

20 wasn't. We provided, our group, during Cotter's

21 license renewal in 2005 a three-inch stack of printed

22 studies from universities and real estate research on

23 social and economic impacts from radioactive waste

24 facilities. Energy Fuels, just like Cotter at that

25 time, claimed that potential economic and social



1228

1 consequences are not quantifiable. Though absolutely

2 possible to quantify, there was no effort by Energy

3 Fuels in this document or the health department.

4 That's understanding from Energy Fuels. But not from

5 the health department. The health department knows

6 the research is out there. They should have included

7 such research in this decision analysis and their

8 EIA. And they should have required Energy Fuels to

9 provide evidence of their claims of no impacts.

10 Also something that our group, as we read

11 the EIA, was disturbed by were a number of errors and

12 misrepresentations in the state's EIA when

13 referencing experience at the Cotter mill. One claim

14 was that doses to employees came down since the 1990s

15 at Cotter. That's on Page 120. But they failed to

16 mention that Cotter's lab was shut down in mid 2000s

17 for deficiencies, and they had numerous violations

18 for issues around how they calculated employee dose

19 erroneously for ages. And then they stopped

20 operating shortly after this was corrected.

21 A few examples of half truths leaving an

22 erroneous impression was one on Page 140 where the

23 state claims that the ATSDR's draft public health

24 assessment found no health risks. What they failed

25 to tell you is ATSDR's conclusion that there would be



1229

1 a risk if people drank from their wells. So the only

2 way there would be no risk was if people didn't use

3 their wells. And there are no strong institutional

4 controls that prevent anyone from using their wells.

5 On Page 185 the state claimed they stopped

6 Cotter from receiving waste from Sequoyah Fuels in

7 Oklahoma, which was a half truth. They stopped the

8 second shipment but not the first shipment of equally

9 similar, dangerous, and inappropriate material to be

10 processed and disposed. And then on Page 168 they

11 claim that Cotter funded 2 million in community and

12 environmental improvements, which leaves a false

13 impression. That money was required from Cotter by

14 Court decree to pay for environmental damage, but it

15 didn't go to repair any damage like water wells.

16 Instead, it funded a river walk and a local park

17 outside the immediately impacted area.

18 Basically our group has fought for ten

19 years for transparency and public participation, and

20 we encouraged our community to support three House

21 bills that would improve the public's rights. What

22 I'm disturbed by currently is how inconsistently the

23 health department has applied the laws for public

24 participation. During Cotter's first required

25 license hearing in 2003, we requested an adjudicatory



1230

1 hearing like you're having right now on Cotter's

2 application, and we were refused. We did not have a

3 full-blown adjudicatory hearing. After Cotter's

4 license was submitted and Cotter appealed in 2005, we

5 did have a hearing like this. But, you know, now for

6 this situation, the whole process is reversed.

7 And what's confusing about it is that

8 there have only been two uranium mill license

9 proposals or renewals in Colorado in a decade so it

10 completely surprises us that there can't be some

11 consistency. The public is confused about what is

12 and isn't required. We can't keep our rights

13 straight based on CDPHE's use of their discretion to

14 change the rules of the game which, in our opinion,

15 is often not to the public's advantage.

16 Also, there was a difficulty in preparing

17 these comments for this hearing exacerbated by the

18 fact that changes were made after the environmental

19 report and the EIA documents came out and public

20 comments came out. There's been no comprehensive

21 revised ER or EIA provided. And the only way to

22 discover what those changes were was to wade through

23 dozens of documents submitted in 2010, '11, and '12.

24 There really should have been a revised ER and EIA

25 for us to comment on.



1231

1 Before the health department finalizes a

2 license proposal for the Pinon Ridge mill, we

3 strongly request that a revision of the ER and EIA be

4 required incorporating all the changes since 2009 and

5 a revision that also would require a serious

6 addressing of the noneconomic, environmental, and

7 social effects as required by the Colorado statute.

8 And I thank you very much for being able

9 to give this comment.

10 HEARING OFFICER: Is there anybody else on

11 the telephone that wants to make oral public

12 comments? Is there anybody else in the back of the

13 room now that wishes to make oral public comments?

14 Okay. For the moment we've beaten this

15 horse dead so let's take ten minutes and then figure

16 out where we're going to start with evidence from the

17 lawyers. It's about 10 after 2:00. At about 3:00

18 o'clock, 3:15, at some convenient break point I will

19 ask that same set of questions.


21 HEARING OFFICER: Who's next?

22 MR. STILLS: I believe we have Frank Filas

23 coming up on cross.

24 HEARING OFFICER: Mr. Silas has been

25 previously sworn. We're going to have Mr. Stills on



1232

1 cross-examination, if I understand this correctly.

2 MR. STILLS: Yes.

3 FRANK FILAS,

4 being previously duly sworn in the above cause, was

5 examined and testified as follows:

6 CROSS-EXAMINATION

7 BY MR. STILLS:

8 Q Good afternoon, Mr. Filas. I appreciate

9 getting a chance to chat now and follow up on or do

10 my cross-examination now. Let's just jump right in.

11 You testified you're an employee of Energy

12 Fuels Resources Corporation; is that correct?

13 A That's correct.

14 Q And you work closely with Steve Antony?

15 A Yes.

16 Q And Mr. Antony is currently your direct

17 supervisor; is that correct?

18 A Correct.

19 Q And Mr. Antony has not attended these

20 hearings correct?

21 A Correct.

22 Q Is he here today?

23 A No.

24 Q And Mr. Antony reports to the Energy Fuels

25 board; is that correct?



1233

1 A Yes.

2 Q And in the chain of command you don't

3 report to anyone else but Mr. Antony?

4 A That's correct.

5 Q I suppose the board could reach down, but

6 as far as chain --

7 A Right. I obviously work with a lot of

8 people. And some people are at a higher level than

9 me, but I do report directly to Steve.

10 Q Okay. And the board ends up making the

11 final decisions concerning the proposed mill; isn't

12 that correct?

13 A You know, I'm not sure how that works.

14 I've never been to a board meeting.

15 Q Okay. And before Mr. Antony, you reported

16 to George Glasier?

17 A I reported to Steve, and Steve reported to

18 George.

19 Q Okay. Did you also take your direction

20 from Gary Steele?

21 A No.

22 Q Was Gary Steele someone in the company

23 that provided you information?

24 A Occasionally, not very often.

25 Q Okay. And Mr. Steele has left Energy



1234

1 Fuels; is that correct?

2 A No. Gary is still with us.

3 Q Okay. My mistake.

4 And during the time that the mill

5 application was being prepared, Mr. Antony was among

6 the people helping make budgeting decisions for the

7 corporation; is that correct?

8 A Correct.

9 Q And as supervisor, he approved the budgets

10 for the parts of the project that you worked on?

11 A Yes.

12 Q And you made day-to-day decisions based on

13 the budget provided in the discovery responses that

14 you certified during this proceeding?

15 A I made what? Please repeat the question.

16 Q I'm sorry. That was a long question. My

17 apologies.

18 You provided budgets as part of the

19 discovery responses that you sent us?

20 A I would provide budgets to Steve, and then

21 these budgets usually were adjusted along with

22 everybody else's budgets as part of usually a

23 six-month type of budget review.

24 Q Okay. And those budgets guided your

25 day-to-day decision-making?



1235

1 A To a certain extent, yes.

2 Q Okay. And as an engineer, your job is to

3 bring the project into fruition on time and on

4 budget; is that correct?

5 A To the extent I can.

6 Q And as an environmental permitter, the

7 same thing? Your job is to bring the job into

8 fruition on time and on budget, correct?

9 A You do your best.

10 Q And in 2008 Energy Fuels adopted a capital

11 preservation strategy; is that correct?

12 A Yes.

13 Q And as part of that capital preservation

14 strategy, your ability to use outside contractors to

15 prepare the application was restricted; is that

16 correct?

17 A I would say it was reduced.

18 Q Reduced, okay. And at that time was the

19 ability to carry out the day-to-day handling of the

20 budget linked directly to whether or not Energy Fuels

21 could remain a going concern?

22 A Well, first of all, I think we probably

23 need to define "going concern" because it does

24 have -- our parent company is a Canadian corporation.

25 And according to Canadian rules, if you reach a point



1236

1 where, based on your spending, you cannot guarantee

2 to your investors that you have enough money for the

3 next 12 months, then you have to make a statement in

4 your quarterly report to the effect. And don't ask

5 me exactly what it is, but something to do with

6 there's some concern as far as being a going concern.

7 There's a definition attached to it. And I'm not a

8 financial person so I don't know exactly what that

9 definition is.

10 But I say that because for people sitting

11 out there that are laymen, they might say, oh, you're

12 not a going concern. It has a legal definition, and

13 we are required to report that, if we get into that

14 circumstance.

15 Q But during the period when there was a --

16 you weren't able to use as many outside contractors,

17 there was some question about being close to that

18 line, whatever that line was; is that correct?

19 A Yes.

20 HEARING OFFICER: Did you say a date that

21 went with that?

22 Q (By Mr. Stills) During the period of

23 2008, 2009, 2010 would be the period.

24 A There was some point in time in there that

25 there was -- I understand one time where that was a



1237

1 concern, yes. I don't remember the exact dates.

2 Q Okay. Perhaps this document will refresh

3 your memory as far as the date when that began.

4 HEARING OFFICER: I'll have to look at the

5 numbers.

6 Q (By Mr. Stills) That was November 2008,

7 about the time when the capital preservation strategy

8 went into effect?

9 A Uh-huh.

10 Q Okay. Would you agree that radiation

11 emitted from uranium ore is a human health hazard?

12 A It can be.

13 Q Do you agree that the radiation emitted

14 from the uranium ore that is involved with this

15 project is a human health hazard?

16 A It potentially could be.

17 Q Do you know whether or not the radiation

18 emitted from the uranium ore involved with the Energy

19 Fuels project is a human health hazard?

20 A Under certain circumstances, it can be.

21 Q Under the circumstances in which Energy

22 Fuels is going to carry out this project, do you know

23 whether radiation emitted from the uranium ore is a

24 human health hazard?

25 A If you're talking about a stockpile of ore



1238

1 at the mill, it would be a very low, very low hazard

2 compared to other things.

3 Q Are there any situations where the

4 radiation emitted from the uranium ore would be a

5 more increased human health hazard?

6 A Yes. Of course it would be if, for

7 example, you were mining this ore underground like

8 historically the miners did with poor ventilation or

9 no ventilation. It would be a very high human health

10 hazard, just as radon can build up in the basement of

11 a house. Then it becomes a much higher health

12 hazard. And so that's why I say under certain

13 circumstances, uranium ore can be a health hazard.

14 Q But even in a stockpile, it could be a

15 health hazard; is that correct?

16 A It's a very low level health hazard.

17 Q Do you agree that the radiation emitted

18 from yellowcake is a human health hazard?

19 A Yes, it can be. Again, it's how you

20 handle the product. You can have drums of yellowcake

21 that sit for a long period of time. And after a long

22 period of time, you can build up more radiation. The

23 other thing, obviously if you inhale yellowcake, it's

24 an alpha emitter, and that can be a health hazard

25 under those circumstances. So they are all potential



1239

1 health hazards. It's how you deal with the material

2 that determines at what level that risk is.

3 Q And alpha emitters, those are components

4 of the ore that are particularly dangerous; is that

5 correct?

6 A If inhaled.

7 Q And that can attach to dust, those alpha

8 emitters?

9 A Certainly.

10 Q And do you recall during your testimony

11 comparing the radiation hazard at the mills to the

12 hills around -- the radiation levels that you would

13 encounter in the hills around the mill?

14 A Certainly. We explained to folks during

15 our presentations that we're looking at a background

16 radiation level in the area for a year of about

17 450 millirem per year. And we explained also through

18 modeling that -- and this would be at the property

19 line that you're looking at an incremental dose above

20 that. But it would not be -- it would be at a

21 certain level -- I think typically we were looking at

22 about 10 millirem per year.

23 Q But encountering the hazards from ore in a

24 mill is very different than encountering an outcrop

25 of the Morrison formation; isn't that correct?



1240

1 A Yes. Now you're talking about within the

2 mill, whereas when I was explaining this I was

3 talking about offsite exposure of the public.

4 Q But if someone were to be listening to

5 your presentation, they could think that you were

6 talking about the exposure inside the mill; isn't

7 that right?

8 A Not necessarily. I typically said it was

9 at the fence, property line. And we also talked

10 about what that incremental exposure would be to the

11 nearest residents in the valley as well as in the

12 cities nearby. And we always couched it in those

13 terms.

14 Q But when we have such a dangerous

15 component don't you think it's important to be very

16 clear that there are ways that this material can be

17 very dangerous, and there are ways this material can

18 be hazardous but not as dangerous? Is that not

19 important to lay out for folks so they don't get

20 confused?

21 A I think we were very clear when we

22 presented radiation levels to the public. We talked

23 about what our exposures with our workers would be

24 and what our goals were. These were certainly not

25 10 millirem per year. We were talking about, you



1241

1 know, our goal of meeting 100 millirem per year. But

2 we knew that with most mills, 200 or 300 was not out

3 of the question as far as an incremental dose.

4 Q But my question was, because of the

5 hazards and the deaths that have been involved with

6 uranium for the past 60, 80, whatever the number of

7 years are, don't you think there's a special duty to

8 let people know what those ranges of hazards are so

9 they can know the difference very clearly between the

10 deadly hazards and the mild hazards and the lesser

11 hazards?

12 A Well, I guess we probably have a

13 fundamental difference as far as what we consider the

14 hazards of uranium. As I've indicated before, it is

15 a -- a very highly radioactive substance. It's mined

16 in its natural state. We certainly see the hazards

17 for miners. And as you're well aware, because I've

18 submitted it to Montrose County, many studies have

19 been done on mill workers that worked at historic

20 mills that were exposed to much higher levels than

21 our workers are today. And these studies concluded

22 there was no evidence of a higher cancer rate. So I

23 would submit back to you, I guess, that I don't see

24 those hazard levels as high as you do. However, I do

25 know that if you improperly handle and store these



1242

1 materials, you can certainly -- they can certainly

2 pose a health risk.

3 Q Do you see an important duty to warn

4 people about the hazardous project that you're --

5 A Well, certainly. And that's why we have

6 these very thick health and safety plans and we have

7 emergency response plans. And as you know, there are

8 many, many health and safety procedures that are in

9 our health and safety plans. There's procedures for

10 monitoring our workers. There's procedures for

11 training our workers so they're aware of the risks

12 that are there.

13 When somebody comes on-site to an

14 operating mill, they have to take training at that

15 time, and they are made aware of those risks. So as

16 far as, you know, the work that's actually being done

17 on the mill, at the mill, or if anybody comes onto

18 the site to see the mill, these people are all made

19 aware of the potential hazards.

20 Q But you couldn't really find those, the

21 language warning people of such deadly hazards, in

22 the EA; is that correct?

23 MS. LUCAS: Objection. I haven't heard

24 Mr. Filas characterize anything as "deadly."

25 HEARING OFFICER: The witness can answer



1243

1 the question.

2 A There is no EA. You're referring to

3 the --

4 Q (By Mr. Stills) My apologies. Go ahead,

5 Mr. Filas.

6 A There is no EA. Are you referring to the

7 ER on the EIA?

8 Q I'm referring to the ER, and I appreciate

9 your clarity on that. We get acronyms piling up, and

10 I appreciate you being very clear.

11 A Certainly. You know, my recollection is

12 that the radiation section of the ER did go through

13 and look at risks. And there was a section on risk

14 assessment, and it was summarized in the ER, and it

15 was looked at in detail. And the risk assessment was

16 in the license application and the one that was

17 revised in response to CDPHE's comments. So my

18 recollection is different than yours. I have not

19 read the ER now for quite some time. Maybe there's

20 some part of it that I'm not aware of.

21 Q Is it your view that radiation linked to

22 uranium mining and milling is deadly?

23 A That link to historical mining is deadly

24 in my opinion, yes, but not milling.

25 Q Could modern uranium mining be deadly?



1244

1 A I don't think in this country that it

2 could be. But that's my opinion. And I'm not a

3 uranium miner, and that's not something -- I don't do

4 the health and safety for our mines so I'm speaking

5 more as a generalist now.

6 Q Is it your understanding that --

7 A And I might add, Travis, that any sort of

8 underground mining is always very dangerous. I

9 worked as an underground miner in a coal mine for six

10 years. It's a very dangerous occupation. So I guess

11 I should qualify it that way, underground uranium

12 mining is no more deadly or dangerous than other

13 types of underground mining.

14 Q Uranium mining is no more deadly than any

15 other type of underground mining? Is that your

16 testimony?

17 A That is my opinion.

18 Q That is your opinion. What is that

19 opinion based upon?

20 A That's my opinion of having worked as a

21 underground miner.

22 Q And the basis of your testimony, I believe

23 last Wednesday, is your experience as an underground

24 miner?

25 A I believe my testimony last Wednesday was



1245

1 based on my other experience, as well.

2 Q Because there seems to be some debate

3 about the deadliness of -- well, I'll move on.

4 You testified that Energy Fuels has

5 recently added Denison board members to its own

6 board?

7 A I didn't testify to that. I believe there

8 are, however, two board members that have been added

9 that are associated with Denison Mines, yes.

10 Q And who are those persons?

11 A I don't recall their names. Ron Hochstein

12 was one. I don't recall the name of the other

13 person.

14 Q Mr. Hochstein is very integral to the

15 operation of the White Mesa mill; is that correct?

16 A No. Ron Hochstein is on our board. I

17 don't believe he has any interaction anymore. He

18 certainly did when he was president of Denison Mines

19 USA. I don't believe he's actively involved in

20 operating White Mesa at this time.

21 Q Do you have any involvement with the

22 operations of White Mesa?

23 A Mine are pretty tangential, I should say.

24 I work with people who are, but I do not have

25 responsibility at the White Mesa mill.



1246

1 Q Okay. And isn't it true that Energy Fuels

2 has recently announced a halt to mining and

3 processing Colorado plateau ores at the White Mesa

4 mill?

5 A We announced a halt to most of our mines

6 in Utah. That include the Denarius main and the

7 La Sal and Beaver. The Pandora continues to operate

8 in Utah.

9 Q And that was because of the low grade and

10 low value of the ore on the Colorado plateau at this

11 time; is that correct?

12 A I would state that a little differently.

13 I would say that that's because of the very low price

14 of uranium right now. At $40 a pound, our management

15 decided that those mines should not be operated at a

16 loss.

17 Q If you could take a look at that press

18 release. It was sent to all counsel.

19 A Uh-huh. Is there any particular part you

20 want me to look at?

21 Q Just take a look at it. In general, do

22 you recognize that press release?

23 A I do recognize it, yes.

24 HEARING OFFICER: Is there a date on it?

25 THE WITNESS: Yeah; October 17, 2012.



1247

1 MR. STILLS: I'll submit this as the next

2 exhibit.

3 HEARING OFFICER: 19.

4 (Sheep Mountain Exhibit 19 admitted.)

5 (By Mr. Stills) As part of this press

6 release, Energy Fuels says it's going to focus on

7 lower cost uranium production. Is that what it says?

8 A I saw that, yes.

9 Q So the Colorado plateau ore and --


11 Q (By Mr. Stills) So the Colorado plateau

12 ores are a higher cost to produce ore than the

13 Arizona ores?

14 A That's correct. I shouldn't say it's a

15 higher cost to produce the ore. It's a higher

16 cost -- they're a higher grade ores. So it's about

17 the same cost to produce the ore, but you get more

18 uranium out of a higher grade ore so you can still

19 make a profit, while you may not be able to at the

20 lower grade ore.

21 Q Okay. And lower grade ore is just that,

22 it's much more subject to closure of a mill during

23 lower price periods; is that correct?

24 A Much more subject to closure of the mine

25 and putting on standby until the prices come up, yes.



1248

1 Q And if a mill is relying completely on

2 those Colorado plateau ores, that mill would be much

3 more vulnerable to shutdowns due to lower uranium

4 prices; is that correct?

5 A That's correct.

6 Q And at White Mesa Energy Fuels is now in

7 the business of processing industrial municipal

8 radioactive waste known as alternate feed; is that

9 correct?

10 A We do that as well as process ores, yes.

11 Q And is the alternate --

12 MS. LUCAS: I object to this line of

13 questioning. I don't understand the relevance to the

14 Pinon Ridge application.

15 HEARING OFFICER: Well, it goes to the

16 question of whether alternative fuels will ultimately

17 get considered at this facility. I'll allow it.

18 MR. STILLS: Would you read back my

19 question, please.

20 THE REPORTER: You were in the middle of

21 the question, and there was an objection.

22 MR. STILLS: Okay.

23 Q (By Mr. Stills) So processing alternate

24 feed is actually a lower cost production alternative

25 than either Arizona ores or Colorado plateau ores; is



1249

1 that correct?

2 A Yes.

3 Q And that's because you get paid to receive

4 the materials you're going to process; is that

5 correct?

6 A Correct; instead of having to pay for

7 them, yes.

8 Q So you --

9 A So it's a lower --

10 THE REPORTER: One at a time.

11 MR. STILLS: Thank you. We're trying to

12 hurry. We'll take our time and get through it

13 quicker, then.

14 Q (By Mr. Stills) So one business model is

15 you pay people to bring in the things that you

16 process, and in the alternate feed business model you

17 get paid to take the things you're going to process;

18 is that correct?

19 A I wouldn't refer to them as models. I

20 don't work with business models. But I agree with

21 the general concept, yes.

22 Q Okay. And as far as very directly related

23 to the current proposal, wouldn't resuming the long

24 practice -- long-standing practice of shipping to the

25 White Mesa mill provide an alternative to processing



1250

1 at a new mill in the Paradox Valley?

2 A I really don't understand your question,

3 Travis. Could you restate it?

4 Q Might Energy Fuels begin shipping ore from

5 this area to White Mesa if it restarts processing?

6 A Oh, shipping ores from Western Colorado to

7 the White Mesa mill? Is that what you're asking me?

8 Q Correct.

9 A Yes. We could do that.

10 Q And in fact, that's what you sought to do

11 previously; isn't that correct?

12 A Before the mergers we did approach Denison

13 to see if we could make a deal to ship ores from the

14 Whirlwind mine in Mesa County to them, but we could

15 never reach an agreement.

16 So if that was the question, I hope I

17 answered it.

18 Q That was the question, I believe.

19 So now that there's no barrier to shipping

20 to White Mesa, that is an alternative that Energy

21 Fuels might consider; is that correct?

22 A Certainly.

23 Q So that should be an alternative that the

24 public should be able to consider when looking at all

25 of the impacts and options; is that correct?



1251

1 A An alternative in -- are you saying within

2 an environmental report or an EIA, or are you talking

3 about just an alternative in general?

4 Q Alternative in general.

5 A Shipping ore to the White Mesa mill is an

6 alternative in our minds, yes.

7 Q In your minds. So if it's an alternative

8 in the project proponent's minds, it should be an

9 alternative in the environmental assessment; isn't

10 that correct?

11 A But remember, that alternative was not

12 available in 2009 and 2010 when these documents were

13 written. If we are going to go back and take another

14 look -- or I should say if CDPHE is, then that may be

15 something that they should look at this point in

16 time.

17 Q So your testimony is that the

18 environmental assessment does not reflect current

19 conditions?

20 A The environmental impact assessment

21 reflects the conditions that existed when it was

22 written, which was in late 2010 and early 2011.

23 Q And it's your testimony that the

24 environmental report produced by Energy Fuels does

25 not reflect current conditions concerning the White



1252

1 Mesa mill?

2 A Correct.

3 Q Did your mill -- does the EA talk about

4 the Ticaboo site?

5 A I assume you're talking about the

6 environmental report?

7 Q Your environmental report. Thank you.

8 HEARING OFFICER: The which site?

9 MR. STILLS: Ticaboo.

10 HEARING OFFICER: Spell it.

11 MR. STILLS: T-i-c-a-b-o-o.

12 A I believe it did. I don't recall what

13 statements were made about that mill.

14 Q (By Mr. Stills) Do you recall that the

15 history of that mill is that it was built in Arizona,

16 operated for -- if it operated at all -- an

17 extraordinarily short amount of time, and it sat idle

18 for 10, 15, 20 years?

19 A I wasn't aware that it was built in

20 Arizona. Was it shipped up there, then?

21 Q It must have been because it's always been

22 in Utah.

23 A Okay.

24 Q Thank you for correcting me.

25 A The Ticaboo mill I believe operated for



1253

1 three or four months back in the early '80s and has

2 been on standby since that time, yes.

3 Q So there's another built mill in the

4 region that's not processing ore at this time; is

5 that correct?

6 A That mill is incomplete at this time.

7 They sold off portions of that mill, and it would

8 take major refurbishment to bring that into position

9 where it could produce. I also might add that it is

10 not -- it was not located -- when that ER was

11 written, it was not located near any of Energy Fuels

12 Resources' properties.

13 Q But it's located near them now; is that

14 correct?


16 HEARING OFFICER: If I can interrupt, is

17 that an Energy Fuels facility?

18 THE WITNESS: No. It is -- Uranium One

19 has that facility.

20 HEARING OFFICER: Okay.

21 Q (By Mr. Stills) And Uranium One, they're

22 a Russian owned company now?

23 A I believe so.

24 Q And have you attempted to negotiate with

25 the Russian company for use of their mill?



1254

1 A Not necessarily for use of their mill. We

2 have had negotiations with them as far as possibly

3 property acquisitions. But we've signed

4 confidentiality agreements, and I'm not at liberty to

5 discuss those one way or the other.

6 Q And it's outside of what I was trying to

7 ask so I'll move on.

8 A Okay.

9 Q But you considered the alternative of

10 Ticaboo but saw that was in a condition that didn't

11 warrant further investigation; is that correct?

12 A I would say that was a very short

13 consideration. That was an easy decision to come to.

14 Q So in the language of the environmental

15 reports it was an alternative and eliminated from a

16 detailed review; would that be correct?

17 A You know, I don't recall what it said in

18 there.

19 Q I'm sorry. I wasn't asking about what it

20 said. But in the language of environmental studies,

21 Ticaboo would be an example of an alternative that

22 was identified and eliminated from detailed review;

23 is that correct?

24 A I don't believe that's what was done in

25 the ER, but it certainly -- it certainly would have



1255

1 been I guess if it would have been evaluated as an

2 alternative.

3 Q So in your view it's something -- that

4 type of a category includes something like Ticaboo

5 that's out there, but it's so remote in distance and

6 construction that it wouldn't warrant really a

7 serious analysis? It's that kind of a project?

8 A Again, since we didn't really evaluate it,

9 I'm a little reluctant to say that. But my personal

10 opinion would be yes.

11 Q And your environmental report did not

12 consider ablation; is that correct?

13 A Correct.

14 Q Is ablation a credible technology for

15 uranium production?

16 A For certain types of ores it would be.

17 But it's a very new technology that will require many

18 years of development. I also don't necessarily agree

19 that it would be an appropriate technology for the

20 salt wash ores.

21 Q I'm sorry. I didn't hear you. You said

22 it would not be an appropriate technology for salt

23 wash ores?

24 A Some people believe that it would be. My

25 personal opinion -- and I'm not a processing person.



1256

1 I'm an environmental manager. I believe that the

2 salt wash ores are too fine grained to allow a clean

3 separation between ore and nonore. However, there

4 are other ores that appear to be very amenable to the

5 process. But at this point in time, I don't think

6 enough R&D has been done to say that salt wash ores

7 are not amenable or that other ores are amenable.

8 It's just my initial opinion, looking at it from a

9 distance.

10 HEARING OFFICER: Can you spell the name

11 of the technology you're talking about.

12 MR. STILLS: A-b-l-a-t-i-o-n.

13 DR. GROSSMAN: Excuse me. Could you just

14 give a brief explanation of what it is?

15 MR. STILLS: No. We need to keep moving.

16 We'll get you on a break on that. I apologize for

17 that.

18 Q (By Mr. Stills) But it is your testimony

19 that some people who have more experience than you do

20 think it might work for salt wash ores?

21 A It has been proposed, yes.

22 Q By whom?

23 A I think it's been -- well, to be honest

24 with you, all I've heard is hearsay so I can't really

25 testify to, you know, who says it might work for salt



1257

1 wash ores. I've dealt with it with our Sheep

2 Mountain project up in Wyoming, and that's where I've

3 been involved with possibly looking at ablation.

4 Q Has George Glasier promoted that

5 technology for the salt wash ores?

6 A I don't know if he was promoting it for

7 the salt wash ores or for our ores up at Sheep

8 Mountain. I was not involved in those discussions.

9 The only way I've been involved with ablation is on

10 the Sheep Mountain project.

11 Q Thank you. I appreciate that.

12 So let's assume that someday it becomes

13 economic again to process Colorado plateau ores.

14 A Remember, we are still mining at the

15 Pandora so I wouldn't say that it's not economical

16 now for all mines.

17 Q But there are plans to close down the

18 Pandora soon?

19 A It sounds like it in six, nine months,

20 something like that.

21 Q So if it's not closed down, it's heading

22 there right now; is that correct?

23 A We believe that it will be shut down.

24 Q Okay. So back to -- let's dispose with

25 the small details around the edge. Let's just assume



1258

1 that it becomes economic to process Colorado plateau

2 ores. If you accept that assumption, the White Mesa

3 mill would actually provide an alternative for

4 consolidating mill waste into one site; isn't that

5 correct?

6 A Yes. It would provide an alternative for

7 that, yes.

8 Q So avoiding the creation of a new tailings

9 impoundment would better address Part 18, Appendix A,

10 Criteria 2 that you testified to; isn't that correct?

11 A It would be correct if you assumed that

12 there was only a limited pool of uranium mines that

13 would be producing. Obviously at one time here in

14 this area there was half a dozen different mills and

15 6500 tons per day being processed. So it just

16 depends upon -- the White Mesa mill has the capacity

17 right now, I believe, of 1500 tons per day. And it

18 could probably produce at its nameplate capacity at

19 2,000 tons per day. Anything over that, you would

20 need another mill.

21 Q Or you could expand the White Mesa mill to

22 take more ore, is that correct, as an alternative?

23 I'm not --

24 A I don't know what --

25 Q As an alternative, not as a business



1259

1 model, but as a practical alternative?

2 A I don't know if the White Mesa mill could

3 be expanded economically. I just don't know enough

4 about the processing side of things.

5 Q But an alternative analysis would give us

6 an answer to that question; isn't that correct?

7 A It could try to, I guess. You know,

8 again, we could seek that answer out and see if the

9 mill could be expanded realistically.

10 Q And I know some people might not like the

11 fact that I'm saying things like that, but I'm

12 looking at assumptions and exploring.

13 And Appendix A, Criteria 2 talks about the

14 nonproliferation of tailings; isn't that correct?

15 A Certainly.

16 Q So back to my question. Isn't it correct

17 that keeping the ore on one site would actually

18 better serve Appendix A, Criteria 2? That's correct,

19 then, right?

20 A Yes.

21 Q That alternative was not analyzed in the

22 environmental report; is that correct?

23 A That is correct. And again, that's

24 because the environmental report was written in 2009

25 before the companies merged.



1260

1 Q And when did the companies merge? That

2 was June 2012; is that correct?

3 A The end of June 2012.

4 Q And this proceeding was noticed August 6,

5 2012?

6 A The proceeding was noticed?

7 Q This hearing began with a notice issued by

8 the CDPHE on August 6, 2012?

9 A I'll take your word for it. That sounds

10 about right.

11 Q Okay. So you had the opportunity before

12 we went down this road to update your environmental

13 report; isn't that correct?

14 A I think that would have been a very

15 difficult task to do. And it was not -- the license

16 was set aside so there was no reason to update an

17 environmental report for a license that was set

18 aside.

19 Q Didn't the application remain in place?

20 A Yes.

21 Q And the environmental report remained in

22 place?

23 A Travis, I'm not saying that we can't go

24 back and revise the environmental report. But

25 wouldn't it make more sense if you got everybody's



1261

1 comments and then had CDPHE indicate what they might

2 need? Why would we -- what do you call it --

3 unilaterally go and update our environmental report.

4 There would be no reason to do that.

5 Q Well, before going into a hearing, doesn't

6 it make sense to make sure that the underlying

7 documents reflect the reality as we're going in?

8 A I think large documents like this, you

9 don't just update them over the weekend. There has

10 to be a regulatory-driven process. And in this

11 current position where we are, where we are taking

12 additional testimony and collecting additional

13 information -- when I use the word "we" I should

14 probably just say CDPHE is. But we are, as a company

15 also, listening to what people have to say. I think

16 you wait until you're ready to take care of all the

17 issues and not just maybe one issue that you've

18 identified at this point in time.

19 Q So the public came into this proceeding

20 with a false view of what was going on with Energy

21 Fuels if they were to read the environmental report;

22 isn't that correct?

23 MS. LUCAS: Objection, Your Honor. It

24 speculates on what the public view was coming into

25 the hearing.



1262

1 HEARING OFFICER: Sustained.

2 Q (By Mr. Stills) It's your testimony that

3 the environmental report does not reflect current

4 conditions; is that correct?

5 A Correct, although I would say a large part

6 of the environmental report still does. There are

7 certain things that change in a three-year period.

8 Q How long do you estimate it would take to

9 update the environmental report based on some of the

10 concerns you've identified?

11 A At this point in time, I couldn't tell

12 you. The bottom line is, we would have to take a

13 close look at it and see if CDPHE requested that we

14 update it. We'd have to take a close look at it and

15 make a determination at that time.

16 Q You testified that Energy Fuels' staff's

17 experience and training is relevant to meeting

18 Regulation 3.9.1; is that correct?

19 A Could you paraphrase what 3.9.1 says?

20 Q It says that the company's experience and

21 training needs to demonstrate -- I'll paraphrase.

22 Let me not get into a dissertation on the

23 law. I'm sorry. You testified that Energy Fuels'

24 staff's experience and training is relevant to these

25 proceedings; isn't that correct?



1263

1 A Correct.

2 Q And part of Energy Fuels' experience is

3 drawn from former Cotter employees; is that correct?

4 A Correct.

5 Q And do those employees include Dick White?

6 A Yes.

7 Q Do they include contractor Richard Cherry?

8 A Yes.

9 Q Anyone else who came directly from Cotter?

10 A Not that I can think of.

11 Q And Richard Cherry, was he the CEO of

12 Cotter?

13 A I can't remember what position he had. I

14 know he was, you know, fairly high up the ladder at

15 Cotter, yeah.

16 Q Okay. And George Glasier is no longer CEO

17 of Energy Fuels; is that correct?


19 Q Does Mr. Glasier have any contractual

20 connections to Energy Fuels?

21 A No, not at this time.

22 Q So he has nothing to do with this project?

23 A I believe he's still a stockholder, but

24 I'm not sure. That's just my understanding.

25 Q As far as your knowledge of people



1264

1 operating within the company, he's not --

2 A That's correct.

3 Q The relevant experience includes your own

4 experience; is that right?

5 A Correct.

6 Q And Energy Fuels relies on your experience

7 to show it can act in accordance with Colorado's

8 radiation regulations; isn't that correct?

9 A I'm one of those people, yes.

10 Q Okay. And you testified that one of your

11 accomplishments includes permitting the Whirlwind

12 mine; is that correct?

13 A Yes.

14 Q And were you the lead for permitting the

15 water treatment facility there?

16 A Yes.

17 Q And was Energy Fuels provided a permit

18 under the Clean Water Act based on your work as

19 permit lead?

20 A Yes.

21 HEARING OFFICER: Which mine are we

22 talking about?

23 MR. STILLS: The Whirlwind mine. It's one

24 of the mines that was identified as feeding this

25 mill.



1265

1 Q (By Mr. Stills) Did you reference the

2 treatment technology as barium chloride treatment in

3 your testimony?

4 A I don't recall doing that in my testimony,

5 but yes, it is a barium chloride treatment system at

6 the Whirlwind.

7 Q And were radium and selenium among the

8 target constituents?

9 A Radium definitely; selenium also, yes.

10 Q And the water treatment plant resulted in

11 discharges that were cited for noncompliance with

12 water quality -- Colorado Walter quality standards;


14 A No. They were never cited. We had

15 exceedances of several individual standards over time

16 that included radium once or twice while we were

17 still in the early stages of getting that water

18 treatment plant operating correctly. There was also

19 exceedances of selenium during the early period of

20 water treatment. I believe the water treatment plant

21 operated over the last year with no exceedances of

22 individual standards; or if there were, there were

23 only one or two.

24 Q Is it your testimony that the water

25 treatment plant operated in 2012?



1266

1 A No. It operated -- let's see. It

2 operated up through 2009, late 2009.

3 Q And it's your testimony that there was no

4 noncompliance at the --

5 A I didn't say that. I said that if my

6 memory serves me right, there were none or very few

7 over the last -- over the last 6 months to 12 months

8 that we operated that system.

9 MS. LUCAS: Your Honor, object to the

10 relevance of the line of questioning, or at least I'd

11 like to hear what the relevance is.

12 HEARING OFFICER: Can you make an offer?

13 Where are you going?

14 MR. STILLS: I'll make an offer. I'm

15 going to demonstrate that his relevant experience on

16 permitting and engineering are linked to

17 noncompliance with Colorado regulations. 3.9.1

18 concerns whether the company has the experience to

19 comply with state regulations. I believe I'm going

20 to show that the Whirlwind mine is an example where

21 they have not, in fact, complied and where that was

22 directly relevant to Mr. Filas' experience.

23 MS. LUCAS: I would submit that the

24 permitting of a facility and its operation are two

25 separate actions and that the fact that it may or may



1267

1 not have operated with or without citation is not

2 necessarily relevant to how it was permitted.

3 HEARING OFFICER: I'll hear the cross, and

4 I'll hear the redirect.

5 MS. LUCAS: Are these submitted with your

6 exhibit list?

7 MR. STILLS: No. They're coming in to

8 impeach the witness on cross.

9 MS. LUCAS: Impeach him --

10 MR. STILLS: We'll get there.

11 HEARING OFFICER: This is Exhibit 20.


13 MR. STILLS: So I've offered No. 20, and

14 we're looking at a document titled A. Or the file is

15 A, November 7, 2007, selenium.PDF. Do you recognize

16 this document, Mr. Filas?

17 A Yes.

18 Q And what does the RE -- I'm sorry. First,

19 what is the date?

20 A December 27, 2007.

21 Q And could you read the RE, please.

22 A It says, Submittal of November discharge

23 monitoring report and notification of noncompliance.

24 Q And do you recall what the noncompliance

25 was for?



1268

1 A No.

2 Q But you do recognize this document?

3 A Yes.

4 Q And in fact, you were on the list of

5 people who received this document directly; is that

6 correct?

7 A I would have been, yes.

8 Q So you have a role in the operations of

9 the mines; is that also correct?

10 A I don't have a role in operating them, but

11 I do have a role in reporting noncompliance if it

12 occurs.

13 Q So you have a -- part of your role is for

14 regulatory compliance --

15 A Correct.

16 Q -- at these mines?

17 A Correct.

18 Q And this mine did not comply with

19 regulations after you designed it; is that correct?

20 A It did not comply with some of the

21 individual limits. And that is not something that is

22 uncommon on for water treatment plants upon start-up,

23 to have noncompliance on some individual parameters.

24 Q But this treatment plant never came into

25 compliance; is that correct?



1269

1 A No.

2 MS. LUCAS: I'd like to clarify the answer

3 to that. That was a double negative question. Can

4 you please ask it --

5 MR. STILLS: Withdraw.

6 I guess I don't know if you've had a

7 chance to look at these, but I have a series of about

8 eight or nine documents. All I would like to put

9 them forward for is for authentication. I submit

10 that each one of the documents on that CD was

11 received by Mr. Filas. He's testified that he's the

12 person who receives these. If there's a problem with

13 authentication, we can come back to it. I would like

14 to submit them in evidence.

15 MS. LUCAS: Let me take a moment to look

16 at them, please. This is the first time I've seen

17 them.


19 MS. LUCAS: These appear to be authentic

20 documents for Energy Fuels' self-reporting to the

21 Colorado Department of Public Health and Environment.

22 And as such, we don't have an objection to their

23 authenticity, but we preserve objection to relevance.

24 HEARING OFFICER: All right.

25 Q (By Mr. Stills) And again, these



1270

1 documents were all provided to you. And the

2 violations include Ph, total suspended solids, whole

3 effluent toxicity, selenium, and radium?

4 MS. LUCAS: I have an objection to the

5 characterization as violations. These are not

6 citations or violations. These are reporting of

7 exceedances by the company.

8 HEARING OFFICER: I will note the

9 objection. What was your question?

10 Q (By Mr. Stills) The noncompliance

11 involved with these Clean Water Act permits included

12 Ph, total suspended solids, whole effluent toxicity,

13 selenium and radium; isn't that correct?

14 A Yes. Those at one point or another were

15 at least reported at least once over that two-year

16 discharge period.

17 Q And the Whirlwind mine has been allowed to

18 fill with water; isn't that correct?

19 A Correct.

20 Q It's currently underwater?

21 A The bottom portion is flooded, yes.

22 Q Has the water treatment plant that you

23 designed and testified about been redesigned yet?

24 A I'm working on it.

25 Q And you also testified that you led the



1271

1 effort to design a radon cap for the Atlas tailings

2 pile?

3 A I didn't lead the effort, but I was

4 involved in it and was involved in some of the

5 changes that were made for an interim cover, yes.

6 Q What was your role?

7 A My role was to revise the cover to meet

8 the questions that were being posed by the NRC at

9 that time, concerns.

10 Q So you weren't project lead on the --

11 A I was not the project --

12 Q You weren't project lead on the Atlas

13 tailings cap that you testified about; is that

14 correct?

15 A I was not the project manager. I was the

16 project engineer for a period of time.

17 Q And what years were those?

18 A I believe it would have been possibly

19 1996, but I can't say for sure.

20 Q Was that before or after Atlas went

21 bankrupt?

22 A Well, they were still in business at that

23 time so I would guess that it was before.

24 Q And you designed the cap, though, was your

25 testimony; is that correct?



1272

1 A No. I was involved in the cap design or

2 the revision to the cap. And I wrote the technical

3 specifications for putting down the cap at one point

4 in time or constructing the cap.

5 Q And when Atlas went bankrupt, an adequate

6 bond was not in place; is that correct?

7 A I don't know.

8 MR. STILLS: Exhibit 21. It's actually

9 from the record, a paper copy. This is from the

10 district court record PL-AR 021772, Page 1-9 of the

11 environmental report.


13 Q (By Mr. Stills) And let's see how we do.

14 I'll have you read it from here so you can face this

15 way. Here you go, Mr. Filas.

16 A What would you like me to read?

17 Q The first paragraph, please.

18 A The Atlas mill and Moab -- is there a date

19 on this document?

20 Q Are you familiar with this document?

21 A No. Is this my document? Is this an

22 environmental report document? What is this?

23 Q An excerpt from the environmental report

24 produced for this proceeding.

25 A "The Atlas mill in Moab is one of the few



1273

1 unreclaimed tailings facilities left in this area.

2 This facility was a Title II facility with both

3 private and federal funding obligations for closure;

4 however, Atlas went into bankruptcy and its bond and

5 Moab assets were managed by a bankruptcy trustee with

6 the intent of conducting in-place closure of the

7 facility. Ultimately, however, Congress made the

8 Moab site a Title I site and DOE decided to move the

9 tailings to an off-site repository due to the

10 facility's location on the Colorado River floodplain.

11 This work, which is funded by the federal government,

12 was started in May 2009."

13 Q So the cap that you helped design for

14 in-place closure was ultimately rejected by the

15 Department of Energy; is that correct?

16 MS. LUCAS: Objection. That's not what

17 this paragraph says.

18 HEARING OFFICER: Well, I'll allow the

19 question.

20 A I don't know what the DOE's opinion was on

21 the cap. I was not involved with the project at that

22 time. It was always my understanding that they felt,

23 whoever the movers and shakers were, that they

24 decided that offsite disposal was preferred versus

25 onsite disposal or in-place reclamation.



1274

1 Q (By Mr. Stills) So the Atlas tailings

2 pile, including the cap, are currently being

3 excavated and moved to a Crescent Junction disposal

4 cell; is that correct?

5 A That's correct.

6 Q And do you consider the Crescent Junction

7 facility a state-of-the-art facility?

8 A I don't know anything about the Crescent

9 Junction facility other than where it's generally

10 located.

11 Q And with this, wouldn't you say that this

12 Atlas bankruptcy highlights the need for a financial

13 surety that addresses potential design failures?

14 A Give me that question again.

15 Q Would you agree that the Atlas facility

16 and its bankruptcy highlight the need for a financial

17 surety that addresses design failures?

18 A You know, I don't know enough about that

19 to say for sure. If the bond was adequate for

20 in-place closure and in-place closure had been

21 approved, then I would say that they met their

22 obligations; but if it wasn't, then they wouldn't

23 have. But I'm not familiar enough with the bonding

24 portion of that project and what transpired

25 afterwards to have an opinion.



1275

1 Q So it's your testimony that bonding for a

2 company's current intent is sufficient?

3 A This is a very unusual situation, Travis,

4 where a facility that was originally started by the

5 U.S. government in the early '50s and was operated

6 for over 30 years was entirely moved to another

7 location. And there were those who felt that it was

8 fine where it was, and obviously the decision-makers

9 made a decision to move it. It's really too

10 complicated of a situation for me to weigh in with

11 the very limited knowledge I have. I did work on

12 that facility for a time as an engineer. And I --

13 the work I did I was -- I felt was done

14 professionally.

15 Q And you did your best job on the design;

16 is that correct? You did your best, you said. I'm

17 sorry.

18 A Well, I did what was asked of me. And

19 yes, I thought I did a good job on it.

20 Q And that potential or that attempt did not

21 succeed at getting the job done? I'm not saying it's

22 your fault. I'm just saying it didn't get the job

23 done? It had to be moved?

24 MS. LUCAS: Objection. The testimony was

25 simply that someone decided it had to be moved. It



1276

1 had nothing to do with the job that was done.

2 MR. STILLS: I'll withdraw that.

3 Q (By Mr. Stills) I just want to be clear

4 here on what I'm trying to ask. And my apologies

5 because it's taking me a couple minutes.

6 Folks had a plan. You were involved in

7 that plan at Atlas; is that correct?

8 A I was working for a consulting company

9 that put that plan together for Atlas.

10 Q And your testimony is that a bond only

11 needed to be in place to cover that particular plan

12 to cap in place; is that correct?

13 A The bond that is in place should be

14 adequate to cover the approved reclamation plan. If

15 that reclamation plan changes, then the bond has to

16 be changed accordingly.

17 Q Are other potential reclamation

18 alternatives important to bonding?

19 A Only the one that is approved.

20 Q Only the company's plan is relevant to

21 a --

22 A No. Only the plan --

23 Q -- calculation of the bond?

24 A Sorry. Only the plan that is approved by

25 the regulating agency is what you bond for.



1277

1 Q And you also testified that you were

2 involved in groundwater flume at Church Rock; is that

3 correct?

4 A That's correct. I was a consultant. It

5 was my job to evaluate the remediation and to -- we

6 also looked at background standards for the site as

7 part of that work.

8 Q And the Church Rock groundwater flume

9 hasn't been fully remediated yet today; is that

10 correct?

11 A I don't know. I haven't worked on that

12 project for many years.

13 Q You're not aware of the costs so far to

14 clean up Church Rock?

15 A No.

16 Q Was the work you did at Church Rock at the

17 time considered to be state of the art?

18 A It was what was typically done at that

19 time for groundwater remediation. It had a pump-back

20 system to remove contaminated water.

21 Q And it's your testimony that bonding only

22 needed to be considered for that one approach that

23 was currently under operation for cleaning the ground

24 water?

25 A You would typically bond for whatever the



1278

1 agencies decided what was required to remediate.

2 Q And in your view, bonding does not

3 consider possibilities that the design may not work?

4 A Some level of contingency is typically

5 included in bonds, and bonds are periodically

6 reviewed by agreement states or the NRC to make sure

7 that they're current.

8 Q Okay. Your testimony was also that

9 alternate sites exist for what is now known as the

10 Pinon Ridge mill or the PR mill; is that correct?

11 A We looked at alternate site.

12 Q And you toured the sites with Colorado

13 Department of Public Health and Environment before

14 deciding to buy the current site; is that correct?

15 A We toured two sites in East Paradox Valley

16 on one afternoon with CDPHE. They were doing an

17 inspection of the Durita site, which was not too far

18 away. And we made arrangements for them to come and

19 look at these sites before making a decision on

20 whether either of them was suitable.

21 Q You didn't tour the Durita site with

22 CDPHE?

23 A No.

24 Q You didn't tour the Pioneer site with

25 CDPHE?



1279

1 A No.

2 Q Were those already eliminated from your

3 consideration by that time?

4 A Yes, they were.

5 Q And of the sites, the two sites that you

6 toured, which ones were those, again?

7 A There was the Carver site, east of where

8 Pinon Ridge is now, about 2 miles east, and there was

9 the Pinon Ridge ridge site.

10 Q Is the Pinon Ridge site referred to by

11 other names?

12 A It's sometimes referred to as the Cooper

13 site.

14 Q So the Cooper site and the Pinon Ridge

15 site are synonymous?

16 A No -- yes.

17 Q Okay. Thank you. As with some of our

18 acronyms, I kind of circled back through those so I

19 wanted to be clear.

20 A Sure.

21 Q And at the time, did George Glasier own

22 any potential sites that you were considering?

23 A Yes. He had a piece of property over by

24 the Durita site that we felt that if we could acquire

25 additional property in that area that was suitable,



1280

1 that we might be able to expand that area

2 sufficiently to allow for a mill.

3 Q But the Durita site had the

4 characteristics, the physical site, and criteria that

5 could have allowed a site there, had you been able to

6 buy property; is that correct?

7 A In retrospect, probably not. There was

8 not enough area right at the Durita site so that

9 would have been basically an impossibility. George's

10 land was not contiguous with the Durita site, but it

11 was in close proximity, within half a mile. And in

12 retrospect, looking back at that, I think that the

13 best we could have done was 160 acres, which our

14 consultants at that time said was adequate. I've

15 since -- after doing additional permitting on this

16 project, I don't think that site would have been

17 large enough or suitable for a 500-ton-per-day mill.

18 Q Did you look at any federal land?

19 A We looked at the Rio Algom site, which is

20 partially private and partially federal. Again, that

21 one, we didn't feel there was enough useable area

22 left and remaining to site the mill there. And it

23 was also in close proximity to residents.

24 Q Did you look at any wholly federally owned

25 sites?



1281

1 A No.

2 Q Why not?

3 A It has been my past experience that

4 federal land managing agencies are very reluctant to

5 permit processing on their land. Typically -- having

6 worked with them in other mining industries, they

7 generally want you to put your processing facility on

8 private or state land. And they are amenable to

9 obviously mining the resource if you have valid

10 claims, but they're very reluctant in most cases to

11 allow you to process on federal lands.

12 Q And it's true that you avoid that land

13 because you don't want to conduct a federal EIS; is

14 that correct?

15 MS. LUCAS: Objection. That's not what

16 the witness testified to.

17 HEARING OFFICER: No, but he can answer

18 the question.

19 A I certainly can.

20 In this case, that was an added incentive.

21 The available land or available federal land that may

22 have been appropriate would have been on Bureau of

23 Land Management managed land. And the Bureau of Land

24 Management does not have much expertise in uranium

25 milling. And they would have been required to, if it



1282

1 was the state of Colorado or state of Utah, establish

2 a memorandum of understanding with the state agency

3 and move forward with that EIS. And we felt that

4 that permitting, that time period, would be very,

5 very long for permitting. That, more than anything,

6 was just an added incentive not to try to permit a

7 facility on federal land.

8 Q (By Mr. Stills) And how long -- you would

9 estimate that time to be about three to five years if

10 you were to go through the federal process; isn't

11 that correct?

12 A I don't know if I said three to five

13 years; if I did, I was being very optimistic.

14 Q And in your testimony you testified that

15 Pioneer site was eliminated from consideration due to

16 the level of scrutiny it would receive by San Miguel

17 County; is that correct?

18 A I think it was the level of objection that

19 we would have received from San Miguel County, not

20 the level of scrutiny.

21 Q So your concern was San Miguel County

22 would have objected to the mill being located there?

23 A Certainly.

24 Q San Miguel County is a state regulatory

25 body who has to adhere to the state laws and the



1283

1 county laws; isn't that correct?

2 A I would hope so.

3 Q Energy Fuels owns the Sunday mine complex

4 in San Miguel County; isn't that correct?

5 A That's correct.

6 Q And those mines have been permitted and

7 approved by San Miguel County; is that also correct?

8 A Correct.

9 Q The Pioneer site met all the physical

10 siting criteria; is that correct?

11 A It met them, yes.

12 Q So the real reason for eliminating Pioneer

13 from the study of alternatives is your view that

14 Montrose County would object less than San Miguel

15 County; isn't that correct?

16 A That was one of two reasons.

17 Q You also testified about the Cooper site,

18 which was eliminated from detailed analysis in the

19 environmental report; isn't that correct?

20 A No. I think you're referring to the

21 Carver site. The Cooper site ultimately became the

22 Pinon Ridge site.

23 Q I believe that might have been why I asked

24 that earlier question. I had that backwards.

25 So the same question: You testified that



1284

1 the Carver site was eliminated from detailed analysis

2 in the environmental report?

3 A Correct.

4 Q And the Carver site was eliminated because

5 it might involve review by the BLM and an EIS,

6 correct?

7 A No. The Carver site was on private land.

8 MR. STILLS: If I could submit an exhibit.

9 This is from the record. It's EFPH 0090888.

10 HEARING OFFICER: I'll mark it as 22.


12 MR. STILLS: So I guess this is the Cooper

13 site.

14 MS. LUCAS: Can we get a clarification of

15 what you mean by "from the record."

16 MR. STILLS: It's in the discovery

17 disclosures that were entered into the record I think

18 as Exhibit 12.

19 MS. LUCAS: Okay.

20 Q (By Mr. Stills) So this is the Cooper

21 site, I guess. The Cooper site, was it configured to

22 avoid a power pole on BLM land?

23 Go ahead and --

24 A Thank you.

25 Q -- chat with me, if you don't mind.



1285

1 A I'd like to read the letter. I haven't

2 seen it.

3 Q Okay. Was a power pole moved on the

4 current site to avoid BLM review?

5 Again, I'm sorry. We'll come back to the

6 document. I'm just asking.

7 A Okay. The reason I'm looking at that,

8 that has nothing to do with a mill site. That has to

9 do with the siting of an air monitoring station. And

10 they thought that they had put the air monitoring

11 station on Cooper's property, who we were making an

12 agreement with or had already made an agreement to

13 put that air monitoring station in there. But it was

14 not located properly, and where they had flagged it

15 was actually BLM land. So we needed to move it back

16 onto Cooper property, and we certainly didn't want to

17 spend probably at least six months trying to get a

18 right-of-way from the BLM to put that air monitoring

19 station in. So that was -- that's what that refers

20 to. It does not refer to a mill site.

21 Q But if that monitoring station had gone in

22 on BLM land, there would have been no question that

23 it would have triggered the need for an EIS for the

24 entire mill; isn't that correct?

25 A Not necessarily. Zach Rogers wrote that,



1286

1 and he works for me. And that was I think just his

2 overall concern, that it could trigger a connected

3 NEPA action. But the bottom line is the air

4 monitoring station would have taken -- even if it was

5 not a connected action, it would have taken a long

6 time to permit so we definitely didn't want to put it

7 on BLM land.

8 Q Can we agree that just because you're on

9 private land you don't avoid the need for an EIS, on

10 that fact alone; is that correct?

11 MS. LUCAS: Objection. There's been no

12 agreement to that that I've heard from this witness.

13 A I disagree.

14 Q (By Mr. Stills) Can you explain?

15 A In order for a NEPA analysis to be done,

16 whether it be a categorical exemption, an

17 environmental assessment, or an EIS, there has to be

18 certain triggers. And one of them is a federal

19 action. If you're on private land and there's no

20 federal action involved that triggers a NEPA

21 analysis, then you do not have to do an EIS, an EIA,

22 or a cat ex, short for categorical exemption.

23 Q And it's true that you work very hard to

24 avoid those NEPA triggers in putting together these

25 mill proposals?



1287

1 A Certainly once we realize that we might

2 not have to have a federal action involved, it was

3 certainly something that I tried to avoid because it

4 adds time and money to a project.

5 Q Why is that?

6 A Because you have a large federal permit

7 requirement that you have to meet that otherwise you

8 wouldn't have to.

9 Q But the CDPHE's environmental impact

10 analysis process would be a low cost alternative to

11 that. What was that your view?

12 A No. This would just have been an

13 incremental cost and probably a longer time period if

14 it went to -- if you were looking at, say, an EIS.

15 Obviously air monitoring stations would most likely

16 be a lesser action, but it still adds time and money.

17 And as a business entity, if you can avoid a certain

18 permit time delay or if you can avoid additional

19 costs, you do it. It's just part of business.

20 Q I'm again a bit confused. How would it be

21 more expensive to do a federal EIS than the state

22 EIA?

23 A Well, you would have had to have done

24 both. In fact, if you take a look at our Sheep

25 Mountain project we're doing two EISs, one for the



1288

1 BLM and one for the Nuclear Regulatory Commission.

2 It would certainly be a lot better to do one, but

3 that's what I'm required to do.

4 In this case, if we can keep it as a state

5 EIA and license, that's what we wanted to do. If,

6 for example, the EPA would have said that in order

7 for us to get our air permit for radon emissions, if

8 they would have said that was a NEPA action, we would

9 have been going through the NEPA process with the

10 EPA. But they said it was not, it did not trigger

11 NEPA, so we did not do it.

12 Q But NEPA's been triggered for components

13 of this mill now, hasn't it?

14 A No.

15 Q Really?

16 A That's true. No.

17 Q No component of this mill is being

18 subjected to scrutiny in a federal EIA?

19 A That is correct.

20 Q Okay. Back to the parcels for a minute.

21 So CDPHE and Energy Fuels discussed alternate

22 locations, right?

23 A Well, we showed them those two locations,

24 and they thought that the one was much better than

25 the other.



1289

1 Q So if you've got two and you're going to

2 choose one, that's alternatives. Is that a good way

3 to define it?

4 A Yes.

5 Q Okay. And if one's better than the other,

6 that's another way to define alternatives, right?

7 You've got two, and you're going to choose one?

8 A So you have an alternative, two

9 alternatives, yes.

10 Q But in the EIA there was no analysis of

11 the relative impacts of these two alternatives; isn't

12 that correct?

13 A Are you talking about the environmental

14 report?

15 Q I appreciate your clarification. For some

16 reason -- I don't know why -- I confuse Cooper/Carver

17 and EIA and ER. But I appreciate your corrections.

18 There's no analysis of the impacts across

19 these potential parcels in the environmental report?

20 A The alternatives were looked at, and they

21 were discussed briefly, and then they were not

22 evaluated in detail.

23 Q Their impacts were not compared to each

24 other?

25 A There was -- the discussion described each



1290

1 of these sites. And basically what we did was a

2 fatal flaw analysis. If there was a fatal flaw, it

3 was not evaluated further.

4 MR. STILLS: Okay. Would this be a good

5 time for a break?

6 HEARING OFFICER: Sure. How much more do

7 you anticipate?

8 MR. STILLS: That's part of what I want to

9 do on the break.

10 HEARING OFFICER: Okay. Let's take a

11 break first. Let's take 10 minutes.


13 HEARING OFFICER: All right. We're going

14 to interrupt for a few minutes the cross-examination

15 of Mr. Filas while we hear from Catherine Peterson.

16 Are you Ms. Peterson? Is Catherine

17 Peterson here?

18 MS. PETERSON: I'm right here.

19 HEARING OFFICER: You want to come up and

20 make a comment in addition to the one you gave me in

21 writing?

22 MS. PETERSON: That's from another person.

23 HEARING OFFICER: Okay. Would you like to

24 make a comment?

25 MS. PETERSON: If it's okay.



1291

1 HEARING OFFICER: That's where you stand,

2 right there by the guy with the fancy orange

3 sweatshirt or whatever it is.

4 Go ahead, Ms. Peterson.

5 MS. PETERSON: Well, I'm here again. And

6 as I realized after listening to the hearing, we are

7 really years away from these jobs, and there could be

8 appeal processes. And at this point I feel like

9 there's speculators and corporations making money,

10 and I feel like they're pitting us against each

11 other. We don't quite have as many people from the

12 area here today. But I feel like they're already

13 making money. They're a corporation basically

14 concerned with their profit and loss statements.

15 They don't really -- like listening to the gentleman

16 earlier when he was examined about the different

17 sites, he made, you know, a conscious effort to talk

18 about profit and loss statements and whether or not

19 he had to really look at the environment closely.

20 Now, that's because they're corporations.

21 That's why they can do that. They only -- they're

22 responsible to their shareholders. But we're like

23 the citizens here, and we're the citizens of this

24 community. And we're giving -- I mean, we really

25 need to stop this because we're kind of giving up --



1292

1 we are giving up the control of our future to

2 corporate entities and their -- when we talk about,

3 you know, we have these rights as citizens and local

4 control, when we bring in these big corporations with

5 unsustainable industries, we're not really going to

6 get good teachers here because they're not going to

7 want to live here. We are probably not going to get

8 good professionals because they're not going to want

9 to be around here.

10 As far as like -- I can't really see that

11 it's going to improve our quality of life or improve

12 the quality of life over here because it's going to

13 have -- it's going to become a sacrificed area that

14 people aren't going to want to talk about. The real

15 estate agents over around Telluride and around this

16 area and maybe over by Cortez or Dove Creek, they're

17 not going to want to talk about it over here because

18 there's nothing between these mill sites and these

19 places they're going to haul stuff and these trucks

20 on the road from any of these areas that are pristine

21 at this point.

22 Now, there has been sort of a slump in the

23 overall -- like people have had a hard time moving

24 forward. We're having a hard time moving forward in

25 our country because we seem to be like pitted against



1293

1 each other on like big, unimportant -- you know, or

2 just things that -- we all want to be better people.

3 We all really probably know that this mill and mining

4 uranium is probably wrong and probably not right for

5 our children and their children. And it takes a lot

6 of courage to try to join together and say, well, I

7 can be -- I know I want to be a better person, and

8 that's sort of what we're going to have to do. We're

9 going to have to be better people, try to join

10 together to make our lives in this area more

11 sustainable. And we have to do it locally.

12 We can't have a big corporation coming in

13 and telling us, okay, well, I am -- you're 20.2 miles

14 from Norwood. And Norwood -- this is a threat I'm

15 pulling here. It's about the economics of the area.

16 I'm an equestrian. Norwood has the only public horse

17 arena event center in the whole Four Corners area.

18 The equestrian --

19 (Speaker phone interruption.)

20 HEARING OFFICER: Go ahead.

21 MS PETERSON: Here you are 20.2 miles from

22 Norwood to your co-op. The co-op's got bridles and

23 saddles and feed, and it's associated with a co-op

24 over in Fruita and Grand Junction. And we have an

25 underused event center with all this space. And I



1294

1 found out -- I went all the way to Yellow Jacket to

2 get my hay this year, and you had hay over here in

3 Nucla, as I understand it. But I didn't know that,

4 and I don't have as close of ties as I should.

5 But we have a whole equestrian industry

6 that has a lot of money involved in it. And over

7 here -- like just going past Disappointment Valley is

8 a world renowned equestrian team-building, leadership

9 place called Buffalo Woman Ranch. They are right on

10 the other side of Disappointment Valley with a huge

11 international clientele. These women bought that

12 land over 20 years ago. They've been there all that

13 time. People come from Germany and like everywhere,

14 Europe and all over the United States to take these

15 week-long seminars about horses and humans, healing

16 each other.

17 Well, the equestrian industry has a lot of

18 money in it. It's never really been developed in

19 this area. We have a huge event center. We could --

20 just like Telluride has festivals, we could have a

21 lot more agricultural and equestrian, which is, like

22 I said, again, it's a high dollar industry which is

23 moving into corporate needs; like I said, a future

24 for the horse and humanity. Now, this actually ties

25 into the fact that we, in our county, have a wild



1295

1 horse herd.

2 Now, we all have to work together because

3 this is a tourist -- you know, this is something.

4 And we've got the tourists in this area. Not only

5 that, we actually -- Grand Junction, with its huge

6 medical complex is not going anywhere soon. Okay.

7 They're coming out here to recreate. We're coming

8 over here to recreate. We want to develop these

9 mountain bike trails. Moab's further than this area.

10 We should be just coming here to ride our mountain

11 bikes. We should be buying our hay right here. We

12 should be using this event center for agricultural

13 exhibits and bringing in top-of-the-line equestrians.

14 We should be encouraging equestrians. Like this

15 climate here is like -- it's like perfect for the

16 high dollar consumer right there with his arena and

17 everything and a place to have shows, which is what

18 they have to do when they have those kinds of horses.

19 So that's that side note, that threat

20 about the fact that we have not developed this

21 potential, again, in the ranching and with the

22 sustainable range management that could happen in

23 Disappointment Valley and the people who are already

24 trying in this area and have been for the last, you

25 know, 30 years to develop this. But, you know,



1296

1 really now is the time for us to join together, to

2 stop being pitted against one another like as -- and

3 be citizens, kind of being better people and trying

4 to take control of getting the type of professionals,

5 teachers, climate, biodiversity, recreation, and not

6 bring this scourge, which is already a scourge upon

7 the planet, right into this area where we could do so

8 much better if we just worked together like citizens.

9 All right. Thank you very much. Thank

10 you, Judge.

11 HEARING OFFICER: Uh-huh.

12 MR. STILLS: Ready to resume?

13 HEARING OFFICER: Just a second. Have you

14 got some more you want to say?

15 MR. GLYNN: Yeah.

16 HEARING OFFICER: Go ahead. State your

17 name again, if you would.

18 MR. GLYNN: David Glynn, G-l-y-n-n. I'm a

19 resident of Colorado. I have here two tapes that I

20 would like to submit and a video. And the purpose of

21 this is these tapes are a San Miguel County record of

22 a meeting that was held I believe in May of 2008, the

23 first meeting on the mill that was held in San Miguel

24 County in front of the county commissioners there.

25 We were there to film it, record it. We were denied



1297

1 the ability to film it by Energy Fuels because of

2 their objections from the CEO at the time, George

3 Glasier. The video will show that. I'm not sure if

4 that's in the San Miguel record.

5 The part that's in the San Miguel County

6 record here that I think is important is when George

7 Glasier got up in front of the county commissioners

8 and the public and stated flatly that the mill was

9 going to be built and there was nothing that we, the

10 people, could do to stop it or government agencies,

11 that it was going to happen. And the reason I want

12 to present this is because it shows the total

13 disregard that a company like Energy Fuels has for

14 the will of the public or of the laws, for that

15 matter.

16 So whom may I hand this to?

17 HEARING OFFICER: Me.

18 MR. GLYNN: The other thing that I would

19 like to say is I'd like to underscore what I was

20 saying the other day, talking about near disasters

21 and disasters that have actually happened. It's not,

22 in my opinion or my feeling, the local -- the mining

23 and the milling that is the most dangerous. It's the

24 end product. There would be no reason to mine or

25 mill uranium if not for the needs of the end product.



1298

1 These needs that I'll talk about are nuclear power

2 plants and nuclear weapons. This ore that they are

3 mining could go into either. More probably than not,

4 it will go into both eventually.

5 I wanted to speak a little bit, too, about

6 the Rio Puerco, which is considered the most -- the

7 biggest, rather -- the biggest radioactive spill in

8 this country and, until Fukushima happened, the

9 second largest in the world. Now, this wasn't a

10 nuclear power plant exploding. This wasn't a nuclear

11 bomb exploding. This was a mill tailings waste pile

12 that breached its earthen berm containment, a berm

13 that was only two years old at the time. It released

14 11 thousand -- no -- 1100 tons of radioactive waste

15 into the Rio Puerco along with 93 million gallons of

16 toxic mine effluent.

17 The Rio Puerco -- after this incident the

18 water in the river went from safe drinking water

19 standards to over 7,000 times the safe level for

20 drinking water. This is mill tailings that are so

21 often made to look rather benign by the people that

22 are proposing the mill; 7,000 times beyond the legal

23 limit. The water, of course, was deemed unsafe to

24 drink. Until this day, the people that have

25 livestock in this area -- this is an 80-mile stretch



1299

1 of the river -- are told not to water their stock in

2 this, with this water. We don't know what kind of

3 correlation -- or if you water your stock out of

4 radioactive water, if the animals can become

5 radioactive, what kind of transmission is there to

6 the people that consume this? The livestock there

7 have been reported, especially recently or after the

8 incident, that they were -- a lot of lambs and cattle

9 were being born without limbs, for example. There's

10 been a noticeable increase in deaths and disease of

11 humans since this accident.

12 Mill tailings are very dangerous. They

13 need to be contained not just for a few years but for

14 thousands of years. So the economy of -- we've

15 looked at this. You know, we've heard some of the

16 testimony of how close Energy Fuels is to insolvency.

17 Things come and go. We've all experienced this in

18 the economy, especially lately. What happens a

19 hundred years from now when there's no money to

20 maintain the mill tailings, to maintain the site? I

21 think it's very shortsighted for us to believe that

22 we can manage this kind of waste for that long. And

23 again, it isn't just the waste here, but it's the end

24 product. It's like the near disaster that I spoke of

25 the other day in Missouri that could have



1300

1 contaminated thousands of miles of the best farmland

2 on the planet forever, as far as in all practicality.

3 Another thing I wanted to speak of, we've

4 heard talk of the Whirlwind mine. Now, the Whirlwind

5 mine has been promoted by Energy Fuels as their

6 flagship mine. I don't know how long they've owned

7 it, how long it's been in their hands. But the

8 Whirlwind mine, if that's a flagship, we're in big

9 trouble. I would like to ask Mr. Filas --

10 HEARING OFFICER: No. I'm sorry. You

11 don't get to ask questions.

12 MR. GLYNN: Okay. Well, maybe somebody

13 else can ask this off of this testimony. But my

14 question would be if they are involved in any of the

15 settlements with former employees, monetary

16 settlements that are happening now as we speak.

17 If anyone here has been driving around the

18 region the last few years, they've probably seen big

19 billboards posted, asking people to call a certain

20 number if they were employees in the uranium industry

21 over the years. I have a friend who used to work for

22 the Whirlwind mine. He just was granted a settlement

23 of $180,000 for his health issues stemming out of

24 working in the Whirlwind mine. I think these are

25 things that we've got to keep in mind when we're



1301

1 going through this permitting process. Uranium is

2 not safe by any stretch of the imagination. This is

3 something that should be left in the ground.

4 I believe that's about all I wanted to

5 say. I just want to re-underscore the fact that it

6 is not just the milling and the mining, but it is the

7 end product, the stuff that we have to keep such a

8 close eye on for hundreds of thousands of years. And

9 remember that these products, this is where they go.

10 They go into nuclear fuel for power plants, into

11 nuclear weapons. Thank you.

12 HEARING OFFICER: Do I have anybody else

13 in the room that wants to make oral public comments?

14 MR. HARRISON: My name is Max Harrison.

15 HEARING OFFICER: Max Harrison?

16 MR. HARRISON: Yeah, Max Harrison. I've

17 been doing some research on this, and it seems to me

18 from the discovery of radioactive material the

19 problem has always been how to contain it and public

20 safety. And so far, I don't think there's any real

21 solutions. And the reality of that I think needs to

22 be addressed. And don't think the uranium industry,

23 the nuclear power plant industry, and these people

24 are going to attend to this problem unless people

25 like you stand up for people like us and say no to



1302

1 this advancement in these particular uranium mills

2 and what it is that they want to do in this area.

3 I have a Gamma-Scout that measures

4 radiation, and I take it with me frequently. And

5 it's all over the board. There is background

6 radiation from these tailings piles. It always

7 spikes anytime you go by an old mill site. I used to

8 fly fish down there at Silver Creek where the

9 Superfund cleanup was down there. And I'm down there

10 and I'm fishing -- I've been going down there for

11 years, and all of a sudden there's this big cleanup.

12 And come to find out I've been hanging out, going

13 down there with friends and this and that, in a

14 radioactive area from a mill that was just left. You

15 know, there's no signs. There's nothing there to

16 tell you that you may possibly be standing in a

17 radioactive fill, whatever that means.

18 And it seems to me that the jury seems to

19 be out on what is safe exposure and what isn't. And

20 there's many reports out there that say there is no

21 safe exposure to radioactive material, and I have a

22 tendency to agree with them. Thank you for taking

23 your time out to come out and hear us all and have

24 these hearings about this because this is big.

25 From what I understand, Henry Ford was



1303

1 warned about the possible consequences of emissions

2 from the internal combustion engine, and now we know

3 it's real, and it's something that we have to address

4 worldwide. And I'm afraid that this radioactive

5 material being dug up out of the ground and

6 intensified, made into plutonium and all these things

7 for bombs and bomb testing and this and that, that

8 one day we're going to pick our heads up and say, Oh,

9 my God, we're being radiated, too. I don't think

10 this is a future that any of us want to face and say

11 we did nothing about it.

12 Thank you for your time. I also have a

13 report I wanted to --

14 HEARING OFFICER: Okay. Before you leave,

15 there's a sign-up sheet over by the door. I need you

16 to fill out one of them, if you would.

17 MR. HARRISON: All right. You want this

18 now?

19 HEARING OFFICER: Yes. Thank you.

20 Anyone else who's here?

21 MR. EDWARDS: Judge Dana, yes. I spoke

22 earlier. There's one, I think, very important thing

23 which I have yet to hear addressed. And I don't know

24 if it would be better -- if I'm allowed to speak a

25 second time today quickly. I was getting lengthy,



1304

1 and I left this out.

2 HEARING OFFICER: Which is what?

3 MR. EDWARDS: Transportation and the

4 potential -- I've listened to dialog between

5 attorneys and witnesses regarding the possible

6 expansion of this mine from 500 tons to a thousand to

7 1500 on down and also to the bringing in of municipal

8 water radionuclides waste I guess from the

9 municipalities around and also the possibility of

10 some waste coming down from Canon City and these

11 other places even higher, making this a radioactive

12 repository.

13 And I do remember when I testified back in

14 2001, whenever it was, regarding the Shattuck

15 materials coming into this area, that one of the big

16 issues was transportation, the amount of trucks, the

17 type of materials that would be carried over these

18 highways. And I think that was one of the reasons

19 that materials were not brought to Uravan but rather

20 shipped by train somewhere else. That's just what I

21 understand from what came about. But I haven't heard

22 anyone really addressing, beyond the initial

23 application for 500 tons, what will be coming, what

24 kind of expansion there would be, and what effect

25 that would have on the traffic DOT requirements,



1305

1 et cetera, et cetera, for this area. If I could

2 include that or I could E-mail it to you --

3 HEARING OFFICER: No, you got it. It's

4 in. Mr. Tarlton did offer some testimony yesterday

5 about alternative fuel or materials sources or

6 alternative feed sources. I don't know if you were

7 here or not.

8 MR. EDWARDS: I was here for part of that,

9 but I had to leave in the afternoon so I did not get

10 to hear the entire testimony.

11 HEARING OFFICER: Anyone else? Yes,

12 ma'am.

13 MS. VANEK: I spoke earlier, and I have

14 one point; one point.

15 HEARING OFFICER: Your name, again?

16 MS. VANEK: Jolana Vanek. I spoke

17 earlier. And when I just listened to the questioning

18 between the attorneys and Mr. Filas, I was keenly

19 aware that during the meeting in Nucla there was a

20 great concern of the public. There were 31 people

21 who spoke about the dust concerns because there is

22 dust generated. And part of the application is --

23 what is it -- 40,000 tons of dust generated a year

24 permitted for. And when I spoke to Mr. Seth Low from

25 the EPA afterwards he said to me, Don't worry about



1306

1 it much. Only 3 percent of the 40,000 pounds is

2 highly radioactive because as it gets processed by

3 sulfuric acid, it becomes highly radioactive. So

4 don't worry about it. It's just 3 percent.

5 But I like calculators. I like math.

6 It's a high amount. What I came across was somebody

7 went to the CDPHE offices and discovered, by the

8 Freedom of Information, an E-mail that was discussing

9 the senior planner of Montrose wanting to know about

10 the health issues regarding radioactive dust. And

11 the answer from CDPHE from -- I think it was Phil

12 Egidi -- was that it would take a while to put

13 something together, and time was short. It was only

14 three weeks to the final verdict by the Montrose

15 board of commissioners.

16 So the health department sent the senior

17 planner, Mr. John Washbush, to Montrose. He was

18 referred to Energy Fuels for expertise. And he was

19 told that Energy Fuels has all the health experts it

20 needs. And I was thinking it reminded me of the

21 tobacco companies testifying that there is no danger.

22 And when I heard Mr. Filas saying yes, there is

23 definitely a danger connected to radioactivity dust,

24 there's a full 1 percent that would escape the --

25 what are they called -- the scrubbers.



1307

1 And I have been thinking about 1 percent

2 of whatever they process, which is -- I don't know

3 how many tons a year. It's 500 tons a day. So

4 1 percent of that processed stuff will escape from

5 the chimney. And I thought, that's huge. And being

6 sent to the operator/applicant for health

7 information, that really concerns me, to be receiving

8 for my health information. Thank you.

9 HEARING OFFICER: Anyone else? Anyone on

10 the phone that wants to make a public comment?

11 Mr. Filas, you want to come back up here.

12 I asked you before the break how much more

13 you had. I'll ask again.

14 MR. STILLS: In the spirit of

15 Dr. Grossman's answer a couple days ago, I'm trying

16 to aim long and come in short; probably an hour and a

17 half. Thank you. I think I've only had an hour or

18 so.

19 HEARING OFFICER: No, I'm not quarreling

20 with what you have.

21 MR. STILLS: I'm just looking at the clock

22 and where I am in my day and things. It actually has

23 nothing to do with this hearing so I'll keep my

24 editorials to myself.

25



1308

1 CROSS-EXAMINATION (resumed)

2 BY MR. STILLS:

3 Q Good afternoon again, Mr. Filas. I

4 believe that you testified that Energy Fuels'

5 tailings disposal methods provide a modern

6 alternative to past practices; is that correct?

7 A Yes.

8 Q But the tailings disposal that you chose

9 to submit with the application is not the only means

10 to dispose of uranium tailings; is that correct?


12 Q There are other alternatives out there?

13 A Under current law there are two

14 alternatives: conventional disposal and what we call

15 paste tailings.

16 Q And your application did not analyze --

17 I'm sorry. Your environmental report did not analyze

18 the use of paste tailings?

19 A Yes.

20 Q But that is an accepted method?

21 A Yes.

22 Q And dry stack tailings disposal, are you

23 familiar with that?

24 A That's the same as paste tailings.

25 Q There's no difference between paste



1309

1 tailings and dry stack?

2 A They both accomplish the same thing.

3 They're not fundamentally different. The EPA allows

4 two different methods. You can either go with the

5 conventional tailings, as we have, or you can dewater

6 your tailings and put them in a repository.

7 Q And when you submitted the application,

8 you knew that paste tailings was an available

9 alternative; is that correct?

10 A Correct.

11 MR. STILLS: I'd like to submit for the

12 next exhibit Document EFPH 0147872. This is a

13 document titled "Pinon Ridge Mill License

14 Application, Potential Technical Issues, Frank Filas,

15 11-25-09."

16 HEARING OFFICER: Is this part of the

17 record?

18 MR. STILLS: It's part of the record.

19 HEARING OFFICER: It's marked as 23.


21 Q (By Mr. Stills) So in 2009 when you

22 submitted the application, you knew that the state

23 was interested in paste tailings disposal; is that

24 correct?

25 A I knew that one person at the state was



1310

1 interested in it.

2 Q And can you read where it starts with "The

3 state likes this concept."

4 A "The state likes this concept because

5 there would be little to no chance of leakage of

6 tailings solution and the tailings would already be

7 dewatered, which would facilitate reclamation. They

8 also favor having only 10 acres of tails open at any

9 one time" --

10 Q I'm sorry. Go ahead and continue with --

11 A -- "rather than the 80 acres allowed for

12 conventional phased tailings operation. Note, EPA

13 may add evaporation ponds under this umbrella, which

14 would limit us to 40 acres of tailings."

15 Q So there are several alternate

16 configurations of the tailings identified in that one

17 paragraph; is that correct?

18 A There's two; phased conventional and paste

19 tailings.

20 Q So that's three?

21 A No. A phased conventional tailings --

22 Q So that's --

23 A -- is one --

24 THE REPORTER: Excuse me. One at a time.

25 Q (By Mr. Stills) Is phased conventional



1311

1 tailings one?

2 A Yes.

3 Q A cap at the end, conventional tailings,

4 is two?

5 A No.

6 Q That's not the same as phased?

7 A That's all part of phased. It's not two.

8 You have phased conventional tailings. You cap them

9 at the end.

10 Q Can you cap as you go, a continuous cover

11 approach?

12 A You can -- to a certain extent you can cap

13 as you go with paste tailings, but it would not be a

14 final cap. It would just an interim cap, much like a

15 landfill.

16 Q So that's another alternative? An interim

17 cap phased, and at the end you cap the whole thing?

18 A We're looking at two alternatives. We're

19 looking at the two that the EPA allowed. One is a

20 conventional tailings system, and the other is a

21 paste tailings or stacked tailings.

22 Q So we are in agreement that there's at

23 least two, even if we can't agree on how many

24 configurations and --

25 A There are two.



1312

1 Q -- how many alternatives --

2 A There are two.

3 Q -- how many variations --

4 Okay. We can stop there. But no analysis

5 of those alternative methods for tailings disposal

6 were in the environmental assessment even though you

7 knew in 2009 -- were in the environment report even

8 though you knew in 2009 that that was something that

9 the state would like to know about?

10 A This was -- this memo was written after

11 the environmental report was submitted.

12 Q When was the environmental report

13 submitted?

14 A November 18, 2009.

15 Q So less than a week?

16 A A week later, yes.

17 Q But you didn't go back and update the

18 environmental report, did you?

19 A No.

20 Q After this time did anyone from CDPHE ask

21 you to analyze paste tailings alternative disposal

22 methods?

23 A No.

24 Q Was it ever discussed again?

25 A I don't recall.



1313

1 Q So as a member of the public, there's no

2 way to read the application documents and know about

3 paste tailings; is that correct?

4 A Correct.

5 Q And you also testified that the industry

6 has made advances in tailings disposal methods since

7 the '80s back when Energy Fuels Nuclear owned White

8 Mesa; is that correct?

9 A Correct.

10 Q So there's no alternative -- I'm sorry.

11 There's no comparison of any improvements of Energy

12 Fuels' design in the environmental report, though,

13 was there?

14 A I'm not sure I understand your question.

15 Could you expand on it?

16 Q Did the environmental report look at an

17 alternative which was, build as we've always done,

18 and another alternative that says, build as Energy

19 Fuels would like, that resulted in a comparison of

20 the impacts?

21 A I still don't understand your question.

22 Q Was there any way to know whether or not

23 Energy Fuels' design was better than past designs in

24 the environmental report?

25 A I'm not sure. I don't recall the exact



1314

1 explanation that went with the text in the


3 Q So you were brought in as an expert in

4 environmental permitting; is that correct?

5 A That's one of the things I do, yes.

6 Q But you don't know what an alternatives

7 analysis does?

8 A I do know what an alternatives analysis

9 does. I don't know if that was evaluated in the


11 Q And you were responsible for preparation

12 of the environmental report; is that right?

13 A Correct, but that was --

14 Q And you testified during these proceedings

15 as to the compliance of that document I believe for

16 two days last week; is that correct?

17 A Parts of two days maybe.

18 Q Okay. And Energy Fuels has not contacted

19 the Navajo Nation regarding cultural resources at the

20 site?

21 A Our archaeologists -- we did not contact

22 anybody. Our archaeologists contacted I believe

23 three of the Ute tribes.

24 Q And those were the only tribes that were

25 contacted, correct?



1315

1 A That's my understanding.

2 Q So the Hopi tribe, the Acoma tribe, the

3 Navajo tribe, all of whom have descendants in this

4 area, were not contacted?

5 A To the best of my knowledge, they were

6 not.

7 MR. STILLS: I'm going to talk about some

8 things that are designated confidential, but I'm

9 going to avoid the confidential aspects so that we

10 don't have to close this public hearing. I believe

11 that through the submission of papers, as we

12 discussed before, we can talk about the CH2M Hill

13 basic engineering design and those other documents.

14 And folks in the public will have to deal with it,

15 but as a party we're just going to go ahead and make

16 reference and avoid the confidential aspects.

17 MS. LUCAS: I have a question about that.

18 We haven't designated any aspects of the CH2M Hill

19 report nonconfidential except for those that were in

20 the application itself. Are those the ones you're

21 going to talk about?

22 MR. STILLS: I'm going to talk about their

23 basic existence, but I'm not going to talk about

24 anything that is not publicly known about those

25 documents.



1316

1 MS. LUCAS: How do you define what's

2 "publicly known about those documents" other than

3 what's in the application? Are you going to be

4 referring to application material, I guess is what

5 I'm asking.

6 MR. STILLS: I'm not going to be referring

7 to the details in those documents at all. I just

8 wanted to make you aware, as a courtesy, that we'll

9 be near that subject matter.

10 MS. LUCAS: All right.

11 Q (By Mr. Stills) So CH2M Hill provided

12 basic engineering design for the project. When was

13 that?

14 A I believe the final report was issued in

15 early 2009.

16 Q Is that design still being relied upon?

17 A Yes.

18 Q Have changes been made to that design?

19 A We've looked at what we could leave out

20 for a 500-ton-per-day mill. And there was a few

21 tanks that we could take out, but otherwise the

22 milling configuration would remain the same. No

23 final decision was made on whether we would not take

24 those tanks out during construction because it would

25 be a matter of whether we could come in afterwards



1317

1 and install them. In other words, if it's something

2 that we could facilitate adding it later on, I think

3 that's the approach we would have taken. But there's

4 been no final decision. In other words, the design,

5 yes, is still the same.

6 Q But you provided those changes to CDPHE in

7 2011; is that correct?

8 A We provided a drawing showing which of

9 those tanks we might not install as part of

10 construction.

11 Q And CDPHE did not update any of its

12 materials based on those updates; is that correct?


14 Q So the mill is still designed to produce

15 with a production capacity of a thousand tons per

16 day; is that correct?

17 A It could conceivably produce a thousand

18 tons per day if we had all the permits.

19 MR. STILLS: Would you read back my

20 question, please.

21 (Last question read.)

22 Q (By Mr. Stills) I'm sorry. Go ahead.

23 I'm just doing this while you answer the question.

24 A Okay. Yes.

25 Q What was the reason that you updated the



1318

1 design?

2 A We never did update the design.

3 Q What was the reason you made changes to

4 the design?

5 A As far as -- are you talking about the

6 drawing we submitted in 2011 showing which tanks we

7 might eliminate?

8 Q Among other changes, but yeah, that's what

9 I'm talking about.

10 A You know, I don't really recall. CDPHE

11 may have asked us that question. I'm not sure that

12 it was a burning issue, though.

13 MR. STILLS: Submit EFPH 0053278 as an

14 exhibit. It's already in.

15 HEARING OFFICER: It will be marked as 24.


17 Q (By Mr. Stills) This is an E-mail from

18 that time period, and I use it so I can refer to

19 things that are confidential. Can you read where it

20 starts with, "We are currently permitting."

21 A Where's that at?

22 Q I'm sorry. I should also say this is a

23 E-mail from you; is that correct?

24 A Correct.

25 Q And it's dated July 5, 2011; is that



1319

1 correct?

2 A Yes.

3 Q Okay. Again, after the --

4 A "We are currently permitting the

5 1,000-ton-per-day mill with Colorado Air Pollution

6 Control and have the opportunity to fix the

7 application and modeling if the CH2M Hill design is

8 incorrect. Thanks for your help with this."

9 Q You're permitting a 1,000-ton-per-day mill

10 for the Colorado Air Pollution Control?


12 Q Of the Colorado Department of Public

13 Health and Environment?


15 Q And they won't let you put a smaller

16 program -- project forward, saying you're going to

17 run it smaller and then permit it later? They see a

18 whole project here, and they require you to permit

19 the whole project; is that correct?

20 A Partially.

21 Q But the design of the mill is also

22 changing as to boilers, locations of things? You're

23 tweaking the design; is that correct?

24 A No, that is not correct.

25 Q Okay. Like I said, I'm trying to -- I'll



1320

1 deal with the other stuff elsewhere.

2 The mill is designed based on a long-term

3 plan to increase processing to 1,000 tons per day;


5 A Yes, if the conditions are allowed for it

6 later on. In other words, if economically it makes

7 sense, that was the plan.

8 Q And Montrose County will allow you to run

9 the mill as hard as you can run it as long as you

10 don't exceed a yearly average; isn't that correct?

11 A Correct.

12 Q Take a look at that document for me while

13 I deal with the computer. Are you familiar with that

14 document?

15 A No, I'm not.

16 Q You've never seen it before?

17 A Not that I recall.

18 Q Did you certify Energy Fuels' response to

19 discovery, which included the production of

20 documents?

21 A I don't recall doing that.

22 Q Are you aware that your signatures is on

23 the Energy Fuels discovery response in this case?

24 A Okay. It could have been if the attorneys

25 asked me to sign something. Understand, we gave you



1321

1 probably hundreds of thousands of documents. Did I

2 see each one of them? Probably not.

3 Q You just threw them out the door?

4 A No. I looked at my own files, but I did

5 not look at every other file that was submitted.

6 Q But if we have this and it's stamped EFPH

7 0053906, this is an Energy Fuels document? There's

8 no question about that?

9 A No, it looks like an Energy Fuels

10 document. And if it was in what we gave you, then it

11 is definitely an Energy Fuels document.

12 Q And this is a three step plan dated March

13 of 2012; is that correct?

14 A Yes.

15 Q Let's move through this document. Are you

16 aware -- you're not aware of this document?

17 A No.

18 Q Does this look like something that Steve

19 Antony normally prepares?

20 A This looks like something that Steve

21 Antony may have prepared in -- is this something that

22 goes with this document (indicating)?

23 Q Thank you. It's not. It's a stapling

24 error.

25 A It looks like something Steve Antony may



1322

1 have prepared in response to questions from the board

2 as to how you could expand this mill in the future.

3 Q Okay. And there's actually a plan for

4 producing the mill -- or improving --

5 MS. LUCAS: Your Honor, I object to the

6 line of questioning on this document that Mr. Filas

7 has just testified he's not familiar with.

8 HEARING OFFICER: Well, it's part of the

9 record. I'll allow him to examine it. He's not

10 taking authorship of it, but I'll allow questions

11 about it.

12 Q (By Mr. Stills) So there's the plan as of

13 March of this year, and that's before Judge Mullen's

14 order which would have changed the plan. Do you

15 recall Judge McMullen's order?

16 A His order changed the plan?

17 Q You don't have a license.

18 A Okay. We don't have a license.

19 Q A construction start requires a license, I

20 would presume.

21 A Uh-huh.

22 Q So apparently this plan would have

23 changed, or maybe not. I don't know.

24 A Uh-huh.

25 Q Does Energy Fuels still plan to start



1323

1 construction in 2012?

2 A No.

3 Q Okay. There we go.

4 So Stage 1, build a 1,000-ton-per-day

5 capacity mill and start production at 500. Raise the

6 capital.

7 MS. LUCAS: One more objection, Your

8 Honor. The witness has testified based on counsel's

9 question that there is no plan because there's no

10 construction plan for 2012. So renew the objection

11 to the relevance of this document in light of the

12 order setting aside a license.

13 HEARING OFFICER: It's in the record.

14 I'll consider it, and I'll allow questions on it. I

15 mean, the weight to be given to those questions and

16 the answers is a whole different question, but I'll

17 allow it.

18 Q (By Mr. Stills) All right. As soon as

19 the mill gets under construction, Line 2, Energy

20 Fuels' approach to licensing is to, in 2012, get a

21 license amendment in to get up to 750 tons per day.

22 Is that what this document says?

23 A Yes, that's what this document says.

24 Q And then next year CDPHE's (sic) plan is

25 to get another license amendment in by the end of



1324

1 2013 to ramp up to 1500 tons per day; is that

2 correct?

3 MR. GOAD: Your Honor, I object to the

4 question as to "CDPHE's plan."

5 MR. STILLS: My mistake.

6 Q (By Mr. Stills) Energy Fuels' plan is to

7 submit a license amendment to CDPHE by the end of

8 2013, the year after the 750 is in, but now to go to

9 an upgrade to 1500; is that correct?

10 A You know, I think it's unfair to

11 characterize it as Energy Fuels' plan. Again, I was

12 not involved in this. But our board frequently asks

13 us questions as to, okay, if the price of uranium

14 allows it, how fast could you permit something like

15 this, how fast could you build it, what would the

16 cost be.

17 This is what you do as a company. You

18 look at the various possibilities into the future.

19 So to characterize this PowerPoint as a definitive

20 plan I think is incorrect. It is probably a

21 potential plan that the board asked him to look at

22 with some guidelines as to increasing production.

23 Q So it's a reasonably foreseeable scenario

24 even if it might not be a plan?

25 A I wouldn't call it a reasonably



1325

1 foreseeable scenario other than the fact that we

2 probably look at 30 to 40 different scenarios as a

3 company. Is this one that is likely? Well,

4 obviously not at this time with the price of uranium

5 and with the license set aside.

6 Q But at the time in March when this was

7 produced, it seemed like a likely scenario before

8 Judge McMullen invalidated the order, right, the

9 license?

10 A You know, again, I was not part of this.

11 And if it was a likely scenario, I think I would have

12 been more aware of what was going on. I was never

13 asked to begin license permitting for an amendment to

14 expand to a thousand tons per day.

15 Q Is there more about this licensing

16 application that you might not be aware of?

17 A I wouldn't call this a licensing

18 application. What we submitted was a license

19 application. This is something that I believe that

20 our management was informing the board on what could

21 possibly be done in the future to increase production

22 and also to finance the project moving forward.

23 Q But you're not necessarily kept in that

24 loop even though you're in communication with CDPHE

25 about what Energy Fuels' plans are on this project



1326

1 proposal; is that correct?

2 A I am kept in the loop as far as anything

3 definitive going forward. I will certainly know

4 about it and plan for it. And when and if that

5 happens, I will inform CDPHE and the county.

6 MR. STILLS: I'll go ahead and enter that

7 as an exhibit, please.

8 HEARING OFFICER: This is going to be

9 marked as 25.


11 Q (By Mr. Stills) It's correct that the

12 environmental report was never updated to address

13 anything other than a 500-ton-per-day mill's impacts?


15 Q That's all we have in front of us?

16 A Correct.

17 Q Have you discussed expansion plans of any

18 kind with CDPHE?

19 A Yes, to a certain extent, but very

20 limited.

21 Q But they are aware of your plans to expand

22 past 500, regardless of how far; is that correct?

23 A They are aware that someday we may file an

24 amendment to expand the mill to a thousand tons per

25 day average production.



1327

1 Q I guess we've got two -- sort of two sets

2 of applications with two different processing rates

3 in front of the same department. So they're looking

4 at changes in one. Would those changes affect the

5 other?

6 A Who's looking at changes?

7 Q Would changes with the Air Pollution

8 Division application involve changes at the Radiation

9 Control Division?

10 A There's no intent to change our

11 application that's in front of the Air Pollution

12 Control Division.

13 Q I don't know if I artfully asked it.

14 Would changes in the Air Pollution -- would changes

15 requested by the Air Pollution Control Division

16 necessarily impact -- I'll start again.

17 If changes were made in the Air Pollution

18 Control Division in the time they were reviewing that

19 permit, should those be analyzed by the radiation

20 folks, as well?

21 MS. LUCAS: Objection, Your Honor.

22 There's no background for Mr. Filas to answer the

23 question of whether it should or shouldn't be

24 reviewed by the other part of the agency.

25 HEARING OFFICER: The witness can express



1328

1 his opinion. I don't think -- I won't take that as

2 binding on CDPHE or the process.

3 A What changes are you referencing? Are you

4 referencing theoretical changes or real changes?

5 Q (By Mr. Stills) Let's start with real

6 changes. Do you know of any real changes that the

7 Air Pollution Control Division asked you-all to make?

8 A The only one that I'm aware of is we added

9 an additional tank on the -- to recover -- as a

10 storage tank for organic. And I think that that was

11 basically to do a better job of removing the organic

12 from the SX solution. Again, that was done to reduce

13 hydrocarbon emissions. I believe we copied the

14 radiation program on that, and that's the only one I

15 can think of right offhand.

16 Q Were there any other requests to change

17 things?

18 A They asked us to look closely at the

19 process and see if we could do more based on new

20 technologies. And we did submit a pretty

21 comprehensive, reasonably available control

22 technology to them that evaluated what might be done.

23 Q But it is important to analyze changes

24 across two different permits so you still have the

25 same project in front of you; is that correct?



1329

1 A If those changes are substantial, yes. If

2 they're minor, I would say no, if it doesn't have a

3 material effect on what that regulating agency

4 regulates and is responsible for.

5 Q So can a minor change to air issues have a

6 major change to, say, water?

7 A I suppose it could happen. But again, the

8 radiation program was copied on that change as far as

9 the additional tank that we added.

10 Q Okay. Would you look at what's up there.

11 Is this an E-mail from Bob Monok to yourself?

12 A Well, I don't know. You've kind of --

13 Q Sorry. I had to grab the name at the

14 bottom because I -- do you recognize this E-mail?

15 A You say this is from Bob Monok? Okay.

16 Q Sorry if I got his name wrong.

17 A Okay. Go ahead.

18 Q I just wanted to know if you recognize it?

19 A I don't recognize it, to be honest.

20 That's why I kind of would like to read it.

21 MR. STILLS: It was produced by Energy

22 Fuels. I'm sorry. I didn't give counsel the number

23 at the bottom. It's EFPH 0135734.


25 Q (By Mr. Stills) This expresses a concern.



1330

1 Mr. Pray proposed a belt filter or equivalent to deal

2 with processed fluids, reducing the amount of fresh

3 water make-up. Does that seem like a reasonable

4 proposal, at least?

5 A It turned out it wasn't.

6 Q Why not?

7 A I don't recall. But at that time Chuck

8 Pray, who is the project -- the permit lead for APCD,

9 was throwing out a lot of ideas that his people were

10 coming up with with the idea could some of these

11 possibly be appropriate. At least that's my

12 recollection. Again, I haven't seen the entire

13 E-mail so I'm just surmising from what I've seen so

14 far.

15 I do know we looked at quite a few

16 alternatives for Air Pollution Control Division. And

17 ultimately the focus remained on trying to remove

18 hydrocarbons using the centrifuge and a storage tank

19 to store that prior to centrifuging that raffinate.

20 I believe it was the organic -- or it was a mixture

21 of organic and aqueous. Again, we looked at a lot of

22 them. Most of the ideas that the APCD was coming up

23 with, they really didn't understand the process very

24 good. And we spent some time showing them why

25 certain things just wouldn't work.



1331

1 Q Is that because you need to look at the

2 project sort of as a whole to understand if Chuck

3 Pray wanted to change one thing, it could change

4 other things?

5 A No. If it made sense to make a change, we

6 would have made that change, and we would have copied

7 the radiation program. Now, the difference between a

8 belt filter and another type of filter is not a

9 large, substantial change as far as from most

10 agencies' perspective. Again, we were trying to

11 figure out a way to recover more hydrocarbon in the

12 SX process.

13 Q But as part of that analysis of whether

14 the costs outweighed the benefits of that technology,

15 you kind of have to look and see what it does to the

16 rest of the project; is that correct?

17 A It wasn't that big of a change. It was

18 just an unworkable suggestion.

19 Q Because according at least to this E-mail

20 to you, that change would have had a cascading effect

21 of a lot of different projects -- or a lot of

22 different issues; is that correct?

23 MS. LUCAS: Objection to the fact that

24 counsel is testifying from an E-mail that he hasn't

25 let the witness read completely yet. I would request



1332

1 that he allow Mr. Filas the opportunity to read the

2 rest of the E-mail so he can refresh his

3 recollection.

4 Q (By Mr. Stills) I don't want to spend a

5 lot more time on this document other than to say that

6 if there were some issues and that issue was tied to

7 many others, I believe Mr. Monok's conclusion that

8 you may have to do model runs, you may have to go

9 down other avenues, look at other documents when

10 changes are made, that's standard procedure; is that

11 correct?

12 A In this case -- Bob Monok is a very good

13 process design engineer. Sometimes he struggles to

14 understand the permitting process. I think he was

15 overreacting to a suggestion by APCD that was just

16 unworkable, and he saw a lot of imaginary demons in

17 there. We did not change the process so it's pretty

18 much a moot point. Bob is not an expert in mill

19 permitting. He's an expert in mill design.

20 Q Do you recall if a properly strongly

21 worded letter ended up putting this issue to rest?

22 A I don't recall.

23 Q Did a strongly stated phone call put this

24 to rest?

25 A I don't recall. And to be honest with



1333

1 you, again, it wasn't a big issue.

2 Q Is that how issues are dealt with in

3 permitting, is strongly worded letters and strong

4 objections so you don't have to do more modeling and

5 more review?

6 MS. LUCAS: Objection.

7 A I guess I don't --

8 MS. LUCAS: The question --

9 MR. STILLS: I'll withdraw the question.

10 MS. LUCAS: Counsel is using the words

11 "strongly worded" as though it's quoted from

12 somewhere, and I'm curious where that's coming from.

13 MR. STILLS: Could you lead the last

14 sentence from Bob, please.

15 HEARING OFFICER: Are we still on the same

16 exhibit?

17 MR. STILLS: Yes.

18 A "I guess I could go on and on with the

19 negatives. Hopefully I have hit upon some of the

20 most important and that with a properly strongly

21 worded letter can be put to rest."

22 Q No more questions on that particular

23 document. Thank you.

24 So again, we talked a minute ago about a

25 design process with 1500 tons per day; is that



1334

1 correct?

2 A Repeat the question.

3 Q We just looked at a document a couple

4 minutes ago that dealt with a 1500-ton-per-day idea

5 about the mill; is that correct?

6 A Yes. It brought up the concept.

7 Q Okay. The document said plan, though, I

8 believe.

9 HEARING OFFICER: Is that a question?

10 Q (By Mr. Stills) Did the document say

11 "plan"?

12 A The cover said "plan."

13 Q Thank you. Were any other plans developed

14 around a 1500-ton-per-day capacity?

15 A I was not even aware of this presentation.

16 And I have -- in the past when we've been doing water

17 rights, we've looked at the possibility of getting

18 enough water for an ultimate 1500-ton-per-day mill.

19 And that is probably about it as far as from my part

20 of the world when I've looked at 1500 tons per day

21 possibly in the future.

22 MR. STILLS: Here's the next exhibit.

23 HEARING OFFICER: This is, for the

24 record --

25 MR. STILLS: Oh, sorry. I should be doing



1335

1 that.

2 HEARING OFFICER: That's okay. EFPH

3 0148360.


5 Q (By Mr. Stills) So this is a December

6 2010 monthly report, environmental permitting; Frank

7 Filas, environmental manager. Could you read where

8 it's bolded in yellow?

9 A "In conjunction with this filing,

10 engineering staff designed a preliminary pumping

11 pipeline and pump storage system that would supply

12 the water needed for future expansion of the mill

13 capacity to 1500 tons per day or more."

14 Q You wrote that, correct?

15 A Correct.

16 Q Are there any other examples where you

17 were involved with a mill capacity potential of

18 1500 tons per day or more?

19 A Not that I recall.

20 Q Think about it for a second. Do you

21 recall any?

22 A No, I don't.

23 Q For these alternate -- all of these

24 alternate numbers, you said it's economics that's

25 keeping you from going beyond 500; is that correct?



1336

1 A It's economics in the fact that you would

2 have to have the right price, and you would also have

3 to have enough mines to produce the ore for a larger

4 size or a larger production.

5 Q Is there anything else that is restricting

6 the mill to 500 tons per day?

7 A Our permit with the county. Our set-aside

8 permit with the radiation program was also based on

9 500-tons-per-day annual average.

10 Q And why was that kept at 500 tons per day?

11 A Which one?

12 Q The county.

13 A The county was set at 500 tons per day

14 because that's what we requested.

15 Q Any other reason why you're staying at

16 500 tons per day right now?

17 A Yes. We did not have sufficient water

18 capacity to run a 1,000-ton-per-day mill, and we also

19 didn't have a sufficient ore supply to run it at a

20 thousand tons per day. When you permit a mill or any

21 other large project, you have to look at the impacts

22 associated with it. If you don't know where your

23 water's coming from, you don't know where your ore's

24 coming from, you pretty much can't permit it under

25 today's regulations.



1337

1 Q And today's regulations require you to lay

2 out a range of alternatives to be able to figure out

3 what you can build; is that correct?

4 A Not necessarily. You have to look at

5 alternatives. With regard to the CDPHE license, we

6 looked at the 500-ton-per-day alternative and we

7 looked at the no alternative -- or the no, not build

8 it. So there was the two alternatives that were

9 considered.

10 Q So you looked at yes and no?

11 A Correct.

12 Q And you testified as an expert in

13 environmental permitting. Is that approach allowed

14 under the National Environmental Policy Act?

15 A Yes, it is.

16 Q You're not required to have a range of

17 alternatives? You can look at yes and no?

18 A Correct.

19 Q Even if there are alternatives identified

20 that have been somewhat considered; is that correct?

21 A Can I expand on that?

22 Q No, you may not. Please answer yes or no.

23 A Repeat the question.

24 MR. STILLS: Read it back.

25 (Page 1,337 Lines 19 through 20 read.)



1338

1 A Alternatives that are identified and

2 somewhat considered generally do not have enough

3 information to allow them to be evaluated fully as

4 part of an alternative. So in that case, agencies do

5 allow for the proposed project and the no project

6 alternative.

7 Q (By Mr. Stills) But again, you need to

8 look at all reasonable alternatives; is that correct?

9 A All reasonable alternatives that can be

10 properly defined.

11 Q And can we define the issue of water

12 supply?

13 A No, you cannot, for a 1,000-ton-per-day

14 mill because you haven't defined where that water

15 would come from. The same thing with ore. Where

16 would the ore come from? What would be your

17 transportation impacts?

18 MR. STILLS: This is Document EFPH

19 0148045, and we're on the third page.


21 Q (By Mr. Stills) In fact --

22 A Could I see the date of this document?

23 Q I'll read it to you.

24 HEARING OFFICER: November 8, 2010.

25 THE WITNESS: Okay.



1339

1 Q (By Mr. Stills) Are you familiar with

2 this document?

3 A No, because I'm only looking at the middle

4 of it. As usual, Travis, you're having me look at

5 part of a document that I probably haven't read in

6 two years.

7 Q Is this a memorandum to Steve Antony from

8 Frank Filas, November 8, 2010, talking about mill

9 water rights?

10 A Correct.

11 Q It talks about the current status of the

12 mill water rights and the potential future water

13 supply for the mill?

14 A And note the date on this. It's one year

15 after the environmental report was submitted in

16 November of 2009.

17 Q Okay. Your consultants have been working

18 on three alternative water supplies for potential

19 future use at the mill; is that correct? You've got

20 it done to cfs; is that correct? You don't need to

21 answer. I'll just rely on the document.

22 Take some time to read this portion, if

23 you would.

24 A Okay. You want me to read it out loud?

25 Q No, I can't.



1340

1 So the San Miguel River, Delores River,

2 and groundwater are the three alternative sources of

3 water for this mill; is that correct?

4 A Correct.

5 Q As well as -- I guess there's a fourth.

6 More distant groundwater to the north or the south?

7 A Correct.

8 Q But those all the involve federal action;


10 A Yes.

11 Q So those were avoided to avoid triggering

12 an environmental impact statement; isn't that

13 correct?

14 A No, because we don't need those for the

15 500-ton-per-day mill.

16 Q Do you need them for a 1,000-ton-per-day

17 mill?

18 A Yes.

19 Q Thank you.

20 Are you familiar with the rivers in this

21 area?

22 A Somewhat.

23 Q Are there years when even the amount of

24 water for a 500-ton mill -- where water would --

25 water would not even be available?



1341

1 A There could be months in a year or a

2 period of time in the summer during a drought year

3 where you may not have that water available.

4 Q And that goes for the Delores River,

5 correct?

6 A Yes.

7 Q And the San Miguel River; that's correct?

8 A Yes.

9 Q And for the groundwater in those same dry

10 years; is that correct?

11 A I'm not sure on the groundwater.

12 Q You can't testify to the groundwater

13 source?

14 A We never identified a groundwater source.

15 There could be groundwater sources that are tributary

16 to a river that would have conditions placed on them.

17 And I understand that you could have groundwater that

18 is not tributary to a river.

19 Q Okay. I appreciate that. That's a fourth

20 category. But I meant to ask about the third

21 category, which is the groundwater supply that you've

22 identified --

23 A You could have --

24 THE REPORTER: I'm sorry.

25 Q (By Mr. Stills) -- that you've identified



1342

1 as part of this application.

2 A Yes. You could have constraints put on

3 you for a period of time during a drought where you

4 would not be allowed to pump water.

5 Q So it's foreseeable that you could have a

6 year where you can't get water from any of those four

7 sources; is that correct?

8 A No. I would say you could have a period

9 of time during a year when you could not pump water.

10 That is why when we looked at pipeline alternatives,

11 we included a pond for storage, as you're aware. And

12 therefore you would store water and not necessarily

13 have to pump when the water -- when the water in the

14 river was low.

15 Q I don't recall seeing an alternatives

16 analysis that included pipelines. Did I miss that?

17 A That was done one year -- this evaluation

18 was done one year after the environmental report was

19 put forward. And the 1,000-ton-per-day mill is not

20 part of our application. We applied for a

21 500-ton-per-day license.

22 Q But as far as the 500 question, there

23 could be times when you couldn't get water from any

24 of the three; is that correct?

25 A Not that I'm aware of. I think our



1343

1 on-site wells would supply the water for the

2 500-ton-per-day mill, and we would not necessarily be

3 dependent on a pipeline.

4 Q Did you hear testimony about your

5 groundwater being linked to precipitation events?

6 HEARING OFFICER: Let me interrupt you.

7 The reporter's running out of steam.

8 MR. STILLS: I have five minutes, and I

9 can cut off here easily.

10 HEARING OFFICER: Okay.

11 Q (By Mr. Stills) So I'll try to get

12 this -- did you get a report in 2007 talking about

13 the feasibility of water from these three sources?

14 A Yes. We did -- we did get a report early

15 on from a consulting company that did discuss various

16 possibilities. But it was a very preliminary report,

17 and that was before we even investigated the on-site

18 water sources.

19 Q Do you remember the name of that company?

20 A It might have been -- Wright Water

21 Engineers? Is that the report you're referring to?

22 Q Yes. And that report's been designated

23 confidential; is that correct?

24 A I don't know.

25 Q Would a report concerning the availability



1344

1 of water from those sources be confidential?

2 A If it was part of our water attorney's

3 docket, yes, it would be.

4 MR. STILLS: I'd identify for the record

5 the report I'm referring to is EFPH 0140897. I don't

6 know that I need to voir dire it out as far as its

7 confidentiality. I'm not going to make those

8 arguments and take up our time, but I think we're

9 good for now.

10 HEARING OFFICER: Okay. Now, if I

11 could -- did we lose Mr. Spaanstra?

12 MS. LUCAS: He's not here.

13 HEARING OFFICER: But, I mean --

14 MS. LUCAS: Not forever. He'll be back

15 tomorrow, hopefully.

16 HEARING OFFICER: If I wear you all out,

17 then I will be ahead of the game.

18 If we could have a -- during this

19 10-minute break, let's spend three of it talking

20 process.


22 MR. STILLS: I appreciate everyone's

23 patience. We'll just continue, I guess.

24 Q (By Mr. Stills) It was your testimony

25 that Energy Fuels' submitted a surety estimate that



1345

1 was based on an in-house calculation of about a

2 million dollars for the decommissioning surety?

3 A No; 11 million, I believe.

4 Q 11 million. I am getting tired. I'll

5 slow down to make sure I'm accurate.

6 So the in-house estimate was about

7 11 million; is that correct?

8 A Correct.

9 Q And the estimate is based on a closure

10 scenario where the facility operates as planned for

11 40 years; is that correct?

12 A No. It's based on the -- it is based on

13 the maximum height of the Tailings Cell A and the

14 full size mill. But it does not include the two

15 other tailing cells that would not be constructed

16 during the five-year license period. And it

17 doesn't -- it includes 40 acres of evaporation ponds,

18 but it does not include the other 40 acres that would

19 also not be built or operated in the five-year permit

20 period.

21 Q But the methodology for the estimate

22 doesn't take into account -- I'm sorry. The

23 methodology for the estimate involves a closure

24 scenario where it operates for the full life of those

25 components; is that correct?



1346

1 A Correct.

2 Q And are you aware of any conventional

3 uranium mill that has operated as planned without

4 contamination in the United States?

5 A No.

6 Q And Energy Fuels did not provide CDPHE

7 with a surety estimate based on a fire that

8 resulted -- that caused a closure of the mill; isn't

9 that correct?

10 MS. LUCAS: Objection. What mill?

11 Q (By Mr. Stills) As part of the surety

12 estimate -- I'll rephrase -- Energy Fuels did not

13 provide a scenario that included a fire causing the

14 closure of the mill; is that correct?


16 Q And as part of the estimate, Energy Fuels

17 did not provide a surety estimate based on any design

18 failures; is that correct?


20 Q Energy Fuels did not provide a surety

21 estimate scenario that involved cleanup of the

22 groundwater plume; isn't that correct?


24 Q And Energy Fuels did not provide CDPHE

25 with a surety estimate based on a worst case



1347

1 scenario; isn't that correct?

2 A I disagree with that. I think that what

3 we provided was a worst case within what we're

4 permitted to do. By that I mean full build-out on

5 Tailings Cell A even though that would not have

6 occurred during the five-year licensing period.

7 Q And again, listen carefully, if you would.

8 When Energy Fuels provided its surety estimate, there

9 was no discussion of a worst case scenario as part of

10 that estimate; is that correct?

11 A No. There was a discussion in the

12 reclamation cost estimate about doing the estimate

13 for a Tailings Cell A that had reached full capacity,

14 which was the more expensive alternative, even though

15 we know it would not reach capacity during the

16 initial five years.

17 Q I guess by "worst case scenario" I mean a

18 disaster of some kind that closed the mill.

19 A No. There was no estimate for a

20 disaster-related closing.

21 Q No range, no estimate whatsoever?

22 A For that conception -- or for that

23 possibility, no.

24 Q Energy Fuels only provided CDPHE with one

25 scenario in its surety estimate; is that correct?



1348

1 A That is correct. We provided for the

2 approved closure plan.

3 Q Do you recall having any other scenarios

4 estimated?

5 A Yes. We looked at what it would take to

6 close Tailings Cell A if it was not -- if it was not

7 built out to capacity. And that would have been a

8 lesser cost.

9 Q Were any other estimates of closure

10 costs -- I'm sorry -- of decommissioning costs

11 provided --

12 A No.

13 Q -- to Energy Fuels?

14 A To Energy Fuels?

15 Q Yes.

16 A By?

17 Q By any person.

18 A We have -- we did receive another closure

19 estimate, yes.

20 Q And that closure estimate was provided in

21 August 2009 by Ames Construction; is that correct?

22 A Correct.

23 Q Do you recall that that closure --

24 MR. STILLS: And this is, for the record,

25 EFPH 142341.



1349


2 Q (By Mr. Stills) This cost estimate came

3 in at 24 million; isn't that correct?

4 A No.

5 Q This is Page 2 of that document, "Total."

6 A You know, I have never seen this document,

7 but this may have been for the entire mill facility.

8 Q So this is a complete estimate instead of

9 a partial estimate; is that what you're saying?

10 A I don't know. Again, that was not a

11 document that I reviewed.

12 Q Can you read the highlighted in yellow

13 part.

14 A "This cost was based on Scenario 2 as

15 defined in the text of USA Environment. Scenario 2

16 is the more expensive case, where the impoundment

17 Cell A is full of tailings and requires the

18 construction of a complete as-designed cap."

19 Q So this was a scenario that they used as a

20 company with extensive experience in environmental

21 remediation facility decommissioning, as well as

22 radiological services, as to how much it could

23 close -- it could cost under this scenario? And this

24 is different than your $11 million estimate; is that

25 correct?



1350

1 MS. LUCAS: Objection, compound question

2 and --

3 HEARING OFFICER: Break it up.

4 MS. LUCAS: -- lack of foundation on who

5 USA Environment is and their qualifications.

6 Q (By Mr. Stills) Your testimony is that

7 you never -- you've never worked with USA

8 Environment?

9 A I provided them with information at one

10 meeting, but I never saw this report. And it was my

11 understanding from talking to our engineers that

12 their estimate was in the neighborhood of 12 to

13 13 million, not 24 million.

14 HEARING OFFICER: "Their" being?

15 THE WITNESS: What?

16 HEARING OFFICER: "Their estimate" being?

17 THE WITNESS: Ames' estimate was in the

18 neighborhood of 12 to 13 million, is what our

19 engineering group told me.

20 Q (By Mr. Stills) Your engineering group is

21 likely to have received this?

22 A If it's in our files, that's who it would

23 have gone to, to Jeff Osborn, who was head of

24 engineering at that time.

25 Q But you never received this?



1351

1 A That's correct.

2 Q Were you in charge of putting together the

3 surety estimate for this project that was given to

4 CDPHE?

5 A Ultimately, but that was done at a later

6 time.

7 Q Did you ask the engineering folks what

8 Ames' estimates, Ames Construction's estimates came

9 out to?

10 A I did. And they said one to two million

11 higher. Jeff Osborn was no longer with the company

12 at the time so I worked with Bruce Norquist.

13 Q So instead of using Ames Construction or a

14 company with extensive experience preparing these

15 bonds, the bond submitted to CDPHE was prepared by

16 yourself in-house; is that correct?

17 A It was prepared by Bruce Norquist under my

18 supervision, and he had experience in putting

19 together estimates for large projects in the past.

20 Again, it was my understanding -- I have to wonder if

21 this is a final document from Ames Construction or if

22 it was a preliminary one. Because our engineering

23 group did tell me that they were looking at something

24 in the neighborhood of 13 million or 14 with the

25 long-term care included.



1352

1 Q Is it common practice to send drafts back

2 and forth with consultants on this kind of document?

3 A On any type of document it's standard

4 practice to review the work and see if there's errors

5 or omissions.

6 Q How about sort of filling in the blanks on

7 what the answers might be?

8 A I think in some cases you provide

9 information that the consultant would not be aware of

10 otherwise.

11 Q Okay. So the mines that would feed this

12 mill are all on federal public lands; is that

13 correct?

14 A No.

15 Q Which ones are on private lands?

16 A Energy Queen's on private land, two other

17 projects that -- well, we have the Callahan property

18 now, it seems to me there's others. But those two

19 immediately come to mind since they're large mines or

20 potentially large producers.

21 Q They wouldn't be sufficient to keep the

22 mill -- the ore running for the life -- or the mill

23 running for its designed life; is that correct?


25 Q And did we hear testimony from you that



1353

1 clay will need to be hauled in as part of the

2 tailings liners' construction?

3 A I don't believe there's a clay component

4 to the liners other than -- we have the GCL, but

5 that's a manufactured product.

6 Q There's no clay that's going into either

7 the evaporation or the tailings cells; is that your

8 testimony?

9 A As far as I know. Yes.

10 Q So we discussed before some of the

11 components of NEPA. You testified about reclamation

12 being engaged in a NEPA analysis for the Delores

13 project, water and the contracts concerning the water

14 rights. And that water right is not really effective

15 until that NEPA process is complete. That's one.

16 The pipelines would have a NEPA component. EPA has

17 review. Other than the Clean Water Act, there's

18 numerous federal components that are out there. And

19 without getting into the argument that I'm sure we'll

20 all be making, because I raised it, it's your view

21 that if this was subjected to NEPA, if this project

22 was subjected to the NEPA process, as was conducted

23 by federal agencies, it would kill the project; is

24 that correct?

25 A I would say it would add a lot of time and



1354

1 money to the permitting. And, you know, at one time

2 that was a very large concern. It would certainly --

3 for the small company that we were at the time, it

4 would have been have a -- it would have been a

5 struggle, yes. Would it have killed it? Probably

6 not. But, you know, it could have definitely made it

7 much more difficult.

8 Q Do you recall a meeting on September 7,

9 2010, with Fish and Wildlife Service?

10 A Yes, I do. I believe that was a

11 conference call.

12 Q A conference call?

13 A Uh-huh.

14 MR. STILLS: EFPH 0148403.


16 Q (By Mr. Stills) At that time you had

17 identified aspects of the project that involve the

18 Endangered Species Act; is that correct?

19 A That is correct, the downstream fish in

20 the Colorado River.

21 Q And that's in play because the Bureau of

22 Reclamation is part of the water supply for this

23 project?

24 A No. It's in play because there was a

25 depletion of water by -- our pumping wells would



1355

1 cause a depletion of water flowing toward the Delores

2 River.

3 Q But it's also in play because of the

4 reclamation analysis of the water rights that you're

5 looking to get for the groundwater; is that correct?

6 A The Bureau of Reclamation made the

7 determination that if we purchased water under a

8 contract with the Delores Water Conservancy District

9 that a NEPA analysis would be necessary before they

10 would be willing to sign off on that contract with

11 the district.

12 Q So that contract with the district cannot

13 become effective until the Bureau of Reclamation

14 signs off on it after a NEPA analysis, correct?

15 A That was their position, yes.

16 Q And that's because it's a federal agency

17 action; is that correct?

18 A That is what they determined.

19 Q And that's a condition of the water rights

20 that were entered and were provided during your

21 testimony; is that correct?

22 A That is part of the water rights. To be

23 honest with you, I do not know the exact wording in

24 that. Curtis Moore, who will be back tomorrow, was

25 the person in our office that handled that.



1356

1 Q You've testified to all aspects of the

2 mill so I would assume you would know that.

3 A I generally do know most aspects of the

4 mill, yes.

5 Q These are meeting notes. And this is

6 further down on Page 1.

7 A Uh-huh. At that --

8 Q Is that -- I'm sorry. I've got a

9 question.

10 A Okay.

11 Q You told Fish and Wildlife Service if NEPA

12 was brought into the project it would kill the

13 project; is that correct?

14 A At that late stage, it would have.

15 Q And SHPO, is that the State Historic

16 Preservation Office?

17 A Pardon me?

18 Q SHPO, S-H-P-O, the acronym, is the State

19 Historic Preservation Office; is that correct?

20 A Yes.

21 Q And this is on Page 3. You told EPA --

22 I'm sorry -- Fish and Wildlife Service that SHPO had

23 told CDPHE that they considered CDPHE a federal

24 representative agency for this project; is that

25 correct?



1357

1 A Well, SHPO agreed to have CDPHE handle the

2 archeology portion of it, yes.

3 Q And that's because the way that the law --

4 the way that the program is delegated to CDPHE, the

5 National Historic Preservation Act still recognizes

6 an undertaking that has to go through SHPO; is that

7 your understanding?

8 A No. My understanding is that we were

9 doing this on a voluntary basis because the state law

10 does not necessarily have that trigger. But we also

11 wanted to be consistent with what the federal

12 requirements are, and so we did.

13 Q So we've got at least two situations

14 where, voluntary or not voluntary, you complied with

15 federal regulations to avoid NEPA; is that correct?

16 A Not necessarily to avoid NEPA. We did it

17 because we thought that was the appropriate course of

18 action. And to be very honest with you, Travis,

19 these are not -- these are things that are not hard

20 to do. So we did do them, and we think the project's

21 better for it.

22 Q But NEPA is hard to do, and you didn't do

23 that, correct?

24 A NEPA anymore can be very hard. If it's

25 something that you start at the beginning of your



1358

1 project, it wouldn't have been a deal killer. But by

2 the time you get four years into your project and

3 you're getting close to getting your permits, the

4 idea of adding another seven years onto it with

5 perhaps a federal agency like the U.S. Fish and

6 Wildlife Service that has no experience in uranium

7 milling, I would say at that point in time it becomes

8 a deal killer.

9 Q But you knew about NEPA in 2007; is that

10 correct?

11 A Certainly.

12 Q And you testified previously about the

13 process of working with CDPHE on this project?

14 A To a certain extent, yes.

15 Q And Energy Fuels pays CDPHE $152 an hour

16 for their time spent on this project; is that

17 correct?


19 Q Have you ever contested any of the billing

20 statements from CDPHE?

21 A Yes.

22 Q On what basis?

23 A That I didn't understand the billing. And

24 I typically would call Steve on that and ask him for

25 clarification.



1359

1 Q So because it was vague you would call and

2 ask what people were working on?

3 A Most of their billings were vague, but

4 most of the time I understood from what they put down

5 what they were working on. In some cases there might

6 be a new person or maybe somebody's working on

7 something I'm not aware of, and I would ask for

8 clarification. In some cases Steve, Mr. Tarlton, did

9 modify the invoice. In most cases he explained it.

10 And usually it would be two or three days, but he'd

11 get back to me and explain it. And I would say,

12 Okay, I understand, you know, that the guy

13 legitimately put in those hours.

14 Q But you used that as a means to keep track

15 of what CDPHE was doing on the project; is that

16 correct?

17 A That and -- not so much. Because to be

18 honest with you, the state invoices come in fairly

19 late by my standards. In real time usually we would

20 be getting review comments or something to that

21 effect so I knew what they were working on.

22 Q You kept close tabs on what CDPHE was

23 doing from 2007 up until now?

24 A I keep close tabs on all of the agencies

25 that are permitting our projects.



1360

1 Q Okay. And in particular, in May 2012 -- I

2 don't know if you recall this -- but you questioned

3 Mr. Tarlton about CDPHE charges concerning Warren

4 Smith's work concerning public perceptions and

5 construction delays. Do you recall that?

6 A I remember asking at one time what Warren

7 Smith was doing working on the project. And I'm not

8 sure about construction delays, what that might have

9 referred to, to be honest with you.

10 Q Why did you ask whether Warren Smith

11 was -- why Warren Smith was working on the project?

12 A Because I wasn't aware that he was doing

13 anything at that time, and I just wanted to know what

14 it was.

15 Q Okay. Do agencies normally do public

16 perception work on behalf of an applicant?

17 A You know, I don't know.

18 Q In your experience in environmental

19 permitting, you don't know if that's a normal

20 activity or not?

21 A You know, this is something that's

22 happening more and more often with both federal and

23 state agencies, that there is a public outreach

24 effort going on. And sometimes we are aware of it;

25 sometimes we're not.



1361

1 Q And if you had construction delays, why

2 would that have a public perception question?

3 A You know, I don't know what that referred

4 to as far as construction delays.

5 Q Okay. I'll help refresh you a little bit.

6 Do you recall this E-mail?

7 MR. STILLS: And this is EFPH 0054980.


9 A You know, I remember them responding. I

10 don't remember -- you know, again, this is not

11 something that was terribly important to me. I was

12 just asking for clarification. I think what that

13 came back to may have been at that time we asked

14 for -- what was it? May 31, 2012? We may have just

15 modified our decommissioning funding plan, or we

16 planned on asking for it. And that, of course, is

17 because the litigation that we're embroiled in was

18 pretty much preventing us from doing any construction

19 in the near future. So we amended our license, I

20 think, subsequent to --

21 Q (By Mr. Stills) I'm sorry. You were

22 talking about at the end of May. But in April, this

23 was time for internal meetings to -- you asked

24 about -- Mr. Tarlton said, "You asked about Warren

25 Smith's charges in April. This time was for internal



1362

1 meetings to discuss the implication of construction

2 delay on public perception and media coverage." Were

3 those internal meetings involving Energy Fuels?

4 A No.

5 Q Perhaps -- I think you might have -- it

6 involved the subject of Energy Fuels, but Energy

7 Fuels was not at that meeting. Was that your answer?

8 A To the best of my knowledge. I don't

9 remember meeting with CDPHE.

10 Q Okay. And these construction delays --

11 Judge McMullen didn't issue his order until June, and

12 these construction delays that were being talked

13 about were in April; is that correct?

14 A We were basically -- there was the

15 possibility of coming back and having to do a hearing

16 like this. So we basically, as a company, decided we

17 were not going to go forward with anything until this

18 portion of the litigation was resolved. So we knew

19 at least internally at Energy Fuels that we weren't

20 going to go forward with the construction at that

21 point in time.

22 Q And that was because NRC had expressed its

23 view on the problems with the previous process; is

24 that correct?

25 A No. This was something that we had



1363

1 decided just based on the potential of having to do a

2 Section 105 hearing.

3 Q And during this the E-mail exchange, you

4 and Mr. Tarlton talked about a solar project,

5 9 acres, just west of the site that's going up; is

6 that correct?

7 A Yeah. I think he saw something and wanted

8 to know about it, and I was aware of it.

9 Q And that solar project in the East Paradox

10 Valley, are you familiar with it?

11 A Somewhat. I attended the hearing with the

12 planning commission.

13 Q And it went through?

14 A Yes.

15 Q And it's nearly complete?

16 A I can see the cells out there right now so

17 I have to guess it's either complete or nearly

18 complete or operating.

19 Q No further questions. Thank you.

20 A Oh, really? Thanks.

21 HEARING OFFICER: Sorry. Sit down.

22 THE WITNESS: Oh, shoot.

23 MR. STILLS: No further questions from me.

24 I'm sorry.

25 HEARING OFFICER: He had high hopes here



1364

1 for a minute.

2 THE WITNESS: Yes.

3 HEARING OFFICER: Dr. Grossman, your

4 witness.

5

6 BY DR. GROSSMAN:

7 Q I want to ask you a few questions on the

8 testimony you've given so far. I'll try to recall --

9 because it was a couple days ago when you did that,

10 and so we may have a little bit of, what was I

11 talking about, relative to these questions.

12 A Uh-huh.

13 Q And they're going to be all over the board

14 because as I was writing these down it was things

15 that came to my mind, or I was reacting to things

16 that you said or one of the other parties said.

17 A That's fine.

18 Q Do you know what threshold wind was used

19 for the lofting of tailings and the basis for the use

20 of that lofting threshold?

21 A No. I don't know.

22 Q Do you consider a uranium mill a local or

23 regional industry?

24 A I consider it regional to the extent that

25 there are impacts in the area across many



1365

1 environmental media and also socioeconomically.

2 Q And what do you estimate the area -- if

3 you can give just a rough idea. I don't need the

4 exact, but an order of magnitude, as we say in

5 science -- the area impacted by the mill and its

6 suppliers? And that means not just the ore guys but

7 the guys bringing all the processing materials in and

8 repair materials and all of that in addition to the

9 workforce that you might draw in for the area. So

10 what's the order of magnitude?

11 A If you're looking at our vendors or, for

12 example, where we sell our product --

13 Q That whole business.

14 A -- you're probably looking at pretty much

15 most of the United States of America. And you

16 might -- as far as selling our products, some could

17 go to the facility -- the conversion facility in

18 Canada, in Ottawa -- or Ontario. Excuse me.

19 Q So there's more than 880 acres involved in

20 this project?

21 A Well, I think you have to -- when you look

22 at impacts, you have to look at where those impacts

23 will be the greatest. And I think that going and,

24 say, looking at Texas and saying, okay, if we bring

25 in a construction firm to build our tanks, the very



1366

1 large tanks that are specialized tanks, is that

2 really an impact that needs to be assessed in Texas?

3 No. I think that the NRC's suggested impact area of

4 80 kilometers as a maximum makes some sense.

5 Q I'll ask this question again. But if it

6 comes up, I'll try to -- maybe you can remind me that

7 I already asked you this question. But what do you

8 estimate as the noise levels generated by the mill,

9 and especially at night? And I'll tell you why.

10 Because at night, you get these inversions. Like

11 there's one out there right now, and that inversion

12 only sits a couple hundred feet above the ground

13 often. And sound gets ducted in this layer between

14 the ground and the inversion and can travel very long

15 distances, sound can.

16 A Uh-huh.

17 Q So I'm sure you may have experienced this,

18 that on a quiet night you can hear things from very

19 far away.

20 A Yeah, like my neighbor's stereo. I know

21 what you mean.

22 Q Or in Huntsville, Alabama, when they were

23 running those big Apollo engines, they were breaking

24 windows 20 miles away at night because of this

25 phenomenon. So I wonder if it's been investigated,



1367

1 what the mill will do to Paradox Valley's noise

2 situation and whether it will impact the locals here

3 in Nucla and Naturita, especially Naturita, because

4 it's just right down the road.

5 A Okay. We had CH2M Hill look at the noise

6 situation. They said that as far as they could see,

7 the highest decibel level would be the back-up alarms

8 on our trucks at 65 decibels, which is not that high.

9 On top of that, we have committed to minimizing any

10 sort of deliveries at night. This is largely a

11 wildlife mitigation measure. As you know, driving

12 these roads, the deer are pretty --

13 Q It's going to take me an hour to get home.

14 You bet.

15 A They're out there, especially at dusk and

16 dawn and the evening hours. So I would say our

17 impact would be relatively small because we won't

18 have that many deliveries at night. And those would

19 probably be something -- it would be other than ore.

20 It would probably be a chemical reagent or something

21 like that that's scheduled ahead of time because we

22 wouldn't normally have people there to accept

23 deliveries. So I think our impact on noise would be

24 pretty small. The nearest downwind residence is

25 three miles away. And yeah, I think that we're



1368

1 looking at very little impact; probably none on

2 Naturita, which is 12 miles away.

3 Q Except for this inversion at night. The

4 SAG mill -- I don't know much about your operation.

5 I've read your documentation. I've listened to the

6 testimony here. And I guess the SAG mill is some

7 kind of tumbler that rolls these great rocks and

8 things that these trucks bring in and crush it into

9 the slurry kind of thing. Does that make a lot of

10 noise?

11 A Inside the building it does.

12 Q But it's protected -- sound protected by

13 the building?

14 A It's in an insulated building.

15 Q Okay. How many trucks a day, maximum, do

16 you expect for a 500-ton-per-day operation, a

17 1,000-ton-per day operation, and a 1500-ton-per-day

18 operation? Because we've heard allusions to all

19 three of those production rates. Now, the permit, as

20 you know, right now applies to 500, so if you could

21 give me your estimate. Because there have been --

22 one of the reasons I'm asking this is because I'm

23 confused as to exactly what the number of trucks --

24 I've seen 222 a day, operations, not construction.

25 You say there's going to be more when it's under



1369

1 construction so maybe we get 300 a day. I don't

2 know.

3 But do you have an estimate, one that

4 everyone here in your group has agreed upon? Because

5 I see a different estimate in the emissions pathway

6 report, in the air pollution report, and in the

7 environmental report. So let me get the last -- you

8 know, the best estimate.

9 A Okay. I don't recall an estimate saying

10 222 trucks. I'll just say that for now. You can

11 obviously tell me afterwards where you found it, and

12 maybe that may jog a memory.

13 So what we proposed on the 500-ton-per-day

14 mill was running ore trucks five days a week, which

15 would on average require 29 loads per day of ore.

16 Obviously if you have bad weather, you might have to

17 suspend ore haulage for a while, and then you would

18 have to make it up. I don't know that we ever

19 estimated a maximum for the 500-ton-per-day mill, but

20 I would say maybe twice that 29, maybe in the

21 neighborhood of 60 trucks you could have in over a

22 day.

23 As far as the 1,000-ton-per-day mill, we

24 did -- we are permitting with the Air Pollution

25 Control Division for a 1,000-ton-per-day mill, and



1370

1 that is required by Air Pollution Control Division.

2 They have rules that require you to estimate for a

3 future scenario so you're not -- their concern is

4 that you permit for a minor source with the intent of

5 eventually having a major source. It really didn't

6 matter in our case here. We were a minor source

7 either way.

8 But we did look at averages, which are

9 consistent with double what we had for the

10 500-ton-per-day mill. And then I think we asked them

11 to look at a maximum of a 2,000-ton-per-day delivery

12 rate for a 1,000-ton-per-day mill, if you had bad

13 weather or other reasons to need to get more ore in.

14 And 2,000 tons per day, let's see. That would be

15 about -- is that 80 trucks? If we divide that by 25,

16 does that come out to 80, or am I off by a factor?

17 Q 25 into what?

18 A 2,000.

19 Q That's coming up to a hundred, roughly a

20 hundred.

21 A At 25 tons per haul truck. Okay. So that

22 would be for a 1,000-ton-per-day mill. Like I say,

23 we never really estimated it for a 1500-ton-per-day

24 mill. I just know those two because those were

25 things that we worked with. And of course, you have



1371

1 reagent trucks and that sort of thing, but they would

2 be less than what the ore trucks are. And of course,

3 then you have additional -- you have vehicles coming

4 to and from the mill with your employees. If you

5 want to count pickup trucks, you're going to have

6 those, too.

7 Those were all looked at in our

8 application to the Colorado Department of

9 Transportation. And that was, I believe, looked at

10 for a 1,000-ton-per-day mill because, you know, let's

11 face it. We're not going to build access for a

12 500-ton-per-day mill and then later, 5 or 10 years

13 down the road, permit a 1,000-ton-per-day mill and

14 have to tear the access all the way back out again.

15 It's a million dollar access improvement so you'd

16 want to make sure that you overdesign, not

17 underdesign.

18 Q Who's going to pay for that access?

19 A We would.

20 Q Well, just what I read in the ACPD -- or

21 APCD report was 200 -- a maximum of 220 a day. That

22 works out in a 10-hour day, which I think is what you

23 say, that the mill operates roughly 10 hours, a truck

24 every 2 minutes.

25 A Again, I don't recall that. And sometimes



1372

1 with air pollution control permits, again, you may be

2 looking at all the vehicles. And some vehicles may

3 count as more than one vehicle if they're large

4 enough. I'm just -- without actually seeing the

5 reference that you're looking at, I'm just surmising.

6 Q If I get a chance, I'll show it to you.

7 A Okay.

8 Q Where did you get your initial emissions

9 estimate for the emissions pathways report?

10 A For the emissions pathways report? Are

11 you talking about air emissions?

12 Q Yes.

13 A The air emissions basically come from our

14 APENs, the air pollution emission notices that our

15 consultant, Kleinfelder, put together. They took a

16 lot of that from the CH2M Hill report. We also put

17 together a facility operating plan that discussed

18 each of the sources of emissions so that they could

19 follow our text and then go back to those mill design

20 plans and see the process flow diagrams and what

21 those emissions were coming off of the air pollution

22 control devices.

23 Q So the emissions that you-all are

24 providing for the air pollution side of this come

25 from the design of the plant?



1373

1 A Correct.

2 MS. LUCAS: Your Honor, may I approach and

3 turn off the projector?

4 HEARING OFFICER: Yes. Sure.

5 Q (By Dr. Grossman) I have a question here

6 that I'll try to work out. You made the statement --

7 or I thought you made the statement that this ER,

8 that's different from the EIA?

9 A Correct.

10 Q And that's different from an EIS?

11 A Correct.

12 Q And you said this is brand-new because

13 this hasn't been done for uranium mills for 30 years?

14 A No.

15 Q So where did you get the guidance to write

16 this report?

17 A Okay.

18 Q Did somebody give you an outline and say,

19 You need to fill these boxes in? Or did you just

20 come up with it on your own and then had it reviewed

21 by CDPHE, and you-all just went through it back and

22 forth until you got something that you thought was

23 decent?

24 A Doctor, I did address this earlier during

25 my earlier testimony, but I'll repeat it. Basically



1374

1 the only guidance for a mill ER -- environmental

2 reports have been around for years for agreement

3 states in the Nuclear Regulatory Commission.

4 However, the most recent guidance at that

5 time for a conventional mill dated to 1982. And of

6 course, many regulations and ways that we do business

7 have changed since 1982. So we looked at a 2003 --

8 in addition to looking at the '82 guidance, we looked

9 at a 2003 general guidance for doing environmental

10 reports for the NRC. And then basically we built the

11 environmental report out of that 2003 guidance, and

12 we imported items from the 1982 guidance that were

13 specific to conventional mills that may not have been

14 included in the general guidance.

15 Our ER contractor then sat down with

16 CDPHE, and they came up with a few other suggestions

17 for additional items to be put in there and maybe how

18 things should be formatted to more cleanly go

19 forward. We then -- at a later time we also asked

20 for guidance from some of the people that were

21 involved in permitting ISR facilities, which --

22 Q Excuse me. What's an ISR?

23 A In situ recovery facility.

24 Q Okay.

25 A -- that were permitting with the NRC and



1375

1 our agreement states to see what they were putting in

2 the environmental report. And they provided the

3 advice that we break it into three areas: one being

4 construction, one being operations, and one being

5 reclamation. So we overlaid that onto the outline

6 that we had already come up with and incorporated

7 that in there.

8 Q In your discussions with CDPHE and trying

9 to work out the format for this report -- which

10 eventually a good portion of it became the EIA

11 report, the way I understand the testimony so far --

12 was there any indication to you that public comments

13 were involved in your formulation of the ER, or was

14 it just you and CDPHE from your point of view, from

15 what you understand?

16 A It was basically just us. We put together

17 the environmental report based on our consultants.

18 Basically what we told Edge was we wanted this

19 environmental report to follow very closely the BLM,

20 NEPA documents that they had been using, especially

21 as it related to land use and wildlife, vegetation,

22 those sorts of things.

23 As far as the radiation aspects of it, we

24 brought in additional consultants who specialize in

25 that area, health physicists like SENES, for example,



1376

1 a well known consulting company in that area, to

2 assist Edge in evaluating the radiation impacts. But

3 basically the environmental report was prepared by

4 our consultants for us, and it was part of our

5 application. CDPHE did not have much involvement in

6 that. I guess there probably may have been a few

7 technical issues, and I may have sent them an E-mail

8 or called them up and thrown some ideas out. But

9 they were not materially involved in the preparation

10 of the ER.

11 Q So the way I understand it -- and I

12 understand the position your company was in in this

13 nascent effort here, that it was -- you kind of -- I

14 don't want to put it -- maybe you can come back at me

15 if you think that's wrong. You kind of just -- it

16 was a very ad hoc kind of way you went at it. You

17 looked at some documents that were official

18 documents, NRC -- pretty heavyweight official

19 documents, but there was no in-place method for you

20 and your company to fulfill? You kind of did it

21 yourself? That's what I just heard.

22 A That's not what I just said. I disagree.

23 We put a lot of thought into what would go into the

24 environmental report and how it would be organized.

25 And again, we followed general NRC guidance which, as



1377

1 you mentioned, is not thin. There's quite a bit in

2 there as to how they did this. And again, we had

3 those ISR documents that gave us some indication of

4 what they wanted to see in an environmental report.

5 Q But it seems to me it's kind of backwards.

6 In other words -- and I respect the effort you put

7 into this. But it looks to me like you guys came up

8 with the way to do it by looking at these reviews and

9 thinking about it and then presented it to the state

10 and said, How's this?

11 And they looked at it and said, Given all

12 your background, this is okay and we'll go forward on

13 that.

14 Is that what I'm getting?

15 A Well, again, I have to disagree. Again,

16 it's up to us, as the applicant, to put together the

17 application. And we did confer with CDPHE early on

18 to make sure that there was -- that we didn't have

19 omissions that they were looking for in that

20 document. Now, I'm sure that if we had glaring

21 omissions, they probably would have told us. But

22 typically what they said during that meeting was

23 generally minor stuff that they were looking for.

24 Again, we followed NRC guidance, and we

25 looked to the regulations. We didn't make up this



1378

1 guidance. We didn't write the regulations. We

2 followed what the government had out there for us as

3 far as both guidelines and rules.

4 Q But the impression I get as a citizen is

5 that you did some of the work that I feel CDPHE

6 should have done. In other words, CDPHE should have

7 scrutinized these guidelines and done that and handed

8 you an outline and said, Go for it. We'll talk about

9 adjustments to this, but this is the way we do

10 business here in the State of Colorado, and we want

11 you to follow this format.

12 And I don't hear that.

13 A You have a right to express your opinion.

14 Q But do you feel that that's the way it

15 went?

16 A I feel the way we did it is the way we

17 would also do it with the NRC. The bottom line is,

18 we are provided guidance, and we attempt our best to

19 follow that guidance. If this was an NRC license

20 application, we would be submitting a technical

21 report and an environmental report. We essentially

22 did the same here. However, our technical report was

23 formatted differently, and the state was okay with

24 that. It wasn't formatted like an NRC TR. We

25 actually provided a lot more information than is



1379

1 normally seen in an NRC application.

2 But as far as the environmental report,

3 this is the way it's traditionally been done. The

4 applicant does the environmental report, but then the

5 agreement state in the NRC does their own analysis.

6 And do they look at your environmental report? Sure,

7 they do. Do they borrow from it? Yes, when they

8 think it's appropriate.

9 But the government agencies -- ultimately

10 in the State of Colorado, they put out their own

11 report, which was the environmental impact analysis.

12 And with the NRC, they will put out an environmental

13 assessment, or an EIS, in compliance with NEPA.

14 Q Did Energy Fuels at any time go out to the

15 public, do outreach to the public for input to your

16 environmental report, or was it just consultants that

17 you hired? Did you get any other opinions or input

18 for this on your own? Not being forced to do it,

19 like we're sitting here today, but that you said,

20 Hey, we ought to go out and talk to some people out

21 here, go down to Telluride and see what their

22 concerns are and see if we can them cut off at the

23 pass? Did you do any of that?

24 A Yes.

25 Q With whom?



1380

1 A When I hired Edge, the first thing I did

2 was I asked them to come to our first planning

3 commission meeting, I believe it was; if it wasn't

4 the first, it was the second. But I think it was the

5 first on May 19th of --

6 Q Excuse me. This planning commission is

7 just Montrose County?

8 A Correct.

9 Q Not a bigger region?

10 A May 19th of 2009. And they were there for

11 the entire meeting and took notes. I also -- you

12 know, I also gave them comments from the various

13 meetings we had with the county. Understand that the

14 state meetings did not occur until after the

15 environmental report. So basically the public

16 comment base that they had was the six -- they call

17 them five meetings because one was a continuance, but

18 there was actually six meetings, generally an average

19 of five hours, for the county in which comments were

20 provided very similar to what we've seen so far

21 today.

22 Q Do you think the emergency response -- and

23 now I saw in this EIA or in the ER that there was a

24 section on emergency response. But prior to me being

25 led to those documents only a week or so ago -- and



1381

1 they're very hard to find on the Web site. But do

2 you think that the emergency response is adequate,

3 that what you have shown in the report is an adequate

4 response to the possibility of various emergencies

5 that might accrue with the mill, both at the mill

6 site and away from the mill site?

7 A Yes, I do. I think it's adequate for

8 permitting purposes. Our folks contacted the police

9 and ambulance services, hospitals, all the people

10 that are in emergency response for the state and

11 other groups in order to establish contacts,

12 information for the emergency response plan.

13 However, you have to understand -- and of

14 course, we looked at a lot of different potential

15 emergencies. And we have general procedures and more

16 specific procedures for things such as a wildfire or

17 something like that. But understand that once the

18 mill is constructed, and you're training people, then

19 you actually are going to have emergency response

20 exercises at the facility. This was something that

21 we agreed to do. And so that plan, in my mind, is

22 just like our facility operating plan. It's a

23 dynamic plan. As the mill comes into construction

24 and production, it will be fleshed out in a lot more

25 detail. And again, there will be training exercises



1382

1 with the local responders.

2 And so I feel very comfortable with it as

3 far as from a permitting document approach, knowing

4 full well that it will become more robust as the

5 facility comes into being.

6 Q Will you have a fire department on the

7 mill site?

8 A No. We will have trained emergency

9 responders. We also will have large hose reels

10 that -- especially near the SX building because of

11 the flammability of the kerosene. And of course

12 we'll have fire extinguishers and equipment that can

13 be used in the case of a fire. We'll also have an

14 ambulance. We'll have one at our admin building.

15 Q Have you-all planned at all for any kind

16 of fire, wildfire or otherwise, during one of these

17 windstorms where the winds can get up to about

18 60 miles an hour, and some of these windstorms last

19 on the order of 36 hours?

20 A We have planned for wildfires. And I

21 would imagine what we have put in there would be a

22 good first step in that case. Obviously if there was

23 heavy winds and a large wildfire, that could cause

24 problems at the mill, yes.

25 Q I know this has been discussed. I recall



1383

1 these questions from a couple days ago. But in your

2 opinion, is the water used reclaimable?

3 A It could be reclaimable, but it would be

4 at a pretty large expense. And we would also -- it

5 would also be a -- it would produce a pretty large

6 waste stream. You would have all that lime that

7 would have to go up into the tailings area. It's not

8 a huge amount. I believe it was in the neighborhood

9 of -- what we were sending to the evaporation pond

10 was about in the neighborhood of 50 to 60 gallons per

11 minute out of a total consumption of about 140.

12 Q So you're relying on evaporation to get

13 rid of the water and leave the residue?


15 Q Who in the state clears this water use?

16 A We have to -- well, we've got the water

17 rights for using the water from the Chinley aquifer.

18 Q And also with the disposal, is that CDPHE?

19 A CDPHE reviews our disposal plans, yes.

20 HEARING OFFICER: We've got about 10 more

21 minutes. Can you do it in 10 minutes?

22 DR. GROSSMAN: Yeah. I think so.

23 Q (By Dr. Grossman) Are there any studies

24 that you did for the environmental report on the

25 effect of the mill on the night sky and what kind of



1384

1 outdoor lighting you plan? One of the things out

2 here that -- you've heard everybody talk about how

3 beautiful it is out here. I know it's cold out there

4 right now. But on a clear night, you walk out in the

5 Paradox Valley, and it's magic.

6 A We agreed to have the downcast type

7 lighting at the facility, except in those areas where

8 we considered it a very high safety concern if we

9 didn't have better lighting. So overall the mill we

10 expect would have the downcast lighting.

11 Q But it would be a lot of lights? Face it.

12 It's going to be a lot of lights out there, right?

13 A Yes.

14 Q In fact, do you-all expect to put

15 stoplights anywhere as the traffic increases, like

16 maybe a stoplight or some kind of traffic control

17 other than just a turnoff into the mill, a traffic

18 light maybe down at the intersection there of 90 and

19 141?

20 A No. There's no plans to put in stoplights

21 at the intersection. There's a possibility of

22 putting in some type of a warning signal at the mill

23 access. That's one thing that could be added at a

24 later time if the Department of Transportation

25 thought it was necessary or would be beneficial.



1385

1 Q Hold on just a sec. I thought I had

2 another one. We've gone over that.

3 Is it normal for the -- this had to do

4 with Chuck Pray coming up with ideas for what you-all

5 could do. And Chuck, the way I understood it, worked

6 for CDPHE; is that right?

7 A That's correct.

8 Q Thank you. Is it normal for the permitter

9 to suggest plans, changes to plans? Have you

10 experienced that before?

11 A Certainly; pretty much on all levels,

12 federal and state levels. In this case, APCD, Air

13 Pollution Control Division, was asking us to evaluate

14 what we could do to reduce the hydrocarbon emissions,

15 and we proposed a number of alternatives. And so

16 they suggested, Did you look also at these

17 alternatives. And so we looked at those. And as I

18 mentioned -- and I reported back to Chuck. That

19 correspondence or E-mail wasn't there, but basically

20 I reported back to him on the practical limits of

21 what we could do using those methods. But to answer

22 your question, yes, it is fairly common.

23 Q I understand that this is your permitting

24 agency. But in other than legal or judicial

25 settings, have you ever responded to suggestions from



1386

1 outside groups, from the public, pro and con, for

2 changes to your plans?

3 A Sometimes we will based on people's

4 concerns and issues. We will incorporate mitigation,

5 yes.

6 Q This is my last question.

7 A Okay.

8 Q What happens if this permit is denied

9 after five years? You got yourself a 500-ton-per-day

10 operation going on out there, and something comes up.

11 Maybe they find a whole bunch of radioactivity over

12 there in Telluride, and finally they just say you

13 can't do this anymore. You guys have got to close

14 this thing down and go back to whatever you were

15 doing. What do you do with the mill then? Do you go

16 through this $11 million tear-down of the mill

17 because they're through with you?

18 A If the rules or regulations changed so

19 that we could not operate the mill in compliance with

20 the new rules and regulations at any level, then

21 ultimately you would have to close it. Normally if

22 rules and regulations change, we try to adopt

23 additional control measures or change things so that

24 we can still comply with the laws and the rules.

25 But, you know, based on the information we have, the



1387

1 mill as proposed is in compliance with state

2 regulations.

3 DR. GROSSMAN: Thank you. I appreciate

4 your stamina.

5 THE WITNESS: Thank you.

6 HEARING OFFICER: We've got four minutes.

7 Mr. Goad, do you have questions?

8 MR. GOAD: I do not.

9 HEARING OFFICER: Do you have redirect?

10 MS. LUCAS: I do.

11 HEARING OFFICER: How long?

12 MS. LUCAS: More than 4, less than 30.

13 HEARING OFFICER: We're out of steam.

14 That's why I'm asking. Okay.

15 It's, for the record, 6:56 by my watch,

16 which even agrees with my computer, which is wholly

17 unusual. We'll be in recess until 8:30 tomorrow

18 morning.

19 (The proceedings adjourned at 6:56 p.m.

20 on November 12, 2012, to be resumed at

21 8:30 a.m. on November 13, 2012.)

22

23

24

25



1388

1 STATE OF COLORADO)

2 ) ss. REPORTER'S CERTIFICATE

3 COUNTY OF DENVER )

4 I, Janet Lee Priestley, do hereby certify

5 that I am a Registered Professional Reporter and

6 Notary Public within the State of Colorado.

7 I further certify that these proceedings

8 were taken in shorthand by me at the time and place

9 herein set forth, that they were thereafter reduced

10 to typewritten form, and that the foregoing

11 constitutes a true and correct transcript.

12 I further certify that I am not related to,

13 employed by, nor of counsel for any of the parties or

14 attorneys herein, nor otherwise interested in the

15 result of the within action.

16 In witness whereof, I have affixed my

17 signature this 30th day of November, 2012.

18 My commission expires October 29, 2013.

19

20 ____________________________ Janet Lee Priestley

21 216 - 16th Street, Suite 600 Denver, Colorado 80202

22

23

24

25





Aabandonment 1158:14ability 1125:22 1126:221138:19 1148:11 1157:81157:25 1160:7 1215:211235:14,19 1297:1

ablation 1092:151255:12,14 1257:3,9

able 1107:13 1118:151124:24 1127:241137:13 1140:15 1143:81146:21 1148:8 1149:181163:25 1182:191196:15 1231:8 1236:161247:19 1250:24 1280:11280:5 1337:2

above-entitled 1048:17absence 1195:14absolute 1065:3 1095:10absolutely 1145:191167:7 1174:12 1228:1

absorbed 1204:12accept 1112:11 1204:221205:3 1258:2 1367:22

acceptable 1072:81079:6 1162:25 1163:21

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accessed 1085:3accident 1123:9 1125:6,71157:12 1223:1 1299:11

accidents 1085:5 1122:22accommodate 1054:22accompanied 1182:4accompanying 1199:11accomplish 1309:2accomplishments1264:11

account 1158:5 1345:22accountable 1216:7accrue 1381:5accurate 1063:25 1345:5accurately 1141:22accused 1146:15ache 1108:20achieved 1065:12acid 1079:16 1092:181180:8,16 1306:3

acids 1085:8acknowledge 1118:20acknowledged 1076:3Acoma 1315:2ACPD 1371:20acquaintances 1055:21acquire 1279:24acquired 1066:18acquisition 1126:15acquisitions 1254:3acre 1142:4acreage 1226:18acres 1080:1 1142:91155:10 1214:25 1215:11215:1 1280:13 1310:81310:11,14 1345:17,181363:5 1365:19

acronym 1356:18acronyms 1243:91279:18

act 1068:22 1109:21165:16,19,19 1167:8,91184:25 1185:9,10,101185:11,11 1200:221201:14 1223:17 1264:71264:18 1270:111337:14 1353:171354:18 1357:5

acted 1082:9acting 1166:15action 1049:12 1286:3,51286:19,20 1287:2,161288:8 1340:8 1355:171357:18 1388:15

actions 1209:1 1266:25active 1066:11 1113:161117:4 1225:5

actively 1245:19activities 1133:23,241194:6

activity 1079:19 1134:51217:1 1360:20

acts 1185:12actual 1063:22 1098:241109:21 1110:191127:14 1204:15

ad 1376:16add 1093:8 1193:141244:7 1253:9 1310:131353:25

added 1245:5,8 1281:20

1282:6 1328:8 1329:91384:23

addictive 1142:23adding 1194:17 1317:21358:4

addition 1060:131155:14 1290:20 1365:81374:8

additional 1054:81150:11 1261:12,121279:25 1280:151287:18 1328:9 1329:91371:3 1374:17 1375:241386:23

Additionally 1146:25address 1071:10 1110:91124:15 1159:231166:24 1173:131220:18 1226:9 1258:91303:3 1326:12 1373:24

addressed 1075:2 1090:11095:3 1301:22 1303:23

addresses 1274:13,17addressing 1166:171231:6 1304:22

adds 1094:9 1287:4,16adequate 1083:1 1120:101149:16 1272:5 1274:191276:14 1280:14 1381:21381:3,7

adequately 1057:111062:6 1063:9 1064:121075:1 1098:17 1123:201124:15 1217:4

adhere 1161:20 1282:25Adjacent 1068:1adjective 1131:23adjourned 1387:19adjudicatory 1229:251230:3

adjusted 1234:21adjustments 1378:9admin 1382:14Administration 1069:19administrative 1053:3administrator 1179:4admit 1082:14 1105:4,211106:8 1169:20

admitted 1051:7 1052:21247:4 1267:12 1272:121284:11 1309:20

1318:16 1326:101329:24 1335:4 1338:201349:1 1354:15 1361:8

adopt 1386:22adopted 1235:10advancement 1082:31302:1

advances 1184:14,14,161185:4 1313:6

advantage 1079:91099:19 1230:15

advertisements 1108:7advice 1375:3advocacy 1203:4 1213:7advocate 1166:161202:14

Affairs 1049:6affect 1077:1 1171:11190:6 1199:25 1327:4

affiliated 1221:8affixed 1388:16afford 1165:12 1211:10affordable 1138:21201:13

affront 1087:6Afghanistan 1186:17aforementioned 1059:3afraid 1182:17 1303:4aftermath 1071:16afternoon 1209:8 1232:81278:16 1305:9 1308:3

age 1128:21 1164:11181:16 1184:10,101193:17 1202:11,171211:14

agencies 1078:121107:25 1166:2,41167:23 1187:17 1191:21191:3 1197:15 1278:11281:4 1297:10 1331:101338:4 1353:23 1359:241360:15,23 1379:9

agency 1057:24 1117:71162:4 1166:13 1276:251282:2 1327:24 1329:31355:16 1356:24 1358:51385:24

agency's 1127:12agent 1110:7,13 1139:111203:10

agents 1292:15



ages 1228:19aggravates 1088:12aggrieved 1085:24ago 1083:9,11 1098:181105:2 1109:1 1110:11112:3 1135:1 1139:181151:19 1176:2 1200:201201:7 1210:18,211294:12 1307:151333:24 1334:4 1364:91380:25 1383:1

agree 1097:20 1139:241152:4 1217:25 1237:101237:13 1238:171249:20 1255:181274:15 1286:8 1302:221311:23

agreed 1091:16 1357:11369:4 1381:21 1384:6

agreement 1115:111121:14 1127:101167:12 1168:6 1250:151278:6 1285:12,121286:12 1311:22 1374:21375:1 1379:5

agreements 1254:4agrees 1149:16 1387:16agricultural 1085:14,231213:5 1215:3,161294:21 1295:12

agriculture 1134:61155:4 1158:19 1226:17

ahead 1056:25 1109:111171:17 1209:151214:12 1243:4 1284:231291:4 1293:20 1296:161310:10 1315:151317:22 1326:6 1329:171344:17 1367:21

ahold 1186:22aim 1307:16air 1060:12 1069:9,131073:6 1085:18 1086:181091:7 1096:3 1103:161104:25 1113:131131:13,19 1153:6,81156:4,21 1157:141160:2,10 1162:9,151165:19 1167:8 1179:81181:25 1185:9 1190:121194:4 1195:6 1204:15

1208:12 1217:6 1285:91285:10,13,18 1286:31287:15 1288:7 1319:51319:10 1327:7,11,141327:15,17 1328:71329:5 1330:16 1369:61369:24 1370:1 1372:11372:11,13,14,21,241385:12

airborne 1072:171078:20 1156:23,25

airplane 1139:211179:12,14

air's 1135:24Alabama 1366:22alarm 1179:13 1213:8alarmed 1128:4alarms 1367:7Alger 1221:6,7Algom 1280:19alive 1106:13 1204:5alleviate 1136:15Alliance 1049:14 1112:21151:21,22,25 1152:1,71168:19 1213:241220:11,12,13

allocate 1125:15allow 1066:10 1085:221087:15,23 1165:41248:17 1256:2 1273:181280:2 1281:11 1320:81322:9,10 1323:14,171332:1 1338:3,5

allowed 1057:23 1073:141109:2 1117:24 1118:11182:22 1211:131270:17 1280:5 1303:241310:11 1311:19 1320:51337:13 1342:4

allowing 1073:3 1084:61087:18 1088:19 1092:91104:17

allows 1309:3 1324:14allusions 1368:18alpha 1140:4 1199:51238:24 1239:3,7

Alpine 1157:10alter 1218:1altered 1208:14alternate 1066:171079:22 1087:4 1109:10

1248:8,11,23 1249:161278:9,11 1288:211310:15 1335:23,24

alternative 1201:251248:16,24 1249:251250:20,23 1251:1,3,4,61251:7,9,11 1254:9,151254:21 1255:2 1258:31258:6,22,25 1259:1,51259:21 1287:10 1289:81305:5,6 1308:6 1309:91311:16 1312:5,211313:10,17,18 1337:6,71338:4,6 1339:181340:2 1347:14

alternatives 1080:121083:1 1276:18 1283:131289:2,6,9,11,201308:12,14 1311:181312:1 1314:6,81330:16 1337:2,5,8,171337:19 1338:1,8,91342:10,15 1385:15,17

aluminum 1060:21Alzheimer's 1061:11128:24

amass 1216:22amazing 1180:24Amazon 1193:7Amber 1151:21ambulance 1381:91382:14

amenable 1256:4,7,71281:8

amended 1090:9 1361:19amendment 1323:21,251324:7 1325:13 1326:24

amenities 1137:251139:1

America 1137:231165:14 1183:221365:15

American 1141:1,31159:2 1204:20

Americans 1137:211207:4

Ames 1348:21 1350:171351:8,8,13,21

amount 1081:17 1085:61096:19 1125:17 1135:51143:1 1161:20 1180:19

1190:21 1191:9 1192:221193:13 1202:121252:17 1304:16 1306:61330:2 1340:23 1383:8

amounts 1095:7,81107:17

amusement 1210:11analyses 1185:1analysis 1066:20 1067:71067:17,25 1072:91081:4,4 1116:11,201119:18 1189:10 1196:11196:1 1201:20 1216:121218:10,23 1219:251225:19 1228:7 1255:71259:5 1283:18 1284:11286:15,21 1287:101289:10,18 1290:21312:4 1314:7,81331:13 1342:161353:12 1355:4,9,141379:5,11

analyze 1067:19 1308:161308:17 1312:211328:23

analyzed 1217:4 1259:211327:19

anathema 1160:6Anderson 1109:1and/or 1057:18anecdotal 1202:25anecdote 1127:21anemia 1121:2anemometer 1142:12anemometers 1142:5,9Angela 1129:5animal 1081:15animals 1299:4announced 1086:121246:2,5

announcement 1066:141177:19

annual 1087:11,241336:9

annually 1121:18answer 1115:10,151116:5 1117:3,111118:3 1119:4 1161:8,91170:20 1185:221195:16 1197:121242:25 1259:6,8



1269:2 1281:17 1306:111307:15 1317:231327:22 1337:221339:21 1362:7 1385:21

answered 1184:61250:17

answers 1171:13 1323:161352:7

antiballistic 1182:5anticipate 1090:201290:7

anticipation 1088:13Antony 1051:23 1232:141232:16,19,24 1233:31233:15 1234:5 1321:191321:21,25 1339:7

anybody 1053:251054:15,24 1101:31140:16 1148:151172:19 1174:241206:13 1209:6 1213:131214:4,8 1231:10,121242:17 1301:121314:22

anymore 1133:21 1134:21245:17 1357:241386:13

anytime 1302:7anyway 1135:25 1221:10APCD 1330:8,22 1332:151371:21 1385:12

APENs 1372:14aplastic 1121:2Apollo 1366:23apologies 1234:171243:4 1276:4

apologize 1139:141256:16

Appalachia 1137:24apparent 1170:23apparently 1063:161076:10 1322:22

appeal 1168:21 1171:91291:8

appealed 1230:4appealing 1164:13appear 1216:23 1256:41269:19

APPEARANCES 1049:11050:1

appeared 1119:12 1143:9

Appearing 1049:7,14,181049:23

appears 1074:20,251086:14 1116:19,23

appeased 1086:1Appendix 1258:91259:13,18

applicable 1172:15applicant 1057:51063:16 1089:1 1120:21169:2,10,15 1360:161377:16 1379:4

application 1048:51051:14 1053:4 1064:111064:15 1066:25 1071:41073:12 1082:8,9,251083:3,3,8,15,191086:19 1087:12 1089:21089:19 1090:121094:19 1096:1 1112:181112:20 1113:6,11,211113:25 1114:16 1115:21115:3,8,14 1116:7,221117:23 1118:3,6,101119:3,14,20 1120:4,6,91127:15,19 1135:51158:9 1171:24 1176:151177:20 1178:211179:18 1180:181216:14 1224:121225:19 1230:2 1234:51235:15 1243:161248:14 1260:191304:23 1305:22 1308:91308:16 1309:7,14,221313:2 1315:20 1316:31316:4 1319:7 1325:161325:18,19 1327:8,111342:1,20 1371:81376:5 1377:17 1378:201379:1

applications 1088:241117:9 1158:5 1327:2

applied 1086:1 1118:191142:16 1172:8 1229:231342:20

applies 1368:20appreciate 1053:191055:23 1080:201089:15,16 1102:21104:20 1151:10,13

1169:25 1204:9 1232:81243:8,10 1257:111289:15,17 1341:191344:22 1387:3

appreciated 1118:13approach 1078:8 1105:71250:12 1277:221311:11 1317:3 1323:201337:13 1373:2 1382:3

appropriate 1164:12,151255:19,22 1281:221330:11 1357:17 1379:8

approval 1086:7 1089:71166:5 1169:16

approvals 1196:22approve 1104:14 1119:31123:12 1136:241160:15

approved 1068:131077:16 1085:25 1104:31118:6,7 1122:131234:9 1274:21 1276:141276:19,24 1283:71348:2

approving 1115:13approximate 1092:13approximately 1062:141081:9 1153:4,71154:24

April 1361:22,25 1362:13aqueous 1330:21aquifer 1074:15,17,211075:5 1096:17 1191:51192:3 1215:17 1383:17

aquifers 1096:9 1217:2ARBITER 1048:1arc 1081:16,16,18archaeologists 1314:211314:22

archeology 1357:2area 1059:21 1065:171072:14,23 1074:1,3,141075:21 1084:8,121085:13 1086:111088:10,21 1091:121093:3,21,25 1097:161098:3,7 1100:241101:3 1102:15 1119:241123:5,23 1129:151130:4,5 1131:71132:17 1133:3,6,12,25

1134:2 1140:20 1141:51144:17 1145:23 1146:51146:25 1147:6,7,16,221147:25 1148:1,41149:19 1150:15 1151:81151:10 1164:14,151180:15 1181:7,151187:6 1188:22 1194:91196:24 1197:2 1198:181202:5,15 1206:101212:12 1215:9 1222:101222:25 1223:4 1224:181225:2,21 1226:211229:17 1239:16 1250:51258:14 1273:1 1279:251280:1,8,21 1291:121292:13,16 1293:10,151293:17 1294:19 1295:41295:9,24 1296:71298:25 1302:2,141304:15 1305:1 1315:41340:21 1364:25 1365:21365:5,9 1366:31375:25 1376:1 1383:7

areas 1071:4 1073:61085:20 1099:111107:12 1109:4 1113:171122:8 1137:25 1138:51190:8 1214:24 1222:111292:20 1375:3 1384:7

area's 1138:19arena 1293:17 1295:16arguably 1063:16argue 1205:22argued 1094:23argument 1055:15,161353:19

arguments 1055:12,131079:14 1344:8

Arizona 1067:12 1112:61247:13 1248:251252:15,20

arms 1182:6 1183:11army 1216:10arrangements 1278:18arrived 1054:18art 1082:24 1083:211277:17

artful 1142:19artfully 1327:13asbestos 1194:23,24



aside 1053:5 1157:21260:16,18 1323:121325:5

asked 1054:5 1055:91085:22 1109:9 1115:31115:6 1136:14 1160:131173:23 1177:1 1195:131195:24 1275:181283:23 1307:121318:11 1320:251324:21 1325:131327:13 1328:7,181361:13,23,24 1366:71370:10 1374:19 1380:2

askew 1169:8asking 1059:1 1082:241108:7 1110:10 1132:141132:14 1168:25 1250:71254:19 1285:6 1300:191316:5 1360:6 1361:121361:16 1368:221385:13 1387:14

asks 1324:12aspect 1068:15 1119:201144:20 1159:5 1164:6

aspects 1117:22 1315:91315:16,18 1354:171356:1,3 1375:23

Aspens 1180:10Assembly 1212:1assessed 1077:5 1366:2assessment 1062:1,41063:10,11 1113:91116:19 1227:191228:24 1243:14,151251:9,18,20 1286:171312:6 1379:13

assets 1138:23,25 1141:51273:5

assist 1376:2Assistant 1049:22associated 1059:81076:15 1111:9,91160:6 1220:19 1245:91293:23 1336:22

Associates 1074:11,171075:1

association 1151:15,17assortment 1155:6assume 1073:10 1075:41076:25 1097:8 1252:5

1257:12,25 1356:2assumed 1258:11assuming 1067:201082:11

assumption 1258:2assumptions 1259:12assure 1091:6 1216:2assures 1091:9astronomical 1092:11as-designed 1349:18Atlas 1070:23 1071:3,241081:20 1271:1,12,201272:5,18,25 1273:41274:1,12,15 1276:7,9

atmosphere 1094:41180:20

atom 1184:10ATSDR's 1228:23,25attach 1239:7attached 1163:9 1236:7attaches 1180:20attaching 1180:23attack 1199:7,14,15attempt 1141:16 1205:41275:20 1378:18

attempted 1253:24attempting 1078:4attend 1160:23 1301:24attended 1085:211105:22 1160:211232:19 1363:11

attention 1073:16 1086:31120:1 1160:17 1171:191177:16

attenuation 1106:201107:23

Attorney 1049:21,22attorneys 1167:19,21,221216:21 1304:5 1305:181320:24 1388:14

attorney's 1344:2attract 1219:18attracting 1138:24Audience 1055:2 1056:61152:22 1213:16

August 1069:20 1260:4,81348:21

authentic 1269:19authentication 1269:91269:13

authenticity 1269:23

authorities 1069:15authority 1080:141112:21 1117:4 1166:9

authorship 1322:10autism 1061:1automatic 1177:22availability 1093:181343:25

available 1053:241054:15 1071:9 1074:141084:20 1085:3 1092:11124:8 1146:19 1163:151168:25 1219:14 1227:51251:12 1281:21,211309:8 1328:21 1340:251341:3

avalanche 1130:9,12Avenue 1049:10avenues 1332:9average 1087:11,21,241090:6 1320:10 1326:251336:9 1369:15 1380:18

averages 1370:8avoid 1281:12 1284:221285:4 1286:9,241287:3,17,18 1315:9,161340:11 1357:15,16

avoided 1340:11avoiding 1258:8await 1124:5aware 1066:15 1073:251078:16 1120:25 1194:21210:19 1211:5 1241:171242:11,15,19 1243:201252:19 1277:131305:19 1316:8 1320:221321:16,16 1325:12,161326:21,23 1328:81334:15 1342:11,251346:2 1352:9 1359:71360:12,24 1363:8

awareness 1091:221156:1

awful 1164:2A-b-l-a-t-i-o-n 1256:12a.m 1048:19 1120:16,161387:21

Bbachelor 1139:8bachelor's 1149:6

back 1053:3,12,12,181054:23 1055:4,191056:3 1083:24 1096:201111:8,10 1133:201134:21 1135:131136:24 1137:23 1144:81146:2 1170:15 1172:221179:5 1180:1 1181:81181:23 1182:7,81184:11 1185:15 1186:41186:5 1189:1 1195:31195:15,23 1197:8,211198:7 1203:7,131207:13 1209:11,131218:13 1222:231223:11 1227:1,31231:12 1241:231248:18 1251:13 1253:11257:24 1259:161260:24 1269:131279:18 1280:12 1285:51285:15 1288:201304:13 1307:111312:17 1313:7 1317:191337:24 1344:14 1352:11355:24 1359:111361:13 1362:151371:14 1372:191373:21 1376:141385:18,20 1386:14

background 1100:81149:5 1173:10 1239:151277:6 1302:5 1327:221377:12

backwards 1283:241377:5

back-up 1367:7bad 1099:2,7 1144:71224:1 1369:16 1370:12

badly 1077:4Bair 1102:13,14,15BAKER 1049:2bakery 1155:12,151156:17 1158:16 1160:3

balance 1053:15 1145:5Ballantyne 1084:2,3,5ban 1111:4Bane 1152:24,25Bank 1130:17bankrupt 1062:191271:21 1272:5



bankruptcy 1157:231273:4,5 1274:12,16

Barclay 1154:18 1161:21163:24

barely 1200:12,12bargain 1172:4barium 1199:16,231265:2,5

barrier 1250:19base 1075:19 1081:131106:23 1151:1 1380:16

based 1066:9 1076:61082:16 1094:161098:23 1100:11 1105:51116:15 1120:6 1144:91149:15,24,24 1209:181213:8 1230:13 1234:121236:1 1244:19 1245:11262:9 1264:18 1317:121320:2 1323:8 1328:191336:8 1345:1,9,12,121346:7,17,25 1349:141363:1 1375:17 1386:31386:25

baseline 1050:2 1122:5basement 1238:10base-load 1103:5basic 1220:21 1315:13,231316:12

basically 1131:171172:11 1182:21 1219:31229:18 1280:9 1290:11291:13 1328:111362:14,16 1372:131373:25 1374:101375:16,18 1376:31380:15 1385:19

basin 1130:6,20,231157:11

basis 1063:12 1096:191098:13 1155:191244:22 1357:9 1358:221364:19

basket 1218:4bathtub 1197:19batteries 1146:7battling 1128:18bear 1054:13 1056:12bearded 1204:25bearing 1213:10beaten 1135:2 1231:14

beautiful 1073:5 1084:251085:10 1094:221131:14 1215:9 1221:31384:3

beauty 1079:2Beaver 1246:7Beckley 1152:19 1181:5becoming 1194:21215:17

Beede 1136:7,8 1137:6beets 1133:20began 1062:20 1070:241071:2 1237:3 1260:7

beginning 1048:191357:25

begins 1097:24behalf 1049:7,14,18,231065:14 1112:1 1360:16

beings 1058:6believe 1058:16,231059:24 1063:14 1064:71066:7 1067:14 1068:161083:2 1087:15 1089:11089:18,24 1095:241102:4,4,6 1112:71123:20 1128:151129:10 1140:25 1141:21146:4 1148:20 1154:91159:3 1171:19 1187:51195:13,16,21 1207:61215:24 1224:241231:22 1244:22,251245:7,17,19 1250:181252:12,25 1253:231254:24 1255:24 1256:11257:23 1258:171263:23 1265:201266:19 1271:181283:23 1296:221299:21 1301:4 1308:41314:15,22 1315:101316:14 1325:191328:13 1330:20 1332:71334:8 1345:3 1353:31354:10 1371:9 1380:31383:8

believed 1142:23Bell 1081:22belt 1106:15 1107:191111:24 1196:19 1330:11331:8

Ben 1139:3,7bends 1072:4beneficial 1068:191384:25

benefit 1054:2 1056:201090:18 1104:5,111129:18 1165:2 1172:41185:14 1186:1 1204:22

benefits 1067:20 1103:221104:1 1130:25 1225:191226:5 1331:14

benign 1298:21Benita 1198:9,10berm 1298:12,12best 1082:4,17,23 1083:51093:11,12,16 1104:81142:19 1158:7 1159:101162:12 1163:141181:10 1189:18 1190:71235:9 1275:15,161280:13 1300:1 1315:51362:8 1369:8 1378:18

bet 1367:14beta 1199:5 1202:20Betsy 1102:13,14better 1073:13 1080:121101:14,25 1116:211148:22 1156:9 1184:121184:13 1206:11 1258:91259:18 1288:2,241289:5 1293:2,7,91296:3,8 1303:241313:23 1328:111357:21 1384:9

beyond 1129:12 1192:91298:22 1304:221335:25

bias 1089:6biased 1169:17big 1061:11 1066:141067:9 1072:7 1093:191142:21 1176:241181:21 1183:8 1188:91195:18 1201:131205:14 1219:16 1292:41293:1,12 1300:8,181302:11,24 1304:151331:17 1333:1 1366:23

bigger 1084:5 1380:9biggest 1167:10 1298:7,7bike 1295:9

bikes 1295:11bill 1157:22 1169:5,211188:14 1219:6

billboard 1180:2billboards 1108:61300:19

billing 1358:19,23billings 1359:3billion 1062:12 1078:31106:22 1121:7,14,181159:24 1195:2 1222:151225:3

billions 1140:11,11bills 1115:25 1229:21binding 1328:2biodiversity 1092:231296:5

Biological 1049:19biotechnology 1061:10birth 1106:5 1176:81206:11

bit 1070:22 1097:141101:17 1148:2 1169:81170:24 1172:3 1175:81208:16 1287:20 1298:51361:5 1364:10 1377:1

bitterly 1220:25blacksmith 1147:9,12blame 1148:14Blanding 1066:17 1069:8blanket 1135:11blanks 1352:6bless 1207:19blessed 1138:23BLM 1181:11 1186:211195:23 1196:8 1197:51284:5,22 1285:4,15,181285:22 1286:7 1288:11375:19

blocks 1210:4blow 1130:5blowing 1123:3 1136:161222:23

blown 1122:6 1123:22blows 1222:24,25Bluewater 1213:241220:11

board 1087:8 1102:18,241151:14 1152:8 1209:171209:18 1211:191232:25 1233:5,10,14



1245:5,6,8,16 1302:51306:15 1322:1 1324:121324:21 1325:201364:13

Bob 1051:19 1096:41329:11,15 1332:12,181333:14

body 1199:7,25 1227:171282:25

boilers 1319:22Boise 1205:12bolded 1335:8bomb 1298:11 1303:7bombs 1182:16,221183:21 1208:21 1303:7

bond 1062:2 1063:15,181063:21 1071:12 1090:81091:17 1122:10,16,211159:17 1272:6 1273:41274:19 1276:10,13,151276:23,25 1277:251351:15

bonding 1064:6 1109:121114:14,21 1274:231275:1 1276:18 1277:211278:2

bonds 1278:5,5 1351:15bone 1121:5bones 1199:20book 1143:25books 1108:12boom 1067:18 1105:91107:11 1140:20,201175:19

boomer 1137:21boom/bust 1062:71087:17 1097:211156:14 1160:5

border 1077:3 1176:22born 1106:4,5,6 1147:101147:12 1212:12 1299:9

borne 1072:17 1108:251122:21 1159:13

borrow 1379:7bothered 1190:17bottom 1072:9 1198:11262:12 1270:21 1286:31329:14,23 1378:17

bought 1128:13,161294:11

Boulder 1050:3

Boulevard 1049:6box 1049:13 1178:8boxes 1070:5 1373:19brain 1154:2 1174:6brand-new 1127:231373:12

brat 1204:15breached 1298:12breads 1155:13break 1120:15 1231:181256:16 1290:5,9,111307:12 1344:19 1350:31375:3

breaker 1109:22breakfast 1150:2breaking 1366:23breast 1121:5breath 1203:17,20breathe 1131:13 1179:141180:17 1203:19

breathed 1179:9bridles 1293:22brief 1053:20 1070:111107:11 1256:14

briefed 1125:8briefer 1089:18briefing 1186:6briefings 1186:8,15briefly 1127:8 1289:21bring 1076:25 1085:121093:10 1138:6,6,81175:13 1182:9,151189:1 1235:3,71249:15 1253:8 1292:41296:6 1365:24 1368:8

bringing 1101:3,5 1195:31295:13 1304:7 1365:7

brings 1170:12broad 1068:23Broadview 1215:1broilers 1155:8broken 1107:13 1215:7brother 1106:8 1128:21brothers 1147:5brought 1094:25 1096:171102:7 1139:19 1166:171168:2 1171:18 1176:211195:7 1304:19 1314:31334:6 1356:12 1375:24

Brown 1106:9Bruce 1351:12,17

budget 1234:13,231235:4,8,20

budgeting 1234:6budgets 1234:9,18,20,211234:22,24

Buffalo 1294:9build 1108:23 1126:221127:25 1135:21,221136:12 1148:251154:15 1206:241211:18 1238:10,221313:17,18 1323:41324:15 1337:3,71365:25 1371:11

building 1066:8 1141:181153:5 1212:9 1222:171368:11,13,14 1382:101382:14

build-out 1347:4built 1066:1 1082:10,181083:20 1086:20 1088:21092:10 1096:131123:17 1148:3 1210:201215:10 1252:15,191253:3 1297:9 1345:191348:7 1374:10

bulk 1064:3Bull 1077:20,23bunch 1221:20 1386:11Burbridge 1143:12,13,14Bureau 1281:22,231354:21 1355:6,13

buried 1106:15burn 1137:17burning 1165:25 1318:12business 1063:201066:19 1070:201102:16 1103:231110:22 1127:191140:22 1141:4 1149:61149:11,14 1164:131181:2 1185:20 1188:81189:11 1191:2 1196:121210:23 1211:16,211248:7 1249:14,16,201258:25 1271:221287:17,19 1365:131374:6 1378:10

businesses 1079:101101:5 1188:6 1211:19

bust 1067:18 1105:2,17

1107:10,11 1175:19buy 1110:25 1164:41278:14 1280:6

buying 1295:11byproduct 1146:4,10B-e-e-d-e 1137:6

CC 1049:12 1053:1 1140:10cabin 1175:14calculated 1228:18calculation 1276:231345:1

calculators 1306:5California 1093:241212:13

call 1052:3 1105:81134:12 1168:25 1180:51183:14 1199:5 1221:41261:2 1300:19 1308:141324:25 1325:171332:23 1354:11,121358:24 1359:1 1380:16

Callahan 1352:17called 1060:6 1071:251092:15 1115:2 1143:251144:16,17 1165:191172:19 1174:22 1175:91177:23 1178:17 1180:21192:16 1199:4,5,61215:13 1294:9 1306:251376:8

calling 1055:5 1112:16Canada 1071:6 1132:191365:18

Canadian 1141:2,81206:22 1235:24,25

Canal 1166:1cancer 1099:24 1108:41113:3 1121:5 1128:151128:17,22 1176:91202:6 1208:3 1212:131212:15,16 1241:22

cancers 1128:23 1146:141202:23 1206:10

Candace 1213:231214:16

candidate 1126:14candidly 1169:1 1171:8Canon 1068:24 1077:181081:19 1108:1 1110:24



1111:15 1159:221194:13 1207:22 1208:31214:6 1224:6 1304:10

Canyon 1077:20,23Canyons 1111:20,20,22can't-get-a-job 1205:1cap 1271:1,13,24 1272:11272:2,3,4 1273:13,211274:2 1276:12 1311:31311:8,10,12,14,14,171311:17 1349:18

capable 1074:18 1140:16capacity 1082:23 1083:51183:20 1258:16,181317:15 1323:5 1334:141335:13,17 1336:181347:13,15 1348:7

capital 1138:25 1235:101235:13 1237:7 1323:6

capitalization 1125:251126:13,22

capitalize 1138:19car 1059:22Carbide 1081:19,221128:14

carbon 1199:24carcinogenic 1061:5cardiac 1154:3care 1063:24 1094:221174:2 1200:22 1203:51203:14,16 1204:3,211208:24 1215:141261:16 1351:25

careers 1104:1careful 1170:19carefully 1064:15 1347:7carried 1304:17carrot 1214:22carry 1059:22 1179:81235:19 1237:22

Carver 1279:7 1283:211284:1,4,7

Cascade 1077:11 1080:171205:13

cascading 1331:20case 1053:13 1075:71089:1 1110:1 1170:111170:13 1176:1,21216:15 1281:20 1288:41320:23 1332:12 1338:41346:25 1347:3,9,17

1349:16 1370:6 1382:131382:22 1385:12

cases 1061:6 1097:181202:19 1281:10 1352:81359:5,8,9

castle 1141:18cat 1286:22catastrophic 1157:11catch 1137:3categorical 1286:16,22category 1255:4 1341:201341:21

Catherine 1290:15,16cattle 1213:5 1299:8caught 1114:25 1202:191205:25

cause 1057:17 1113:3,151202:23 1209:5 1220:151232:4 1355:1 1382:23

caused 1091:19 1126:81219:16 1346:8

causes 1175:24causing 1103:14 1346:13CD 1051:9 1269:10CDL 1200:8CDPHE 1051:9 1057:231058:8,11,16,17,201059:6 1060:4,8,171061:16 1073:13 1076:91087:2,22 1088:231089:22 1090:2 1094:181095:21,22,24 1096:121098:6 1099:16 1100:161102:8 1106:19 1113:71113:11 1115:1,4,61116:21 1117:3,13,221119:11,19 1122:2,41131:18 1132:14 1135:41135:20 1158:4 1159:161166:15 1168:6,9,251170:15,15 1171:71177:12,13,23 1178:61178:18,21 1195:251203:22 1251:14 1260:81261:1,14 1262:131278:16,22,25 1288:211306:7,11 1312:201317:6,11 1318:101324:7 1325:24 1326:51326:18 1328:2 1337:51346:6,24 1347:24

1351:4,15 1356:23,231357:1,4 1358:13,15,201359:15,22 1360:31362:9 1373:21 1374:161375:8,14 1376:51377:17 1378:5,61383:18,19 1385:6

CDPHE's 1078:81117:12 1122:101230:13 1243:17 1287:91323:24 1324:4

ceased 1057:14ceiling 1179:13cell 1274:4 1345:131347:5,13 1348:61349:17

cells 1076:12 1345:151353:7 1363:16

cement 1210:3center 1049:10,181130:10 1293:17,251294:19 1295:12

centrifuge 1330:18centrifuging 1330:19cents 1126:4 1218:14,14centuries 1220:18century 1062:6 1133:20CEO 1263:11,16 1297:2ceramic-lined 1210:3certain 1064:5 1074:71076:18 1096:23 1152:81185:4 1188:6 1190:81235:1 1237:20 1238:121239:21 1255:16 1262:71286:18 1287:171300:19 1311:121326:19 1330:251358:14

certainly 1132:181161:17 1219:22 1239:91239:14 1240:241241:16 1242:1,1,51243:11 1245:181250:22 1254:25,251259:15 1281:191282:23 1285:16 1287:11287:3 1288:2 1326:31354:2 1358:11 1385:11

certainty 1076:7CERTIFICATE 1388:2certified 1234:14

certify 1320:18 1388:4,71388:12

cesium 1199:16cetera 1096:9,12 1099:231100:19,19 1136:171180:15 1181:13,131185:2,2,21 1189:131194:6 1198:1 1305:1,1

cfs 1339:20chain 1233:2,6chair 1054:18chamber 1102:15,171132:20 1145:10,13

chance 1104:23 1124:71173:9 1232:9 1269:71310:5 1372:6

chances 1171:8 1219:7change 1091:11 1094:31145:21 1215:25 1217:91220:7 1230:14 1262:71327:10 1328:16 1329:51329:6,8 1331:3,3,5,6,91331:17,20 1332:171386:22,23

changed 1069:131070:10 1082:121133:22 1144:1,191211:12 1276:161322:14,16,23 1374:71386:18

changes 1077:6 1082:71093:20 1094:3 1230:181230:22 1231:4 1271:51276:15 1316:18 1317:61318:3,8 1327:4,4,6,7,81327:14,14,17 1328:3,41328:4,6,6,23 1329:11332:10 1385:9 1386:2

changing 1319:22characteristics 1280:4characterization 1270:5characterize 1242:241324:11,19

charge 1351:2charged 1057:24 1058:111121:24 1179:17

charges 1360:3 1361:25chat 1232:9 1284:25cheap 1183:4check 1054:6 1095:51143:22



checked 1110:14checking 1153:25chemical 1367:20chemicals 1085:81092:19 1184:191221:21

chemistry 1184:10Chernobyl 1188:18Cherry 1263:7,11child 1105:14childbearing 1202:17childhood 1215:13children 1060:191095:12 1106:4,5,61121:4 1134:9 1148:61148:19 1151:121162:18,19 1170:101201:12 1208:10,201209:2,5 1211:131293:5,5

chimney 1307:5Chinley 1383:17Chinle-Moenkopi1074:15

chiseling 1174:17chloride 1265:2,5choice 1148:12 1150:7,191168:10 1217:12

choose 1221:3 1289:2,7chop 1200:4chose 1308:8Christian 1127:2,3,6Christianson 1127:1Chuck 1330:7 1331:21385:4,5,18

Church 1212:1 1277:2,81277:14,16

CH2M 1315:12,181316:11 1319:7 1367:51372:16

circled 1279:18circumstance 1236:14circumstances 1237:201237:21 1238:13,25

citation 1267:1citations 1069:21,22,231270:6

cite 1227:3cited 1153:12 1265:11,14cities 1071:20 1137:221240:12

citizen 1065:21 1114:241160:1 1208:8 1221:91378:4

citizens 1056:19 1057:251058:14,15,18 1060:101069:3 1070:12 1087:61091:15 1120:111122:16 1151:22 1152:11159:2 1189:19 1198:41214:6 1216:20 1219:231224:7 1291:23,231292:3 1296:3,8

citizen's 1112:19 1157:16city 1068:24 1077:181081:19 1108:1 1110:241111:15 1112:6,91122:25 1159:221194:13 1207:22 1208:41214:6 1224:6 1304:10

civics 1170:24claim 1182:1 1221:71224:16 1228:131229:11

claimants 1108:12claimed 1227:25 1229:5claiming 1226:1claims 1108:19 1227:2,111228:9,23 1281:10

clarification 1284:141289:15 1358:25 1359:81361:12

clarify 1269:2clarity 1243:9class 1106:2 1207:91216:1

classmates 1106:3,51148:10

clause 1110:21clay 1192:14 1353:1,3,6clean 1070:1 1072:10,241073:6,6,9 1077:241078:4,12 1093:11095:11 1097:6 1100:181100:20 1103:2,51121:10 1138:1 1156:41156:4,5 1160:2,4,101165:19,19 1167:8,91185:9,10 1210:241215:6 1217:6 1256:21264:18 1270:111277:14 1353:17

cleaned 1075:14 1106:191107:9 1132:8 1209:251221:24

cleaner 1133:15cleanest 1092:8cleaning 1062:121072:22 1121:11,151195:2 1208:6 1222:21277:23

cleanly 1374:18cleanup 1062:3,14,161063:15 1071:2,131076:17 1078:2 1090:41090:7 1091:17,191107:22 1122:141132:10,12 1143:211157:22 1159:12,17,191165:13 1218:9 1222:11222:15 1225:6 1302:91302:11 1346:21

cleanups 1159:25clear 1053:21 1083:141145:20 1158:7 1240:161240:21 1243:10 1276:31279:19 1384:4

clearly 1114:19 1127:91176:3 1216:16 1219:191241:9

clears 1383:15clear-cut 1205:13 1206:4clear-cuts 1207:11clear-cutting 1205:22click 1178:10clientele 1294:11climate 1094:3,3 1208:141295:15 1296:5

clock 1307:21close 1059:12 1109:121154:16 1159:211176:11 1236:171257:17 1262:13,141280:11,23 1294:41299:16 1301:8 1315:101348:6 1349:23 1358:31359:22,24 1386:13,21

closed 1070:25 1072:21257:21 1347:18

closely 1056:13 1091:51154:10 1232:141291:19 1328:181375:19

closer 1056:15closes 1124:22closing 1066:15 1070:111086:11 1126:3 1133:161176:6 1347:20

closure 1108:1 1247:221247:24 1273:3,6,141274:20,20 1345:9,231346:8,14 1348:2,9,181348:20,23

cloudiness 1143:9clouds 1180:21,23clumsy 1205:4coal 1130:17 1151:181212:21 1244:9

Coalition 1049:19Cobalt 1199:15cochair 1224:7cohesion 1227:16cold 1105:13,16 1384:3collaborate 1152:3collapse 1080:11 1105:19collateral 1112:17collect 1190:15collecting 1261:12collective 1073:2Coloradan 1105:3Colorado 1048:21,251049:4,7,11,13,17,19,231049:24 1050:3 1056:171056:19 1057:4,6,181059:14,24 1060:101062:5,9,11 1063:251064:9,13 1065:51067:15 1068:22 1070:81070:14 1072:4 1075:201076:16,22,25 1077:21077:13 1078:4 1080:61089:14,24 1091:1,4,81091:20 1092:12 1093:21094:19 1097:1,171103:19,20 1105:81106:21 1109:14,201110:12 1111:13,171114:23 1115:121116:25 1117:14,161120:8,11,19,231121:11,23 1122:201130:9,13,21 1132:41133:17 1138:231144:16 1154:22,23



1157:25 1159:23 1160:11166:6,9,9,11 1175:221180:10 1189:141191:16,17,21 1192:231193:6 1195:1 1198:31198:11 1201:22,231214:6 1215:11 1216:121219:23 1221:10,231223:24 1224:1,2,2,71225:18 1230:9 1231:71246:3,10 1247:9,111248:2,25 1250:61257:13 1258:1 1265:121266:17 1269:211273:10 1278:12 1282:11296:19 1319:5,10,121354:20 1371:8 1378:101379:10 1388:1,6,21

Colorado's 1201:241220:22 1264:7

Columbia 1121:18combustion 1303:2come 1053:15 1055:211071:6 1084:13 1089:171097:16 1104:2,231108:8 1119:1,71124:25 1129:20 1130:31133:5 1136:1,31140:21 1141:11 1147:41149:3,25 1152:51162:12 1163:11 1166:41169:20 1172:14 1173:31174:11 1175:9 1186:101187:16 1195:221204:10 1207:121211:20 1220:24 1223:51223:25 1225:101247:25 1254:131269:13 1278:18 1285:51290:19 1294:131299:17 1302:12,231307:11,16 1316:251338:15,16 1352:191359:18 1370:161372:13,24 1373:201375:6 1376:14 1380:2

comes 1055:24 1059:201060:9 1099:16 1103:41104:12 1156:2 1158:191170:25 1184:151191:20 1193:3,4

1197:8 1222:25 1242:131242:17 1366:6 1381:231382:5 1386:10

comfortable 1073:71179:1 1382:2

comforting 1117:21coming 1056:10 1092:41096:20 1100:24 1101:51101:8 1112:5 1124:211173:3 1198:7 1201:71203:13 1211:22 1213:11231:23 1261:24 1267:71293:12 1295:7,7,101304:10,15,23 1330:101330:22 1333:121336:23,24 1362:151370:19 1371:3 1372:211385:4

comm 1187:4,5command 1233:2commenced 1086:6comment 1053:18 1055:11064:25 1154:201172:21 1184:5 1209:71209:8 1213:15 1225:111225:15 1230:25 1231:91290:20,24 1307:101380:16

commented 1118:14comments 1051:2 1053:51053:7,9,14,22 1054:2,81054:14,16 1055:91056:4,7 1061:251065:14,22 1072:11073:24 1083:241090:15,19,21 1093:71097:15 1102:3 1104:151104:16 1151:11,131152:16,21 1187:21213:20 1214:141230:17,20 1231:12,131243:17 1261:1 1301:131359:20 1375:121380:12,19

Commerce 1102:161132:20 1145:11,13

commercial 1088:201134:17

commission 1090:61115:11 1171:201216:17 1223:16 1288:1

1363:12 1374:3 1380:31380:6 1388:18

commissioned 1111:20commissioner 1086:71151:23

commissioners 1087:81087:13 1088:141296:24 1297:7 1306:15

commitment 1119:22committed 1117:131367:9

Committee 1221:12commodity 1105:15common 1076:1 1105:71109:14 1352:1 1385:22

commonalities 1152:2communication 1325:24Communications1049:5

communities 1062:191080:13 1094:23 1095:61101:11 1129:181130:20,23 1137:201156:13 1158:171164:10,17 1165:1,5,201173:15 1219:5

community 1069:31101:4,13 1102:51110:22 1123:19,211152:13 1155:3,181164:12 1180:11 1208:71210:13,16 1211:5,151211:18,24 1212:3,251215:16,25 1216:11217:6,9,14,14 1218:2,61220:9 1227:16 1229:111229:20 1291:24

commute 1150:21commuting 1151:1companies 1062:181071:14 1108:25 1116:11157:22 1159:9 1205:121206:16 1207:1 1216:111216:21 1218:7 1219:161259:25 1260:1 1306:21

company 1066:24 1071:61083:10,10 1110:131117:20 1124:181125:14,23,25 1126:51126:10,14,15,211141:2,8 1194:8,23

1206:19,22,24 1233:221235:24 1253:22,251261:14 1264:1 1266:181270:7 1276:8 1297:131324:17 1325:3 1343:151343:19 1349:201351:11,14 1354:31362:16 1376:1,12,20

company's 1205:211216:3 1262:20 1275:21276:20

compare 1068:20 1135:9compared 1116:121153:18 1238:2 1289:23

comparing 1239:11comparison 1091:181135:14 1313:11,19

compelling 1160:15compensated 1106:121174:18 1175:2,8

compensation 1106:131108:11,14,15 1110:191121:7

competent 1177:12compile 1119:5complain 1101:23complaining 1101:9complaints 1101:16complete 1107:7 1349:81349:18 1353:151363:15,17,18

completely 1056:111071:15 1106:16 1107:11115:23 1116:151125:16 1230:10 1248:11331:25

complex 1218:12 1283:31295:6

compliance 1268:14,251314:15 1379:131386:19 1387:1

complicated 1193:201275:10

complied 1266:211357:14

comply 1266:19 1268:181268:20 1386:24

complying 1098:12component 1148:161240:15 1288:17 1353:31353:16



components 1239:31288:12 1345:251353:11,18

compound 1350:1comprehensive 1230:201328:21

computer 1320:131387:16

computers 1054:12con 1386:1conceivably 1317:17concept 1081:3 1249:211310:3,4 1334:6

conception 1347:22concepts 1081:3concern 1071:8,171090:1,3 1093:181094:2 1126:12 1131:171170:8 1210:1 1217:171235:21,23 1236:6,6,121237:1 1282:21 1286:21305:20 1329:25 1354:21370:3 1384:8

concerned 1057:5,151059:15 1063:19 1071:31076:19 1077:14 1079:31125:22 1129:19 1140:31142:3 1148:2 1156:211163:24 1164:8 1167:221170:3 1174:2 1178:11179:7,16,19 1207:161208:8 1209:21 1221:91225:17 1291:14

concerning 1115:191153:19 1220:4 1233:111251:25 1343:251353:13 1360:3,4

concerns 1058:3 1074:61093:10 1115:5 1123:161127:11 1129:2,111141:4 1156:14,201158:12 1169:13,141177:14 1188:1 1215:81262:10 1266:18 1271:91305:21 1307:7 1379:221386:4

concluded 1241:21conclusion 1058:251081:3 1111:21 1228:251332:7

concurrence 1119:9

condition 1086:3,231087:10 1118:201254:10 1355:19

conditional 1088:15conditions 1061:11064:17 1070:1 1072:171075:12 1086:1,21087:7 1130:12 1158:151220:4 1251:19,21,251262:4 1320:5 1341:16

condo 1133:8conduct 1161:6 1164:131177:15,18 1281:13

conducted 1145:141160:22,24 1218:231353:22

conducting 1178:111273:6

conduits 1070:4Cone 1157:5,5confer 1377:17conference 1052:31354:11,12

confidence 1126:51157:25

confidential 1051:221315:8,9,16 1318:191343:23 1344:1

confidentiality 1254:41344:7

configuration 1316:22configurations 1310:161311:24

configured 1284:21confinement 1076:5confirmed 1149:20confirming 1086:21conflict 1183:16confuse 1289:16confused 1083:111127:14 1230:111240:20 1287:201368:23

confusing 1115:5 1230:7Congress 1142:221165:16,17,17 1173:221185:14 1189:131198:11 1273:7

congressional 1173:20conjunction 1335:9connected 1286:2,5

1306:23connection 1118:131205:19

connections 1263:20Connie 1190:17,251192:1

conscious 1291:17consent 1065:10,12consequences 1058:51121:20 1131:2 1228:11303:1

Conservancy 1355:8conservation 1065:17conservative 1218:24conservatives 1216:9consider 1062:6 1064:151093:4 1095:25 1131:11132:6,7 1133:251134:10 1150:101217:21 1220:231241:13 1250:21,241255:12 1274:6 1278:31323:14 1364:22,24

considerable 1120:1considerably 1218:19consideration 1068:91080:16 1093:9 1094:61095:15 1117:231119:25 1152:161254:13 1279:3 1282:15

considerations 1098:141098:15 1102:7 1188:25

considered 1063:101083:4,16,19 1157:181163:3,3 1172:5 1176:51248:17 1254:9 1277:171277:22 1298:6 1337:91337:20 1338:2 1356:231384:8

considering 1060:201073:23 1075:12 1113:81117:1 1125:16 1279:22

considers 1088:24consist 1225:25consistency 1230:11consistent 1357:111370:9

consistently 1062:91117:20

consolidating 1258:4constituent 1146:6

constituents 1265:8constitutes 1388:11constitutional 1157:16constrained 1064:5,10constraints 1102:231342:2

construct 1103:1constructed 1227:61345:15 1381:18

constructing 1272:4construction 1068:111086:13,22 1089:81092:15 1097:241136:20,23 1149:51223:7 1255:6 1316:241317:10 1322:19 1323:11323:10,19 1348:211349:18 1351:13,211353:2 1360:5,8 1361:11361:4,18 1362:1,10,121362:20 1365:251368:24 1369:1 1375:41381:23

Construction's 1351:8consultant 1277:41352:9 1372:15

consultants 1280:141339:17 1352:2 1375:171375:24 1376:4 1379:16

consulting 1276:81343:15 1376:1

consume 1299:6consumer 1145:141295:16

consumption 1383:11contact 1314:21contacted 1314:18,22,251315:4 1381:8

contacts 1381:11contain 1122:19 1141:141194:3 1301:19

contained 1100:221116:7 1194:11 1204:11299:13

containing 1200:5containment 1063:61076:6 1080:5 1298:12

containments 1076:9contains 1103:8contaminate 1057:161059:17,21 1076:23



1154:1contaminated 1075:251077:19,22 1097:61107:21 1114:9 1121:101132:8 1157:20 1174:191175:21 1198:191214:24 1215:18 1225:31225:4 1277:20 1300:1

contaminating 1059:51075:22 1085:191157:14

contamination 1057:4,81060:11 1062:9,101075:16 1076:20 1080:71080:11 1085:6 1096:251105:19 1113:131121:17 1131:221138:18 1156:21 1157:71157:10,17 1158:10,231159:23 1174:20,221215:5,6,22 1216:51217:5 1218:6 1220:171224:22 1225:11 1346:4

contested 1358:19context 1055:13contiguous 1280:10continent 1084:19continents 1173:12contingency 1057:191075:9 1278:4

continually 1093:13,221094:1

continuance 1380:17continue 1077:201108:18 1149:191163:25 1184:211188:11 1194:3 1215:211310:10 1344:23

continued 1050:1 1052:11105:20

continues 1088:71215:23 1246:7

continuing 1169:9continuous 1106:241311:10

continuously 1108:13contract 1355:8,10,12contractor 1075:1 1263:71374:15

contractors 1235:141236:16

contracts 1353:13contractual 1263:19contrary 1224:18contrast 1226:7control 1068:22 1102:81106:18 1115:22 1194:41217:13 1223:17 1292:11292:4 1296:4 1319:61319:10 1327:9,12,151327:18 1328:7,211330:16 1369:25 1370:11372:1,22 1384:161385:13 1386:23

controlling 1061:12controls 1229:4convenient 1231:18conventional 1067:11308:14 1309:5 1310:121310:18,21,25 1311:3,81311:20 1346:2 1374:51374:13

converge 1068:4conversation 1137:131168:7 1183:9

conversion 1365:17convinced 1165:2Cooper 1279:12,141283:17,21 1284:12,201284:21 1285:16

cooperative 1163:18Cooper's 1285:11Cooper/Carver 1289:16copied 1328:13 1329:81331:6

copy 1084:3,4 1214:151272:9

core 1220:12corners 1126:11 1131:81293:17

corporate 1060:1,21083:17 1088:4 1143:151292:2 1294:23

corporation 1070:151081:20,21 1149:201216:19 1232:12 1234:71235:24 1291:131293:12

corporations 1061:91078:11 1165:211210:11 1216:6 1291:91291:20 1292:4

correct 1167:7 1168:31170:17 1232:12,13,171232:18,20,21,251233:4,12 1234:1,7,81235:4,8,11,16 1236:181238:15 1239:5,251242:22 1245:151246:11 1247:14,231248:4,5,9 1249:1,5,61249:18 1250:8,11,211250:25 1251:10 1252:21253:5,14,15 1254:111254:16,23 1255:12,131257:22 1258:5,10,111258:22 1259:6,14,161259:18,22,23 1260:21260:13 1261:22 1262:41262:5,18,25 1263:1,3,41263:17,18 1264:2,5,81264:12 1265:13 1268:61268:9,15,17,19,251270:13,18,19 1271:141271:25 1272:6 1273:151274:4,5 1275:161276:7,12 1277:3,4,101278:10,14 1280:61281:14 1282:11,171283:1,4,5,7,8,10,15,191284:3,6 1285:241286:10 1288:191289:12 1308:6,10,111309:9,10,24 1310:171313:3,4,8,9 1314:4,131314:16,25 1317:7,121317:13,16 1318:23,241319:1,11,14,19,23,241320:4,10,11 1321:131324:2,9 1326:1,11,141326:16,22 1328:251331:16,22 1332:111334:1,5 1335:14,15,251337:3,11,18,20 1338:81339:10,19,20 1340:3,41340:7,9,13 1341:5,7,101342:7,24 1343:231345:7,8,11,25 1346:1,91346:14,15,18,19,22,231347:1,10,25 1348:1,211348:22 1349:3,251351:1,16 1352:13,231352:24 1353:24

1354:18,19 1355:5,141355:17,21 1356:13,191356:25 1357:15,231358:10,17,18 1359:161362:13,24 1363:61373:1,9,11 1380:81383:14 1385:7 1388:11

corrected 1228:20correcting 1252:24corrections 1289:17correctly 1084:1 1120:91151:5 1232:1 1265:18

correlation 1299:3correspondence 1385:19corroborates 1112:2Cortez 1151:19,221180:1 1292:16

cost 1051:25 1057:201062:3,13,16 1063:231072:9 1084:21 1090:31090:7 1091:19 1092:111106:21 1107:2 1117:161121:11 1122:13,161132:10 1141:101159:20 1223:3 1247:71247:12,15,16,171248:24 1287:10,131324:16 1347:12 1348:81349:2,14,23

costing 1107:8costs 1063:22 1064:31071:13 1072:9,111076:14 1106:23,231108:17,24 1122:201143:1 1150:11 1153:181159:12 1218:181219:20 1223:201225:20 1277:131287:19 1331:141348:10,10

Cosy 1071:23Cotter 1077:25 1081:201108:1 1208:4 1224:111224:19 1225:5 1226:111227:24 1228:13,151229:6,11,13 1230:41263:3,9,12,15

Cotter's 1226:8 1227:201228:16 1229:24 1230:11230:3

couch 1081:2



couched 1240:12counsel 1054:2 1055:81090:18 1246:181329:22 1331:241333:10 1388:13

counsel's 1323:8count 1070:12,13,151371:5 1372:3

counties 1057:181071:20

countries 1103:1 1219:15country 1099:4 1124:41164:11,16,19 1165:151183:19 1185:3 1186:91186:19 1197:201204:16 1215:14 1244:11292:25 1298:8

country's 1222:6counts 1056:23county 1056:17 1061:241063:17 1065:231085:22 1086:7 1087:61087:7,12 1088:131103:8,23 1111:18,221112:9 1118:20 1124:101124:13 1143:191151:23 1164:7 1172:251174:17 1198:121215:11 1218:3 1241:181250:14 1282:17,19,211282:24 1283:1,4,7,141283:15 1294:251296:21,24,24 1297:5,71320:8 1326:5 1336:71336:12,13 1380:7,131380:19 1388:3

couple 1066:21 1128:131128:16 1140:221151:19 1176:1 1180:141182:13 1190:14 1199:31225:12 1276:5 1307:151334:3 1364:9 1366:121383:1

courage 1293:6course 1067:4 1075:12,181076:22 1077:1 1110:41148:21,22,23 1176:231194:6,13 1197:71198:25 1201:11 1217:91238:6 1298:23 1357:171361:16 1370:25 1371:2

1374:6 1381:14 1382:11court 1065:7 1083:231168:20 1171:9 1176:31229:14 1272:10

courtesy 1316:8courtroom 1178:15cover 1062:2 1063:231072:12 1081:4 1090:81113:22 1271:5,71276:11,14 1311:101334:12

coverage 1362:2covered 1122:15 1190:251225:21,24

covering 1113:25covers 1225:11 1226:1co-op 1293:22,23co-op's 1293:22CO2 1154:13Craig 1152:6crater 1218:5create 1099:25 1100:221101:1,7 1119:61185:20 1188:8,22

created 1072:21,251074:3 1096:13 1102:201109:8 1147:5

creating 1074:4 1146:15creation 1073:3 1103:251148:5 1258:8

credentials 1191:1credible 1255:14Creek 1147:5 1151:21153:23 1292:16 1302:8

Crescent 1274:3,6,8crew 1186:8crews 1212:21criminal 1075:20crippled 1157:9criteria 1258:10 1259:131259:18 1280:4 1283:10

critical 1105:4 1217:1croplands 1122:7cropped 1164:19crops 1122:9 1214:22cross 1102:19 1231:231267:3,8

cross-examination1051:4,5,5 1055:111184:4 1232:1,6,101290:14 1308:1

Crownpoint 1218:12crush 1368:8CSA 1155:2,3cultural 1314:19cultures 1133:22cumulative 1060:241067:25 1068:8 1112:16

Cunningham 1214:5,61224:4,5,6

cure 1146:14Curie 1121:1curious 1333:12current 1064:10 1071:121078:6 1082:4 1086:211093:16 1104:8 1149:151159:21 1176:4 1249:231251:18,25 1261:111262:3 1275:2 1278:71278:14 1285:4 1308:131339:11

currently 1072:141077:23 1092:3 1094:201103:3,8 1139:101150:1,21 1229:221232:16 1270:20 1274:21277:23 1318:20 1319:4

cursory 1116:23Curtis 1049:5 1355:24curves 1072:4customers 1155:4cut 1054:6 1126:111173:5 1205:14 1343:91379:22

C141 1181:24 1186:5

DD 1049:3 1051:1 1052:11053:1

dad 1146:16 1218:11daily 1087:18,21 1124:11Dale 1136:7 1137:6damage 1085:13,161112:17 1154:3,31162:11,13 1175:241176:4,4,8,10 1226:171229:14,15

dammed 1147:5Dana 1048:18 1064:231079:13 1084:6 1094:171123:14 1131:4 1154:191214:15 1303:21

danger 1109:22,241120:25 1206:221306:21,23

dangerous 1059:91072:18 1084:231138:25 1159:101219:19 1220:4 1229:91239:4 1240:14,17,181244:8,10,12 1297:231299:12

dangerously 1107:4dangers 1210:18DANIELS 1049:2Daranyi 1154:18,19dark 1069:9data 1077:17 1143:41190:15 1195:7,9,11,14

date 1078:3 1236:201237:3 1246:24 1267:191272:18 1338:221339:14

dated 1051:17 1318:251321:12 1374:5

dates 1237:1daughter 1148:101217:15 1220:1

David 1296:18Davis 1108:9dawn 1367:16day 1053:9,16 1057:11087:11,14,17,22,241088:18 1102:121118:15 1141:8 1150:21150:3 1163:7 1164:11170:11 1177:4 1185:221188:4 1189:6 1209:191258:15,17,19 1297:201298:24 1299:25 1303:81307:3,22 1317:16,181320:3 1323:21 1324:11325:14 1326:251333:25 1334:201335:13,18 1336:6,101336:13,16,20 1368:151368:17,24 1369:1,151369:22 1370:141371:21,22 1388:17

daylights 1163:11192:17,18

days 1114:10 1129:81139:6 1170:23 1181:25



1184:11 1188:2 1189:71193:19 1200:3 1211:171307:15 1314:16,171359:10 1364:9 1369:141383:1

day-to-day 1234:12,251235:19

dead 1106:4 1174:9,101208:3 1217:19 1231:15

deadline 1086:15deadliness 1245:3deadly 1105:21 1199:171241:10 1242:21,241243:22,23,25 1244:121244:14

deal 1071:16 1081:141109:22 1126:6 1135:71135:24 1136:6 1153:231164:20,24 1167:23,241211:12 1223:18,201239:1 1250:13 1315:141320:1,13 1330:11358:1,8

dealing 1178:21deals 1178:15dealt 1072:15 1074:41111:7 1257:1 1333:21334:4

dear 1154:19 1173:131178:22

death 1135:2,25 1164:251165:7

deaths 1241:5 1299:10Deb 1178:7debate 1245:2debilitating 1161:22decade 1197:13 1211:131224:19 1230:9

decades 1113:16 1140:231210:23

decay 1141:20December 1051:211153:3 1267:20 1335:5

decent 1373:23DeChristopher 1197:1decibel 1367:7decibels 1367:8decide 1110:16 1204:2decided 1164:15 1165:141166:6 1246:15 1273:81273:24 1275:25 1278:1

1362:16 1363:1decides 1109:25deciding 1278:14decision 1116:22 1119:21119:6 1140:16,171144:9 1168:18,221169:22,23,24 1171:21174:18 1204:131207:15 1220:25 1221:21228:7 1254:13 1275:91278:19 1316:23 1317:4

decisions 1144:91167:25 1233:11 1234:61234:12

decision-makers1061:12 1172:1 1275:8

decision-making1115:25 1234:25

declared 1157:22decline 1087:20decommission 1109:5decommissioning1051:24 1063:22 1109:61345:2 1348:10 1349:211361:15

decontamination1063:22

decreases 1067:5decree 1229:14dedicated 1172:13DeeAnna 1143:12,13deem 1095:22deemed 1298:23deep 1057:17 1065:221200:15 1203:19

deeper 1126:15,21deeply 1065:24 1069:11077:14 1104:20

deer 1367:12default 1107:7defaulted 1107:2 1116:1defects 1070:3 1106:61176:8 1206:11

defend 1089:3deferred 1063:4deficiencies 1228:17deficient 1158:4deficiently 1225:22define 1235:23 1289:3,61316:1 1338:11

defined 1114:19 1338:10

1338:14 1349:15definite 1161:22definitely 1265:9 1286:61306:23 1321:11 1354:6

definition 1127:161236:7,9,12

definitive 1227:131324:19 1326:3

degradation 1150:131193:15

degraded 1085:111138:16

degree 1149:6delay 1064:11 1287:181362:2

delays 1224:21,24 1360:51360:8 1361:1,41362:10,12

delegated 1357:4deliberate 1143:9deliberately 1142:18deliver 1205:16deliveries 1367:10,18,23delivering 1074:18delivery 1370:11Delores 1075:18,191076:21 1077:211079:23 1118:231122:19 1151:3,231340:1 1341:4 1353:121355:1,8

Delta 1122:8demand 1082:22 1084:171092:6 1102:25 1103:4

demons 1332:16demonstrate 1262:211266:15

demonstrates 1142:1Denarius 1246:6denial 1095:13 1120:51206:14

denied 1082:25 1083:191086:20 1090:121296:25 1386:8

Denison 1069:221083:13 1153:1,6,11,121153:14,18 1245:5,9,181250:12

Denver 1049:4,17,231081:22 1168:20 1171:91194:7 1388:3,21

deny 1064:16 1073:121077:7 1089:10 1094:18

denying 1063:12 1088:11115:13

department 1049:241057:6 1059:25 1062:51064:4 1065:5,101068:4 1070:14 1091:41091:5 1095:15 1098:61116:13,13,25 1117:151119:18 1120:8,231121:6,23 1125:2,4,111126:18 1130:13 1132:91157:25 1166:10,111189:14 1216:131223:19 1225:9 1227:41228:3,5,5 1229:231231:1 1269:21 1273:151278:13 1306:161319:12 1327:3 1371:81382:6 1384:24

departments 1125:3department's 1116:171225:1,14,25 1227:19

depend 1154:10dependent 1156:5,111157:3 1158:16 1160:31160:14 1343:3

depending 1145:4depends 1140:1 1258:16deplete 1156:10depleted 1203:12depletion 1354:251355:1

depopulated 1137:19deposit 1078:22 1111:2deposited 1070:24deposits 1067:121084:20 1103:9

depressed 1145:24descend 1078:18descendants 1315:3described 1106:171192:15 1289:25

descriptive 1061:2desert 1187:7design 1076:8 1087:151087:22 1114:16,171271:1 1272:1 1273:131274:13,17 1275:151278:3 1313:12,23



1315:13 1316:12,16,181317:4 1318:1,2,41319:7,21,23 1332:131332:19 1333:251346:17 1372:19,25

designated 1062:151315:8,18 1343:22

designations 1071:21designed 1076:4 1082:161122:12 1166:3 1268:191270:23 1271:241317:14 1320:2 1335:101352:23

designs 1068:11 1076:111313:23

desperate 1206:3despite 1067:22 1069:41121:16 1170:2 1227:11

destination 1149:25destroy 1101:1,9destroyed 1106:151208:13

destroying 1205:23destructive 1208:21detail 1065:13 1120:11243:15 1289:221381:25

detailed 1254:16,221283:18 1284:1

details 1177:16 1178:151257:25 1316:7

detection 1076:5deteriorates 1206:9determination 1262:151355:7

determine 1078:131161:5 1185:13

determined 1086:191128:5 1168:15 1176:31355:18

determines 1239:2determining 1117:7detract 1088:7detrimental 1103:15devastated 1137:201164:22

devastation 1080:101081:16,17,19 1105:18

develop 1138:24 1142:101142:25 1295:8,25

developed 1064:12

1089:4 1105:1 1205:151294:18 1295:201334:13

developing 1067:111141:4

development 1066:111077:18 1078:5 1092:161094:15 1103:241108:22 1149:201151:16 1209:4 1227:141255:18

developmental 1138:21developments 1066:23devices 1372:22devoted 1226:4dewater 1309:5dewatered 1310:7diagnosed 1154:21212:15

diagram 1192:15diagrams 1372:20dialog 1139:5 1304:4Dianna 1145:8,9Dick 1263:5dictated 1141:1die 1121:5 1156:81162:18

died 1106:11 1121:21128:15,22 1163:71212:13

diesel 1154:13 1218:141218:17

difference 1217:7 1241:91241:13 1308:25 1331:7

differences 1152:2different 1059:201133:23 1161:131179:15 1197:7 1199:61199:7 1201:17 1207:251221:3,21 1239:241243:18 1258:141291:16 1309:3,41323:16 1325:2 1327:21328:24 1331:21,221349:24 1369:5 1373:81373:10 1381:14

differently 1176:191246:12 1378:23

difficult 1069:2 1119:171119:17 1134:201152:12 1202:24

1204:13 1207:8,151260:15 1354:7

difficulties 1120:7difficulty 1054:61230:16

dignity 1205:4dilute 1192:25diminishes 1088:8dire 1344:6direct 1097:19 1103:211104:1 1117:23 1153:221159:14 1232:16

directing 1067:10direction 1055:221123:22 1184:211233:19

directly 1068:3 1116:121130:3 1149:22 1183:221195:13,24 1233:91235:20 1249:22 1263:91266:22 1268:5

director 1049:5 1151:201151:22

directors 1151:14dirt 1101:17 1128:2dirty 1175:22disability 1204:21disabled 1204:20disadvantage 1138:18disagree 1152:4 1286:131347:2 1376:22 1377:15

disappear 1205:101207:9 1212:3

disappointed 1139:12disappointing 1163:6Disappointment 1294:71294:10 1295:23

disaster 1299:24 1347:18disasters 1297:20,21disaster-related 1347:20discharge 1267:221270:16

discharges 1265:11disclose 1109:25 1110:12disclosure 1111:11139:13

disclosures 1284:17discover 1162:8 1164:91230:22

discovered 1110:31121:2 1179:19 1306:7

discovering 1201:6discovery 1234:13,191284:16 1301:181320:19,23

discretion 1230:13discuss 1118:18 1139:171152:2 1205:4 1254:51343:15 1362:1

discussed 1226:221288:21 1289:211312:24 1315:121326:17 1353:101372:17 1382:25

discussing 1140:21306:8

discussion 1056:11061:20 1098:18 1099:11100:23 1162:5 1226:171247:10 1269:181289:25 1347:9,11

discussions 1149:101257:8 1375:8

disease 1061:2 1206:81299:10

diseases 1060:20dishonest 1142:18disingenuous 1139:161142:20

dismal 1078:7dismayed 1088:23disparage 1210:7disposal 1118:1,8,111226:12 1227:121273:24,25 1274:31308:5,8,14,22 1309:231312:5,21 1313:61383:18,19

dispose 1200:17 1201:91257:24 1308:10

disposed 1087:1 1229:10disposing 1227:7disprove 1119:3disregard 1115:231297:13

disrespect 1205:21dissertation 1262:22distance 1123:1 1255:51256:9

distances 1366:15distant 1091:11 1340:6distinct 1130:16



distressed 1065:241205:8

distressing 1078:7distribution 1142:2district 1062:17 1065:31168:20 1171:9 1272:101355:8,11,12

disturbed 1081:171228:11 1229:22

disturbing 1060:4disturbs 1172:12ditch 1059:22diversification 1107:151138:22

Diversity 1049:19divide 1370:15divided 1066:3dividend 1126:1Division 1117:5 1327:8,91327:12,15,18 1328:71330:16 1369:25 1370:11385:13

docket 1344:3Doctor 1373:24document 1086:4 1119:61227:1 1228:3 1237:21267:14,16 1268:2,51272:19,20,21,221285:6 1309:12,131314:15 1320:12,141321:7,10,11,15,16,221322:6 1323:11,22,231332:5 1333:23 1334:31334:7,10 1338:18,221339:2,5,21 1349:5,6,111351:21 1352:2,31377:20 1382:3

documentation 1368:5documented 1057:31058:10 1059:8 1062:81080:7

documents 1051:91227:11 1230:19,231251:12 1261:7,81269:8,10,20 1270:11313:2 1315:13,251316:2,7 1320:201321:1 1332:9 1375:201376:17,18,19 1377:31380:25

DOE 1076:13 1107:4,21

1109:14 1112:10 1166:41196:18,20,23 1223:191273:8

DOE's 1273:20doing 1100:16,171112:10 1131:181153:11 1162:5 1173:81175:15,16,17,181193:3 1197:11 1212:51265:4 1278:16 1280:151287:25 1301:171317:23 1320:211334:16,25 1347:121357:9 1359:15,231360:7,12 1361:181374:9 1386:15

dollar 1122:18 1206:211294:22 1295:161371:15

dollars 1062:12 1111:251121:12 1129:181136:18 1140:111142:13 1195:2 1219:11222:15 1223:23 1345:2

domestic 1092:3,5Don 1073:19donuts 1055:4doom 1135:11doomed 1099:6door 1172:23 1213:181303:15 1321:3

doors 1071:15dose 1113:1 1228:181239:19 1241:3

doses 1060:22 1228:14dosimeters 1143:22DOT 1304:25double 1269:3 1370:9doubt 1148:1Dove 1151:2 1153:231292:16

downcast 1384:6,10downhill 1122:19downstream 1057:16,181059:23 1076:23 1077:31213:24 1220:111354:19

downwind 1059:231095:6 1123:19 1154:241157:14,18 1175:91180:24 1202:4 1367:24

downwinders 1121:9dozen 1162:20 1258:14dozens 1085:18 1230:23Dr 1051:5 1054:171112:21 1195:6 1256:131307:15 1364:3,61373:5 1383:22,231387:3

draft 1228:23drafts 1352:1drank 1229:1draw 1086:2 1217:81365:9

drawing 1198:23 1317:81318:6

drawn 1263:3drink 1072:7 1131:131298:24

drinking 1076:231078:24 1095:11 1215:41298:18,20

drive 1129:20 1142:31146:22 1180:1

driven 1105:16driver 1092:10drivers 1088:8 1200:8drives 1054:13driving 1136:22 1146:51300:17 1367:11

drought 1075:11 1079:251094:25 1177:3 1222:201341:2 1342:3

droughts 1191:24drown 1197:19drum 1210:3drums 1238:20drunk 1113:15dry 1093:21,23 1308:221309:1 1341:9

ducks 1144:21ducted 1366:13due 1059:5 1074:201075:4,17 1077:221094:3 1130:25 1224:241227:9 1248:3 1273:91282:15

dug 1303:5duly 1232:4dump 1101:19 1212:23dumping 1102:1Dunn 1090:23,24

Durango 1049:111081:21 1181:7 1226:11

Durita 1278:17,211279:24 1280:3,8,10

dusk 1367:15dust 1078:17 1085:171095:5 1114:13 1123:211124:9,13 1130:2,3,171132:25 1133:121136:16 1140:6 1142:21147:20 1156:251222:23,24,25 1239:71305:21,22,23 1306:101306:23

dusty 1130:16duties 1122:3duty 1241:7 1242:3dwindle 1211:24Dyar 1137:1,8,8,9,10dying 1180:10 1217:19Dylla 1214:11dynamic 1381:23dynamics 1094:4D-y-l-l-a 1214:3D.C 1166:20déjà 1134:23

EE 1051:1 1052:1 1053:1,1EA 1242:22 1243:2,61252:3

earlier 1141:6 1181:171183:2 1193:19 1283:241291:16 1303:221305:13,17 1373:24,25

early 1092:16 1107:121184:24 1251:22 1253:11265:17,19 1275:51316:15 1343:141377:17

earn 1134:20earthen 1298:12easier 1083:23easily 1104:25 1122:201157:1 1343:9

east 1143:15 1181:81278:15 1279:7,81363:9

Eastern 1091:21easy 1254:13eat 1122:9



eaten 1113:15echelons 1187:22echo 1137:12economic 1063:9 1079:91080:11 1088:7 1103:221104:5,11 1105:191108:22 1109:221121:20 1123:111137:15 1138:4,14,211140:20 1148:171149:20 1158:14,15,161158:19,24 1159:1,41160:13 1165:2,111201:20 1218:4,91225:16,23 1226:51227:14,23,25 1257:131258:1

economical 1091:251092:21 1099:191100:20,21 1257:15

economically 1107:131138:24 1145:23 1205:81219:4 1259:3 1320:6

economics 1201:191293:15 1335:24 1336:1

economies 1079:121107:16 1137:201163:12

economy 1085:151092:25 1104:131113:11 1119:241120:22 1133:3 1148:131150:6 1155:23,23,241156:12 1158:22 1160:31164:14 1299:14,18

ecosystem 1093:11,17,19ecosystems 1079:6Edgar 1178:20 1179:3edge 1257:25 1375:181376:2 1380:1

editorials 1307:24educated 1144:11,24education 1138:61200:13 1209:25

educations 1210:9Edwards 1181:5,6,61303:21 1304:3 1305:8

effect 1171:3 1198:211202:24 1218:2 1220:51220:6 1236:4 1237:81304:24 1329:3 1331:20

1359:21 1383:25effective 1061:6 1117:171160:11 1353:141355:13

effectively 1123:71142:1

effects 1058:9 1060:241061:5 1074:7 1079:31094:5 1096:21,241176:10 1178:18,241179:22 1225:17,20,231226:10 1227:2 1231:7

effluent 1270:3,121298:16

effort 1060:18 1069:51105:14 1197:25 1228:21271:1,3 1291:171360:24 1376:13 1377:6

efforts 1067:10 1106:211107:15 1121:161125:15

EFPH 1284:9 1309:121318:13 1321:6 1329:231335:2 1338:18 1344:51348:25 1354:14 1361:7

EF's 1227:18eggs 1218:4egg-layers 1155:8Egidi 1119:5,10,131306:12

Egnar 1151:2EIA 1116:15 1120:101195:13,18 1220:201225:14 1226:1 1227:191228:8,11,12 1230:191230:21,24 1231:31243:7 1251:2 1286:211287:22 1288:5,181289:10,17 1373:81375:10 1380:23

EIAs 1185:2eight 1101:12 1155:181269:8

EIS 1196:21 1281:131282:3 1284:5 1285:231286:9,17,21 1287:141287:21 1373:101379:13

EISs 1197:4 1287:25either 1056:19 1064:161090:20 1107:17

1110:14 1145:181167:19 1200:23,241202:19 1206:1 1207:81217:4 1221:8 1223:211226:20,25 1248:251278:20 1298:3 1309:41353:6 1363:17 1370:7

elbow 1177:8elders 1165:1elected 1162:3electric 1188:14electrical 1070:4,4electrician 1153:2electricians 1180:13electronically 1214:14element 1147:22elementary 1207:24elephant 1067:3eliminate 1318:7eliminated 1254:15,221279:2 1282:15 1283:181284:1,4

eliminating 1283:12eloquent 1136:8else's 1234:22eludes 1080:24 1082:20emanate 1136:23embroiled 1361:17emergencies 1381:4,15emergency 1242:71380:22,24 1381:2,101381:12,19 1382:8

emerging 1138:7,20emission 1372:14emissions 1068:3,71107:6 1194:4,4 1288:71303:1 1328:13 1369:51372:8,9,10,11,13,18,211372:23 1385:14

emitted 1237:11,13,181237:23 1238:4,17

emitter 1238:24emitters 1239:3,8emitting 1140:4emphasis 1067:10emphasize 1156:7employed 1388:13employee 1152:251228:18 1232:11

employees 1071:111088:25 1089:5 1102:18

1155:17 1159:151173:23 1177:131228:14 1263:3,51300:15,20 1371:4

employers 1102:18employment 1089:91141:2 1155:14 1207:10

en 1071:21enables 1092:19enabling 1129:8encounter 1239:13encountering 1239:231239:24

encourage 1211:19encouraged 1229:20encourages 1088:9encouraging 1295:14Endangered 1354:18ended 1070:25 1115:241181:24 1332:21

Enders 1207:6endocrine 1154:4ends 1233:10energies 1201:25energy 1048:5 1049:4,71049:10 1051:9 1056:201058:1 1059:1 1060:4,61061:10,16 1066:12,241067:9 1068:4 1069:111069:17 1071:4,5,121072:24 1073:121074:25 1076:3 1083:121083:13,14 1084:151086:10 1087:3 1088:31089:6,18 1091:6,10,161092:2 1093:1 1094:91094:11,18 1095:2,131097:3,4,10 1098:4,7,111100:15,18,20,21,221102:9 1103:2,3,41104:9 1113:6 1115:31116:15 1118:5,181119:14 1122:5,101123:24 1124:151126:20 1131:9 1136:121136:13 1139:12,191140:13 1141:21 1142:41142:18 1144:2,4,251146:8 1154:20 1159:61159:17 1160:9 1168:61169:2,6,23 1176:15,18



1177:19 1178:6,111179:10 1189:9,161190:24 1198:1 1200:231200:23 1202:2 1203:221209:1 1210:24 1223:201224:12 1225:13,241227:4,24 1228:2,4,81232:11,24 1233:251235:10,20 1237:18,211245:4 1246:1 1247:61248:6 1250:4,201251:24 1253:11,171261:20 1262:16,231263:2,17,20 1264:6,171269:20 1273:15 1283:31288:21 1297:1,131299:16 1300:5 1306:181306:19 1308:4 1313:71313:11,18,23 1314:181320:18,23 1321:7,9,111322:25 1323:19 1324:61324:11 1325:251329:21 1344:25 1346:61346:12,16,20,241347:8,24 1348:13,141352:16 1358:15 1362:31362:6,6,19 1379:14

Energy's 1132:10enforce 1158:1 1185:17enforced 1185:181187:14 1197:9

enforcement 1070:131125:3 1158:11 1161:211167:8 1224:21

enforcers 1166:8enforcing 1186:1engage 1058:19engaged 1353:12engine 1303:2engineer 1136:18 1235:21271:16 1275:121332:13

engineering 1136:211266:16 1315:131316:12 1335:101350:19,20,24 1351:71351:22

engineers 1217:241343:21 1350:11

engines 1366:23English-speaking

1186:12enhance 1088:4enigma 1198:22enjoy 1129:17enjoys 1151:1enlightened 1220:6enrich 1183:21ensure 1078:14 1089:91103:13 1116:8

enter 1326:6entered 1284:17 1355:20enterprise 1059:91097:22 1102:4 1141:11141:3 1159:4 1188:6

enterprises 1157:13entire 1092:20 1184:11212:3 1285:24 1305:101330:12 1349:7 1380:11

entirely 1066:7 1138:121139:25 1157:2 1275:6

entirety 1064:16entities 1292:2entitled 1055:10 1136:5entity 1287:17entourage 1182:3entrenched 1069:2environment 1049:241057:7 1059:25 1062:51062:25 1063:3 1064:81064:17 1070:14 1071:51077:16 1079:2 1080:31089:23,25 1091:5,151095:16 1096:10,111100:23 1101:2,10,241103:16 1109:161113:10 1116:9,251117:14 1120:9,21,241121:24 1148:20 1154:11158:1 1160:4 1161:151162:10 1165:231166:10,11 1189:151198:2 1208:23 1216:131220:13 1269:211278:13 1291:19 1312:71319:13 1349:15 1350:51350:8

environmental 1049:191051:10 1063:101067:25 1069:6 1080:101105:19 1116:3,7,11,181117:17 1126:7,11

1129:11 1153:171156:14,17,20 1158:231160:6 1165:15 1166:131166:17 1184:24,251185:1 1189:10 1193:151197:22 1219:151220:19 1225:13,16,201225:24 1226:8 1229:121229:14 1230:18 1231:61235:6 1251:2,9,18,201251:24 1252:6,71254:14,20 1255:111256:1 1259:22,241260:12,17,21,241261:3,21 1262:3,6,91272:11,22,23 1283:191284:2 1286:17 1287:91289:13,19 1308:171312:6,11,12,181313:12,16,24 1314:2,41314:10,12 1326:121335:6,7 1337:13,141339:15 1340:121342:18 1349:201360:18 1365:1 1369:71374:1,9,11 1375:2,171375:19 1376:3,241377:4 1378:21 1379:21379:4,6,11,12,161380:15 1383:24

environments 1138:1Environment's 1065:6envy 1145:2EPA 1086:17 1098:6,181098:21 1166:3,201205:11 1288:6,101305:25 1309:3 1310:121311:19 1353:161356:21

episodes 1130:2equally 1229:8equate 1135:8 1219:22equation 1113:20equestrian 1293:16,181294:5,8,17,21

equestrians 1295:13,14equipment 1070:2,3,41142:9,15,25 1200:161200:17 1382:12

equivalent 1330:1ER 1230:21,24 1231:3

1243:7,8,12,14,191253:10 1254:251289:17 1373:7 1374:11374:15 1375:131376:10 1380:23

era 1147:14erect 1072:24Eric 1204:6Ernie 1151:23erring 1142:6erroneous 1228:22erroneously 1088:91228:19

error 1321:24errors 1228:11 1352:4escape 1306:24 1307:4especially 1059:151075:11 1087:4 1120:101162:18 1172:2 1181:101191:23 1203:9 1299:71299:18 1366:9 1367:31367:15 1375:201382:10

Esq 1049:2,3,5,9,12,16,21essentially 1067:131076:23 1139:151378:21

establish 1057:111058:17 1282:1 1381:11

established 1058:211126:24

estate 1110:4,13 1226:101226:13 1227:221292:15

Estates 1215:2estimate 1051:251074:19 1104:1 1159:211262:8 1282:9 1344:251345:6,9,21,23 1346:71346:12,16,17,21,251347:8,10,12,12,19,211347:25 1348:19,201349:2,8,9,24 1350:121350:16,17 1351:31365:2 1366:8 1368:211369:3,5,8,9 1370:21372:9

estimated 1074:181225:3 1348:4 1369:191370:23

estimates 1348:9 1351:8



1351:8,19estimating 1224:13Esty 1123:13,14,15et 1096:9,12 1099:231100:19,19 1136:171180:15 1181:13,131185:2,2,21 1189:131194:6 1198:1 1305:1,1

eternal 1119:22Ethington 1178:201179:3

Europe 1173:12 1294:14evacuated 1123:6evaluate 1255:8 1277:51385:13

evaluated 1117:101255:1 1289:22 1290:31314:9 1328:22 1338:3

evaluating 1376:2evaluation 1342:17evaporation 1076:21080:2 1124:6 1310:131345:17 1353:7 1383:91383:12

evening 1367:16event 1122:18 1126:161157:9,10 1293:17,251294:19 1295:12

events 1122:23 1343:5eventually 1054:141076:21 1298:4 1370:51375:10

everybody 1054:5,221139:23 1171:4 1180:31202:8 1204:8 1205:21206:12 1207:14,161234:22 1384:2

everybody's 1053:211100:24 1102:2,31260:25

everyone's 1073:241344:22

evidence 1053:121078:19 1113:241170:20 1220:3 1228:91231:16 1241:221269:14

evident 1161:24evolving 1098:14,15ex 1286:22exacerbate 1087:17

exacerbated 1230:17exact 1202:23 1237:11313:25 1355:23 1365:4

exactly 1083:8 1167:181179:2 1190:12 1221:141236:5,8 1368:23

examination 1184:3examine 1068:23 1113:61322:9

examined 1125:101232:5 1291:16

example 1078:1 1196:241199:11,14 1238:71254:21 1266:20 1288:61299:9 1365:12 1375:25

examples 1116:171187:15 1192:7 1228:211335:16

excavated 1274:3excavation 1128:7exceed 1122:20 1320:10exceedances 1265:15,191265:21 1270:7

excellence 1140:14excellent 1191:1exceptional 1138:23excerpt 1051:10 1272:23excessive 1079:22exchange 1126:3 1155:191363:3

exchanges 1051:111200:25 1201:14

Excuse 1256:13 1310:241365:18 1374:22 1380:6

executive 1151:20,21exempt 1068:2,7 1115:18exempted 1099:11,13exemption 1286:16,22exercise 1054:13exercises 1381:20,25exhaust 1153:5exhibit 1051:8,9,10,11,131051:15,17,19,21,22,241052:3,5 1247:2,41267:6,11,12 1272:8,121284:8,11,18 1309:121309:20 1318:14,161326:7,10 1329:241333:16 1334:22 1335:41338:20 1349:1 1354:151361:8

exhibits 1051:7 1052:21295:13

exist 1108:3 1134:21141:19 1153:181178:23 1278:9

existed 1141:15 1251:21existence 1158:21 1159:81315:23

existing 1072:22 1076:121078:12 1136:15 1158:11158:5

exists 1085:15 1179:20expand 1258:21 1280:11313:15 1322:2 1325:141326:21,24 1337:21

expanded 1259:3,9expansion 1304:6,241326:17 1335:12

expect 1149:21 1178:51211:23 1368:161384:10,14

expectation 1122:13expected 1102:251121:17 1169:24

expense 1169:1 1383:4expenses 1169:3expensive 1126:71188:13,14 1287:211347:14 1349:16

experience 1105:61111:13 1130:2 1144:111161:3 1181:19 1184:81190:7 1195:23 1209:191216:16,24 1224:81228:13 1244:23 1245:11256:19 1262:17,20,241263:2 1264:3,4,61266:15,18,22 1281:31349:20 1351:14,181358:6 1360:18

experienced 1124:121128:22 1217:241299:17 1366:171385:10

experiences 1217:81220:23

experimenting 1107:21expert 1143:7,24 1221:71314:3 1332:18,191337:12

expertise 1074:1 1122:2

1138:7 1281:24 1306:18experts 1084:14 1095:191100:8,9 1139:191145:3 1216:21 1306:19

expires 1079:19 1388:18explain 1209:20 1286:141359:11

explained 1111:211114:20 1239:14,171359:9

explaining 1171:51240:2

explanation 1256:141314:1

exploding 1298:10,11exploring 1259:12exposed 1058:6 1164:211179:25 1203:1,9,101204:4 1215:4 1217:181241:20

exposure 1096:22,241112:25 1113:16,231121:3 1143:23 1165:91217:20 1240:3,6,101302:19,21

exposures 1108:171240:23

express 1064:24 1169:131210:1 1327:25 1378:13

expressed 1065:131127:12 1129:3 1137:121169:14 1227:3 1362:22

expresses 1329:25extend 1088:5 1130:19extensive 1079:251155:16 1224:8 1349:201351:14

extent 1220:17 1235:1,51311:12 1326:191358:14 1364:24

external 1138:8extinguishers 1382:12extracted 1147:251214:19 1221:20

extraction 1079:81151:16 1201:23

extraordinarily 1068:151252:17

extreme 1079:25extremely 1085:241154:16



eye 1115:1 1301:8E-mail 1051:11,15,16,191052:5 1130:8,141178:4 1180:22 1225:151305:2 1306:8 1318:171318:23 1329:11,141330:13 1331:19,241332:2 1361:6 1363:31376:7 1385:19

E-mailed 1130:8E-mails 1051:20 1052:6

Ffabric 1066:5fabulous 1132:21face 1100:14 1144:81272:14 1303:101371:11 1384:11

facilitate 1310:7 1317:2facilities 1078:11 1103:11103:10 1227:24 1273:11374:21

facility 1065:1 1066:81068:18 1069:12,131087:1,15 1118:81248:17 1253:17,191264:15 1266:24 1273:21273:2,7 1274:7,7,9,151275:4,12 1281:71282:7 1345:10 1349:71349:21 1365:17,171372:17 1374:231381:20,22 1382:51384:7

facility's 1273:10fact 1065:24 1066:131076:4 1096:22 1133:251146:14 1149:13,211151:11 1161:8,18,211161:24 1162:5,7,131163:22 1165:221168:11 1169:10 1170:31211:20 1219:141230:18 1250:101259:11 1266:21,251268:4 1286:10 1287:241294:25 1295:20 1301:51325:1 1331:23 1336:11338:21 1384:14

factor 1370:16factories 1180:6

factors 1094:17facts 1121:23,25FAEGRE 1049:2fail 1090:4failed 1062:10 1080:81107:23 1122:3 1195:171199:8 1228:15,24

failing 1148:15fails 1062:5failure 1057:12,15,211059:6 1067:18

failures 1057:13 1274:131274:17 1346:18

fair 1143:19fairly 1053:13 1076:181149:9 1150:24 1202:111263:14 1359:181385:22

fall 1124:12 1144:71147:5 1212:20 1221:17

falls 1200:5,6false 1229:12 1261:20fame 1182:1familiar 1272:20 1274:231308:23 1320:13 1322:71339:1 1340:20 1363:10

families 1147:3 1148:81149:18 1201:111210:17 1212:3

family 1110:2 1127:231127:25 1133:19 1162:11163:4 1205:6 1211:141212:12 1220:2

family's 1133:16fancy 1291:2far 1060:22 1091:111093:17 1096:211097:12,15,15 1102:91114:17 1129:111130:19,24 1148:51156:24 1159:181207:18 1222:16 1225:81226:14 1233:6 1236:61237:3 1241:3,131242:16 1249:22 1254:21263:25 1277:131278:17 1292:10 1300:21301:20 1318:5 1326:21326:22 1329:8 1330:141331:9 1334:19 1342:221344:6 1353:9 1361:4

1364:8 1365:16 1366:191367:6 1369:23 1375:111375:23 1378:3 1379:21380:20 1382:3

farm 1154:23 1155:10,151155:19 1156:8,161158:16 1160:2 1163:251164:1 1211:7

farmers 1154:22 1155:51155:17 1156:3 1215:20

farming 1133:18 1138:31163:18,22,22 1211:121211:16 1226:20,20

farmland 1073:5 1300:1farms 1072:24 1079:51100:19,19 1211:14

farther 1082:15far-reaching 1131:1fast 1215:17 1324:14,15faster 1082:7,7fatal 1290:2,2father 1128:3,22father's 1127:24fault 1072:11 1222:181275:22

faultily 1077:5faulty 1076:12favor 1136:1 1163:131310:8

favorable 1089:6fear 1144:9 1183:191213:8 1215:8

fears 1136:15feasibility 1218:111343:13

feasible 1219:4fed 1153:10federal 1068:2,7 1077:241086:17 1099:12,131103:12 1115:8,17,191116:5 1165:22 1168:131189:24 1197:15 1273:31273:11 1280:18,201281:4,11,13,21 1282:71282:10 1286:18,201287:2,6,21 1288:181340:8 1352:12 1353:181353:23 1355:161356:23 1357:11,151358:5 1360:22 1385:12

federally 1280:24

feed 1079:22 1193:2,31248:8,24 1249:161293:23 1305:6 1352:11

feeder 1191:20feeding 1264:24feedstock 1086:251118:4

feedstocks 1087:4feel 1064:5,10,25 1065:71065:9,12 1068:10,141097:13,20 1105:21117:11 1131:8 1139:151140:9,16 1162:251163:8,14 1179:11212:7 1213:7 1217:31224:20 1225:211280:21 1291:8,10,121378:5,14,16 1382:2

feeling 1058:15 1066:31180:3 1297:22

feelings 1098:24feet 1137:23 1142:7,9,121192:3,4,14 1366:12

Felice 1215:1felt 1065:4 1098:111195:14 1273:22 1275:71275:13 1279:24 1282:3

female 1143:14 1202:81202:10,21

fence 1193:18 1240:9fertile 1214:23 1215:15fertility 1061:5festivals 1294:20fetch 1130:4,5fewer 1063:7fickle 1207:1field 1095:19 1187:6,19fifth 1147:3,17 1150:14fight 1136:18 1211:6fighting 1211:6figure 1073:8 1101:241144:4,7,22,22,241145:2,4 1150:101174:14 1175:121192:10 1231:151331:11 1337:2

figures 1218:24figuring 1145:1Filas 1051:4,4,5,12,16,191051:21,23 1052:51176:17,23 1231:22



1232:3,8 1242:241243:5 1266:22 1267:161269:11 1272:151290:15 1300:9 1305:181306:22 1307:11 1308:31309:14 1322:6 1327:221332:1 1335:7 1339:8

file 1054:1 1267:141321:5 1326:23

filed 1168:19files 1321:4 1350:22filibuster 1135:25filing 1335:9fill 1128:2 1270:181302:17 1303:161373:19

filling 1195:17 1352:6film 1177:11 1296:251297:1

filter 1330:1 1331:8,8final 1063:15 1068:111071:21 1083:181088:22 1091:171233:11 1306:141311:14 1316:14,231317:4 1351:21

finalizes 1231:1finally 1071:2 1082:201125:22 1153:8 1178:41386:12

finance 1325:22financial 1056:201057:20 1062:3 1104:51105:20 1107:111114:18,23 1236:81274:12,16

Financially 1126:4find 1092:2 1100:111167:19 1178:221179:24 1180:241206:19 1216:3 1221:131242:20 1302:12 1381:11386:11

finding 1145:5 1146:8findings 1091:4fine 1055:25 1061:21127:6 1146:11 1150:61256:2 1275:8 1364:17

fines 1069:23fingers 1120:14fining 1154:12

finish 1109:6finished 1090:22fire 1179:13 1346:7,131382:6,12,13,16

fired 1205:15firm 1365:25firms 1108:10first 1049:22 1054:61060:4 1062:3 1073:181074:8 1095:23 1114:151115:7 1120:22 1125:11128:13 1130:151137:18 1141:24 1163:51169:9 1173:11 1176:161177:19 1178:12,181186:21 1188:3 1210:191211:21 1221:131225:11 1229:8,241235:22 1267:181269:16 1272:171290:11 1296:23 1380:11380:2,4,5 1382:22

fish 1052:3 1302:81354:9,19 1356:11,221358:5

fishing 1226:23 1302:10fit 1169:22five 1082:14 1125:191134:18 1190:25 1191:41191:7 1217:1 1218:171218:20 1282:9,121343:8 1347:16 1369:141380:17,19 1386:9

five-year 1345:16,191347:6

fix 1177:3 1319:6fixed 1105:12 1176:24flagged 1285:14flagship 1300:6,8flammability 1382:11flash 1140:19,24flat 1144:7flatly 1297:8Flats 1112:24flaw 1067:7 1290:2,2flawed 1058:24 1060:51068:10 1069:1

flaws 1066:20 1216:14fleshed 1381:24flew 1181:25 1186:5flight 1179:14 1186:8

floating 1165:25flood 1216:25flooded 1192:20 1270:21flooding 1122:25floodplain 1273:10Floor 1049:22Florida 1181:9flow 1076:21 1372:20flowing 1355:1flu 1061:3fluctuate 1114:2fluids 1330:2flume 1277:2,8fly 1302:8flying 1139:21 1179:121182:2,11

focus 1066:16 1067:141247:6 1330:17

focused 1198:15folks 1056:10 1093:241101:2,8 1108:7,11,131108:20 1109:201134:19 1135:6 1136:31151:9 1172:20 1198:71216:2 1239:14 1240:191276:6 1315:14 1327:201351:7 1381:8

follow 1088:21 1129:61232:9 1372:19 1375:191378:11,19

followed 1158:141376:25 1377:24 1378:2

following 1094:141107:10 1115:20

follows 1062:21 1232:5food 1150:12 1155:19,211155:24 1156:2,61157:9 1160:7 1162:101164:2,4 1174:231185:10 1208:12

foot 1157:21footprint 1082:2 1150:17Force 1181:25 1204:15forced 1150:21 1379:18forcefully 1060:18forces 1152:3Ford 1302:25foregoing 1388:10foreign 1061:8foreigner 1131:9foremost 1095:15

foreseeable 1324:231325:1 1342:5

forest 1205:23forests 1205:13forever 1075:22 1076:241077:3 1123:7 1148:241175:18 1183:251205:10 1216:1 1227:101300:2 1344:14

forget 1187:3 1205:3form 1140:4 1192:241201:17 1388:10

formaldehyde 1060:21format 1054:4,101055:24 1375:9 1378:11

formation 1239:25formatted 1374:181378:23,24

former 1106:14 1107:191108:4 1152:25 1217:231263:3 1300:15

forms 1140:2 1192:241226:24

formula 1064:11 1114:201114:21

formulas 1064:5formulation 1375:13forth 1116:14 1134:221352:2 1373:22 1388:9

Fortunately 1207:24forward 1056:10 1073:151092:12 1095:21 1103:61108:8 1184:20 1223:111224:1 1269:9 1282:31292:24,24 1319:161325:22 1326:3 1342:191362:17,20 1374:191377:12

fossil 1134:1fought 1094:23 1216:71229:18

found 1105:16 1109:71134:19 1135:19 1156:91157:1 1158:22 1161:11162:9 1163:20 1164:121179:6 1181:9 1185:241185:24 1197:4 1215:151223:15 1228:24 1294:11369:11

foundation 1128:21160:13 1350:4



four 1082:25 1086:81092:3 1094:16 1124:141125:19 1131:8 1132:21150:22 1153:7 1170:231174:9,9 1253:11293:17 1342:6 1358:21387:6

fourth 1147:3,16 1150:141340:5 1341:19

fracking 1060:11fraction 1071:13 1075:5framed 1226:17Frank 1051:4,12,16,19,211051:23 1052:5 1176:171176:23 1231:22 1232:31309:14 1335:6 1339:8

frankly 1195:10fraught 1069:2free 1102:4 1150:71179:24

Freedom 1306:8frequently 1069:211115:2,6 1302:41324:12

fresh 1155:13 1330:2freshly 1154:25Friday 1126:4 1184:1friend 1300:21friends 1055:21 1066:11089:5 1217:18 1302:13

frightened 1165:6,8front 1055:14 1134:241136:11,19 1173:221185:19 1296:24 1297:71326:15 1327:3,111328:25

fruit 1067:13Fruita 1293:24fruition 1235:3,8frustrated 1065:5frustration 1187:81196:6,7

fuel 1100:22 1301:101305:5

fuels 1048:5 1049:4,71051:9 1056:20 1058:11059:1 1060:4,61061:17 1066:12,241067:9 1069:11,171071:4,5,12 1073:121074:25 1076:3 1083:12

1083:13,14 1084:151086:10 1087:3 1088:31089:6,18 1091:6,10,161094:18 1095:2,131097:3,4,11 1098:4,111100:15 1102:9 1103:51104:9 1113:6 1115:31116:15 1118:5,191119:14 1122:5,111123:24 1124:151126:21 1136:12,131139:12,19 1140:131141:21 1142:4,191144:25 1154:201159:17 1160:9 1168:61169:2,6,23 1176:15,181177:19 1178:6,111179:10 1189:9,161190:24 1198:1 1200:231203:22 1210:241224:12 1225:13,241227:4,24 1228:3,4,81229:6 1232:12,241234:1 1235:10,201237:19,22 1245:41246:1 1247:6 1248:61248:16 1250:4,211251:24 1253:11,171261:21 1262:16,231263:2,17,20 1264:6,171269:20 1283:3 1288:211297:1,13 1299:161300:5 1306:18,191308:4 1313:7,12,19,231314:18 1320:18,231321:7,9,11 1322:251323:20 1324:6,111325:25 1329:221344:25 1346:6,12,161346:20,24 1347:8,241348:13,14 1358:151362:3,6,7,19 1379:14

fugitive 1140:6 1142:2Fukushima 1123:11188:17 1298:8

fulfill 1376:20full 1118:22 1180:221220:16 1306:241345:14,24 1347:4,131349:17 1382:4

fully 1065:18 1090:1

1220:18 1277:9 1338:3full-blown 1230:3full-time 1061:231089:14 1155:17

functioning 1070:2fundamental 1241:13fundamentally 1309:3funded 1229:11,161273:11

funding 1273:3 1361:15furniture 1137:17further 1090:3 1094:11103:18 1126:191176:12 1254:11 1290:31295:9 1356:6 1363:191363:23 1388:7,12

Furthermore 1078:8future 1071:10 1073:21084:17 1088:2 1094:221095:7 1102:6,91106:25 1135:11 1141:71155:17 1179:18 1191:91191:24 1197:181208:18,24 1217:101221:1 1226:14 1227:81292:1 1294:23 1303:101322:2 1324:18 1325:211334:21 1335:121339:12,19 1361:191370:3

futures 1221:4

GG 1053:1gain 1132:18gained 1100:4 1132:211133:13

gains 1158:14gallon 1218:14,14gallons 1074:12,13,191075:8 1079:23 1177:41190:22 1225:3 1298:151383:10

game 1230:14 1344:17gamma 1199:6Gamma-Scout 1302:3garden 1059:22garner 1142:13Gary 1233:20,22 1234:2gas 1060:9 1151:191187:7 1196:9 1197:1,6

1200:10 1218:13,16Gateway 1111:20,20,221212:25

gathered 1098:16GCL 1353:4general 1049:21,221206:6 1246:21 1249:211251:3,4 1374:9,141376:25 1381:15

generalist 1244:5generally 1274:9 1281:71338:2 1356:3 1377:231380:18

generate 1142:7generated 1104:131118:9 1305:22,231366:8

generation 1147:3,16,171208:9

generational 1147:11149:19 1183:24

generations 1137:181141:11 1208:19,241215:20 1221:1

genetic 1175:24 1176:3,41176:7,10

gentleman 1135:201141:5 1173:21 1181:171291:15

gentleman's 1137:3gentlemen 1096:61102:12 1141:9

geological 1222:18geologist 1114:201128:14,17

geologists 1128:12George 1233:16,181257:4 1263:16 1279:211297:2,6

George's 1280:9Germany 1294:13getting 1098:9 1133:111191:18 1211:17 1232:91265:17 1275:21 1296:41303:25 1334:17 1345:41353:19 1358:3,31359:20 1377:14

ghost 1133:2 1213:1GI 1154:4giant 1180:1gift 1174:21



give 1058:14 1169:121173:10 1190:5 1191:81191:9 1198:24 1208:191231:9 1256:14 1259:51274:14 1329:22 1365:31368:21 1373:18

given 1053:23 1056:231057:2 1087:23 1096:221097:4 1116:1 1119:251120:3 1161:8 1162:21201:19 1323:15 1351:31364:8 1377:11

gives 1145:20 1170:251204:23

giving 1090:21 1100:71173:9 1291:24,251292:1

glaring 1377:20Glasier 1233:16 1257:41263:16,19 1279:211297:3,7

global 1094:9Glynn 1296:15,18,181297:18 1300:12

go 1053:2 1054:231056:12,25 1070:71071:25 1072:5,151074:23 1082:151083:24 1084:17 1090:51095:21 1099:151100:17 1101:20,211109:11 1124:251127:18 1145:181167:25 1171:3,171182:7 1184:7 1185:151186:4 1188:23 1191:201195:15 1197:21 1200:41202:20,21,21 1207:21207:12 1208:6 1209:151209:19 1211:1 1212:181214:12 1221:161222:17 1224:101229:15 1243:4,121251:13 1260:23 1261:31272:15 1282:101284:23 1291:4 1293:201296:16 1298:3,41299:17 1301:9,101302:7 1309:4 1310:101311:10,13 1312:171315:15 1317:22 1323:3

1324:8 1326:6 1329:171332:8 1333:18 1357:61362:17,20 1365:171372:19 1374:181376:23 1377:12 1378:81379:14,20,21 1383:71386:14,15

Goad 1049:21 1324:31387:7,8

goal 1241:1goals 1240:24goats 1155:8God 1207:19 1212:11303:9

goes 1063:20 1072:7,121096:8 1098:16 1114:171168:21 1187:101192:13,16 1248:151321:22 1341:4

gofer 1106:10going 1053:6,9,111055:11,12,21 1056:121066:10,12 1068:13,241077:10 1081:2 1082:91082:10,15 1093:19,201094:5 1097:2,201098:1,22 1100:1,2,251101:1,9,19,21,221102:8,10,22 1110:81120:14 1132:19 1135:71135:8,16,17,251144:23 1146:5 1152:41152:13 1161:13,14,141163:6,23,25 1164:3,91171:12 1177:11 1183:11183:3,11,16,19,241184:11,12 1185:131186:9,25 1187:151188:11,23 1189:181190:21 1191:3,121195:9 1197:14,181200:13,14,21 1201:151202:15 1204:111209:20 1210:20 1213:61215:25 1218:19 1219:81219:18 1220:181221:15 1222:13,191223:2,3,4,5,12,131225:12 1231:16,251235:21,23 1236:6,121237:22 1247:6 1249:4

1249:17 1251:13 1261:51261:7,20 1266:13,151266:19 1288:9 1289:11289:7 1290:13 1292:51292:6,7,8,11,12,13,141292:17,19 1293:8,91294:7 1295:6 1297:91297:11 1301:1,241302:10,12 1303:81315:7,9,15,21,22,231316:3,6 1319:161325:12 1326:3,81335:25 1344:7 1353:61360:24 1362:17,201363:5 1364:13 1365:231367:13 1368:25 1371:51371:11,18 1381:191384:12 1386:10

goings-on 1135:13goings-ons 1135:12gold 1081:13 1194:191214:17

Golder 1074:11,171075:1

good 1056:18 1059:131060:3 1061:22 1064:221073:22 1080:191090:24 1102:121104:10 1123:141126:14 1129:181134:15,15 1135:18,231139:4 1144:9 1146:221148:19 1149:4 1150:81163:22 1168:101175:10 1186:8 1187:181187:19 1189:171195:14 1196:4 1197:161207:14 1219:24 1232:81275:19 1289:2 1290:41292:6,8 1308:31330:24 1332:12 1344:91375:10 1382:22

goods 1150:1 1219:6Google 1180:23gotta 1221:15gotten 1069:5 1097:121183:13 1184:13

government 1061:12,141105:9 1115:8 1121:131154:11 1159:141165:22 1187:17

1197:15 1216:5 1273:111275:5 1297:10 1378:21379:9

government's 1105:13grab 1329:13grade 1067:11 1084:201092:20 1140:10 1246:91247:16,18,20,21

graduated 1105:231148:9,10

graduating 1207:9grained 1256:2Grand 1093:3 1094:201102:15 1103:22 1105:81105:22,24 1106:61107:6 1108:5,91109:23 1110:1,9,221112:3,6 1119:121127:7,21 1134:201136:9 1147:14 1148:141159:20 1201:191204:14,17 1293:241295:5

grandchildren 1134:91148:6,19 1151:121208:11

grandfather 1147:7,9grandkids 1073:7grandma 1180:4grandmother 1202:7granola 1155:14granted 1057:5 1059:11193:22 1300:22

granting 1058:121061:24

Grants 1214:21grass-fed 1155:7grateful 1065:7graupel 1130:16gravely 1079:2graze 1155:7great 1067:7 1091:13,141104:5 1113:5 1114:231135:7 1136:6 1140:251141:3 1147:7 1211:121219:7 1305:20 1368:7

greater 1065:13 1091:231130:20

greatest 1365:23greatly 1076:19 1210:61226:5



greed 1205:21green 1150:10 1151:41224:2

grew 1065:23 1105:71207:22

grinding 1141:7gross 1107:24grossly 1162:10Grossman 1050:2 1051:51054:17 1256:13 1364:31364:6 1373:5 1383:221383:23 1387:3

Grossman's 1307:15ground 1101:16,181134:11,13 1139:11142:7 1147:24 1158:71159:11 1181:221185:23 1187:10,211193:12 1277:23 1301:31303:5 1366:12,14

grounds 1143:19groundwater 1057:3,81057:16 1059:4 1076:11076:20 1091:9,221132:9 1135:23 1159:231225:4,6 1277:2,8,191340:2,6 1341:9,11,121341:14,15,17,211343:5 1346:22 1355:5

group 1048:1 1055:71151:16 1227:201228:10 1229:181350:19,20 1351:231369:4

groups 1065:17 1213:71220:20 1381:11 1386:1

grow 1152:13 1155:51156:6,9 1157:9 1160:7

growing 1085:141101:22 1105:221108:12 1127:21 1138:41155:24

grown 1154:25 1155:11156:2 1164:5

growth 1088:20 1138:141227:8

guarantee 1058:131095:10 1218:8 1236:1

guaranties 1178:16guess 1101:21 1102:101136:5 1168:1 1189:10

1190:18 1193:211194:17 1196:16 1211:31241:12,23 1244:101255:1 1259:7 1269:61271:23 1284:12,211304:8 1316:4 1327:11333:7,18 1340:51344:23 1347:171363:17 1368:6 1376:6

guest 1219:21guidance 1373:15 1374:11374:4,8,9,11,12,14,201376:25 1377:24 1378:11378:18,19

guide 1129:14,231181:12

guided 1207:17 1234:24guidelines 1324:221378:3,7

gullies 1193:2,2guy 1182:13 1291:21359:12

guys 1101:18,25 1153:101153:13,13 1154:12,161182:13 1186:11 1192:91196:3 1203:7,9 1365:61365:7 1377:7 1386:13

guy's 1187:9Gyp 1153:1G-l-y-n-n 1296:18

HH 1049:5habitat 1150:13haired 1204:25half 1062:6 1214:181226:1 1228:21 1229:71258:14 1280:111307:17

halfway 1222:21half-century 1079:1half-life 1141:12 1157:6Hall 1139:18halt 1246:2,5hand 1056:5 1127:91139:24 1158:9 1297:16

handed 1180:22 1378:7handle 1193:24 1238:201241:25 1357:1

handled 1355:25handling 1113:22

1235:19handout 1159:14hands 1158:8 1182:121300:7

handwriting 1073:21Hanford 1121:15 1202:51202:11

hanging 1067:131302:12

happen 1082:25 1122:231152:14 1165:24 1178:11185:3,7 1188:201200:15,21 1202:151212:6 1215:9 1224:131224:14 1295:221297:11 1329:7

happened 1067:231096:7 1099:8 1123:21135:10 1144:13 1154:61297:21 1298:8

happening 1099:2,91150:17 1186:7 1203:131300:16 1360:22

happens 1068:201180:16 1182:17 1193:11203:2 1223:2 1299:181326:5 1386:8

happy 1137:13 1152:81171:4 1180:3 1181:1

hard 1114:21 1129:61133:2,4 1135:141188:12 1203:17 1206:11206:16,17,21 1211:71222:7 1223:10 1226:21286:23 1292:23,241320:9 1357:19,22,241381:1

hardener 1146:6harder 1222:11harm 1061:19 1091:71104:25 1185:3 1208:23

harmed 1061:19 1091:91175:7

harming 1091:14,15harmless 1174:15Harrison 1301:14,14,151301:16,16 1303:17

Harvey 1051:15hat 1081:20 1144:25haul 1292:19 1370:21haulage 1369:17

hauled 1353:1Hawse 1129:5,6hay 1155:11 1213:51294:2,2 1295:11

hazard 1237:11,15,19,241238:1,5,10,12,13,15,161238:18,24 1239:111241:24

hazardous 1071:171077:21 1078:1,20,221079:15 1210:4 1219:191220:4 1240:18 1242:4

hazards 1239:1,231241:5,8,10,10,11,14,161242:19,21

hazmat 1200:8,9,10,15head 1144:8 1179:101214:10,11 1350:23

heading 1257:21heads 1119:18 1142:211168:1 1303:8

Headwaters 1201:19Head-Dylla 1213:21,231213:24 1214:2,9,10,131214:16

healing 1294:15health 1049:24 1057:6,251058:8,13,18,22 1059:81059:25 1060:1,61062:5 1064:5,7,8,181065:6,10 1069:19,251070:14 1071:101073:10 1077:151078:15 1079:7,71089:23,25 1091:41096:3,24 1098:5,201113:10 1116:9,251117:14,17 1120:8,211120:24,24 1121:1,201121:24 1122:4 1123:111125:3,11 1126:171129:11 1146:22 1158:11161:23 1166:10,111176:13 1189:15 1198:21215:8 1216:13 1220:191224:25 1225:9,14,251227:4,19 1228:3,5,5,231228:24 1229:23 1231:11237:11,15,19,241238:5,9,11,13,15,16,181238:24 1239:1 1242:2



1242:6,8,9 1244:41269:21 1278:131300:23 1306:10,16,191307:6,8 1319:131375:25

healthcare 1060:191179:24 1201:13

healthy 1079:1 1156:6,121161:6 1204:9 1224:2

hear 1054:20,20 1092:231100:14 1101:16 1151:71174:12,14 1187:81213:2 1255:21 1266:111267:3,4 1290:151302:23 1303:231305:10 1343:4 1352:251366:18 1378:12

heard 1162:6,20 1163:241170:20,23 1174:161176:17 1189:6 1190:81207:18 1210:1 1211:21221:16 1224:161242:23 1256:241286:12 1299:15 1300:41304:21 1306:221368:18 1376:21 1384:2

hearing 1048:3,181053:2,3,12 1055:31056:2,7,9,25 1059:111061:21 1064:201070:18 1073:17,201077:8 1080:18,221083:22 1089:121090:14,17,25 1093:61094:13 1095:22 1096:41102:13 1104:7,181114:10 1118:141120:12,17 1123:131127:1,4 1129:5 1131:41134:14 1136:7 1137:11137:4,6,9 1139:31143:12 1145:8 1152:181152:23 1154:181160:18 1161:161166:15 1168:4,14,181168:23,24 1169:1,5,191169:25 1170:5,18,221171:17 1172:171173:21 1174:111176:16 1178:13 1181:41194:2 1198:6,9 1204:6

1207:20 1208:15 1209:61209:13 1213:13,17,221213:25 1214:4,8,121221:6 1224:4 1229:251230:1,3,5,17 1231:101231:21,24 1236:201237:4 1242:25 1246:241247:3 1248:15 1252:81252:10 1253:16,201256:10 1260:7 1261:51261:25 1262:1 1264:211266:12 1267:3,111269:24 1270:8 1273:181281:17 1284:10 1290:61290:10,13,19,231291:1,6 1293:201296:11,13,16 1297:171300:10 1301:12,151303:14,19 1304:21305:3,11,15 1307:9,191307:23 1309:16,191315:10 1318:15 1322:81323:13 1326:8 1327:251333:15 1334:9,231335:2 1338:24 1343:61343:10 1344:10,13,161350:3,14,16 1362:151363:2,11,21,25 1364:31373:4 1383:20 1387:61387:9,11,13

hearings 1085:211112:24 1135:1 1145:131149:21 1150:5 1151:61160:22,24 1166:141168:17 1169:11,121173:2 1177:22 1198:131209:22 1232:201302:24

hearsay 1100:17 1256:24heartland 1137:24heat 1137:17 1150:12heaven 1175:18heavy 1382:23heavyweight 1376:18height 1345:13held 1151:6 1177:71296:22,23

Hello 1204:8 1207:21help 1089:9 1101:61102:5 1108:8 1116:211119:20 1136:15

1146:14 1181:2 1218:91319:8 1361:5

helped 1071:11 1175:111273:13

helping 1108:10 1234:6Henry 1302:25herd 1295:1hesitate 1132:22 1183:14hesitation 1196:5hey 1101:6 1184:211379:20

heyday 1134:4He'll 1344:14high 1070:1 1075:221085:5,7 1087:191094:16 1103:251105:24,25 1117:161125:19 1130:24 1136:41142:12 1147:23 1148:91153:9,13 1154:12,121154:13 1157:101200:12 1205:8 1219:181238:9 1241:24 1263:141294:22 1295:16 1306:61363:25 1367:8 1384:8

higher 1063:4 1067:111084:19 1087:16,181218:17,19 1219:221233:8 1238:11 1241:201241:22 1247:12,15,151247:16,18 1304:111351:11

highest 1082:17 1367:7highlight 1072:11102:22 1274:16

highlighted 1349:12highlights 1274:12highly 1199:10 1200:71241:15 1306:2,3

highways 1085:4,51130:12 1304:18

Hill 1150:23 1315:12,181316:11 1319:7 1367:51372:16

Hillary 1151:20hills 1146:20 1239:12,13hinges 1180:15hippies 1205:11hire 1155:17 1219:21hired 1379:17 1380:1historic 1062:22 1082:2

1159:5 1241:19 1356:151356:19 1357:5

historical 1059:3 1132:11132:6 1243:23

historically 1148:241238:8

history 1057:3 1062:81063:1,24 1065:221067:22 1076:6 1079:201080:4 1097:3 1098:241099:2,5,6 1102:81110:10 1147:2 1158:31202:12 1252:15

hit 1222:11 1223:101333:19

hits 1192:14hoc 1376:16Hochstein 1245:11,14,16hogs 1155:8hold 1084:12 1196:201216:6 1221:2 1385:1

holding 1090:25 1173:1holds 1174:6home 1094:25 1109:241110:5,7,20 1129:131134:21 1138:111147:12 1163:7 1188:151201:11 1208:4 1211:81221:4,10 1224:31367:13

homeowner 1077:12homes 1148:3 1150:141166:1 1215:23

Homestake/Barrick1214:17

hometown 1158:181204:15

honest 1256:23 1329:191332:25 1355:231357:18 1359:18 1360:9

honestly 1184:13honor 1073:22 1080:191096:5 1102:11,141104:19 1110:15 1131:51137:2 1143:11 1173:11175:25 1178:141203:15 1207:171261:23 1266:9 1322:51323:8 1324:3 1327:211373:2

Honorable 1048:18



1129:7hook 1223:22hope 1072:12 1073:41074:2 1136:5 1170:121204:9 1207:16 1208:201209:5 1250:16 1283:2

hopefully 1053:151204:11,12 1333:191344:15

hopes 1211:22 1363:25Hopi 1315:2hoping 1098:1 1111:3horrendous 1203:101204:4

horse 1231:15 1293:161294:24 1295:1

horses 1155:9 1294:151295:18

hose 1382:9hoses 1070:2Hospital 1203:6hospitals 1381:9hosting 1139:5hot 1107:4 1109:8 1128:61128:6,8,10,19

Hotchkiss 1122:8hotel 1150:11hotter 1148:4hour 1120:13 1123:31307:16,17 1358:151367:13 1382:18

hours 1123:4 1173:181359:13 1367:161371:23 1380:191382:19

house 1059:22 1127:231128:2,10,11,13,15,161128:19,25 1129:11137:17 1141:171217:16 1229:201238:11

housed 1141:19houses 1165:16housing 1227:15how's 1057:22 1377:10huge 1092:10 1103:201180:19 1190:191191:12 1192:241294:10,19 1295:51307:5 1383:8

human 1058:6 1077:15

1078:14 1079:6 1080:101089:5 1096:3 1105:181113:2 1121:1 1138:251158:8 1205:2 1237:111237:15,19,24 1238:5,91238:18

humanity 1193:161205:3 1294:24

humans 1294:15 1299:11humble 1205:3hundred 1092:141101:20 1158:21 1177:41214:19 1299:191366:12 1370:19,20

hundreds 1081:251082:1,1 1223:1 1301:81321:1

hundred-year 1122:23hunting 1212:19 1226:22Huntsville 1366:22hurry 1197:22 1249:12hurt 1060:7 1111:25hurts 1211:14husband 1128:131143:16 1148:8 1154:221155:15 1211:25

husbands 1128:12Husch 1070:18,19,19hydrocarbon 1328:131331:11 1385:14

hydrocarbons 1330:18hydrogeologic 1074:10hyphen 1214:3H-e-a-d 1214:3,11

Iidea 1066:4 1082:91110:2 1164:11 1182:251224:1 1330:10 1334:41358:4 1365:3

ideas 1148:22 1330:9,221376:8 1385:4

identified 1254:221261:18 1262:101264:24 1310:161337:19 1338:1 1341:141341:22,25 1354:17

identify 1344:4identifying 1224:22idle 1252:17ignite 1165:25

ignorance 1213:8ignore 1226:5ignored 1153:19 1226:13ignores 1226:14,18ignoring 1226:23II 1182:23 1183:111203:7 1273:2

ill 1206:14illness 1106:11 1108:2illnesses 1112:22imaginary 1332:16imagination 1301:2imagine 1192:6,9 1222:81382:21

imaging 1099:231212:17

imbalance 1169:17immediate 1074:141120:20

immediately 1057:131161:23 1229:171352:19

immensely 1088:12immune 1223:8immunization 1060:23impact 1058:23 1063:111069:6,6 1077:151097:19,20 1103:151104:5 1112:16,161116:4,11,19 1117:11119:23 1123:181137:15 1185:1 1189:101217:5 1226:13,19,211226:23 1227:131251:20 1287:9 1327:161340:12 1366:2,31367:2,17,23 1368:11379:11

impacted 1229:17 1365:5impacting 1227:8impacts 1058:1,181065:25 1068:8 1108:241117:7,18,21 1130:191156:18 1158:24 1226:21226:6,9,14 1227:2,121227:23 1228:9 1250:251289:11,18,23 1313:201326:13 1336:211338:17 1364:251365:22,22 1376:2

impairments 1060:25

impartial 1169:12impeach 1267:8,9impermeable 1192:14impetus 1187:23implication 1161:101362:1

implications 1161:11import 1118:10importance 1089:20important 1068:161073:16 1087:251103:21 1104:8,111110:17 1114:6,7,131200:1 1204:24 1215:121219:25 1240:15,191242:3 1276:18 1297:61303:22 1328:231333:20 1361:11

imported 1118:1 1374:12impose 1064:16imposed 1087:7 1098:51126:17 1141:23

impossibility 1280:9impossible 1114:18impoundment 1258:91349:16

impoundments 1076:21227:10

impression 1162:31168:12 1228:221229:13 1378:4

improperly 1241:25improve 1148:231229:21 1292:11,11

improved 1218:11224:18

improvement 1371:15improvements 1229:121313:11

improves 1086:141088:24

improving 1322:4inability 1176:9inadequacies 1107:25inadequacy 1062:11168:16

inadequate 1062:21063:12,15,17 1078:21078:10 1089:11,191113:12 1114:141122:11 1125:16



1162:11 1168:23inappropriate 1089:111229:9

incentive 1142:25 1143:21281:20 1282:6

incident 1298:17 1299:8Incline 1153:2include 1060:24 1093:161118:8 1126:19 1171:21246:6 1263:5,7 1270:21305:2 1345:14,18

included 1060:5 1069:241125:11 1228:6 1265:161270:11 1278:5 1320:191342:11,16 1346:131351:25 1374:14

includes 1130:5 1255:41264:3,11 1345:17

including 1062:81069:25 1073:131074:13 1086:171103:16,23,25 1108:31166:3 1274:2

inclusion 1120:11income 1108:23incomplete 1113:211114:17 1116:23 1253:6

incompleteness 1127:15incongruent 1117:11inconsistently 1229:22incorporate 1386:4incorporated 1083:141375:6

incorporating 1231:4incorrect 1319:8 1324:20increase 1063:18 1087:141216:16 1299:10 1320:31325:21

increased 1219:1 1238:5increases 1184:171219:20 1384:15

increasing 1109:111324:22

increasingly 1138:8incredibly 1059:91184:12

incremental 1239:191240:10 1241:3 1287:13

indelible 1119:23independent 1116:18index 1218:25

indexed 1125:20Indian 1164:19indicate 1261:1indicated 1097:91241:14

indicates 1095:16indicating 1054:171174:24 1321:22

indication 1082:211375:12 1377:3

indirect 1103:22 1117:23indirectly 1149:22individual 1203:51265:15,22 1268:21,23

individually 1117:10individuals 1165:51213:19

induced 1112:22industrial 1057:251085:23 1088:20 1200:91248:7

industries 1061:101079:11 1111:10,151133:19 1138:8 1142:161215:5 1281:6 1292:5

industrious 1215:16industry 1060:9 1063:11073:3 1074:2 1082:61101:7 1103:20 1105:71105:21 1107:251108:21 1110:3 1111:141111:18 1112:171117:18 1121:211132:24 1133:14,15,181134:1,10 1135:91141:24 1142:14 1146:11146:2,8,13 1147:151151:12 1153:171160:14 1161:3,191172:10 1175:4,14,221196:11 1201:7 1206:181218:25 1224:10 1294:51294:17,22 1300:201301:22,23 1313:51364:23

inevitable 1131:241171:11

infinity 1192:11inflation 1125:20influence 1149:10influenza 1060:19

info 1174:6inform 1116:20 1140:141141:22 1143:6,81326:5

information 1053:201065:15 1074:231076:11 1097:5 1098:161110:17 1112:2 1116:161120:7 1124:19 1130:101179:16 1190:25 1195:81213:10 1221:111227:18 1233:231261:13 1306:8 1307:71307:8 1338:3 1350:91352:9 1378:25 1381:121386:25

informed 1116:211125:8 1140:15,171206:14

informing 1325:20inhale 1201:3 1238:23inhaled 1113:15 1202:191239:6

inherent 1158:6,241160:5

inherently 1126:10initial 1166:14 1256:81304:22 1347:16 1372:8

injecting 1158:13injury 1176:5,13innocuous 1188:21innovate 1148:24,25input 1091:2 1095:251379:15,17

inquire 1178:18inside 1135:16 1240:61368:11

insinuating 1210:8insolvency 1299:16inspecting 1173:24inspection 1069:181278:17

inspector 1173:22inspires 1126:5install 1317:1,9instance 1061:8 1080:81098:17 1099:221186:20

instances 1096:231224:23

Institute 1111:19

institutional 1229:3insufficient 1080:5insulated 1368:14insurance 1159:81200:24,25 1201:16

insure 1159:9integral 1155:22 1245:14integrated 1155:12intelligence 1210:7intend 1056:4intended 1087:15 1134:1intending 1056:61169:15

intense 1200:11,18intensified 1303:6intent 1273:6 1275:21327:10 1370:4

intention 1156:7intentionally 1122:3intentions 1187:19interaction 1113:71115:4,16 1245:17

interest 1048:17 1050:31071:4 1095:14 1123:91123:11

interested 1138:31309:23 1310:1 1388:14

interesting 1114:251173:4 1177:5 1192:171202:1

interim 1271:5 1311:141311:16

intermittent 1067:19intermittently 1062:22intermountain 1137:24internal 1113:15 1303:21361:23,25 1362:3

internally 1362:19international 1083:131112:21 1190:1 1294:11

Internet 1053:24 1100:12internship 1155:16interpret 1186:3interpreted 1186:19interrupt 1053:131253:16 1290:14 1343:6

interruption 1056:241293:19

intersection 1384:18,21intervals 1053:14intervention 1168:13



intimately 1129:221207:7

intolerably 1085:11intrinsically 1095:7introduced 1060:121134:16 1184:18

invalidated 1325:8inversion 1366:11,141368:3

inversions 1366:10investigate 1100:131209:23

investigated 1343:171366:25

investigation 1069:161254:11

investment 1073:21111:25 1142:11,13,141227:15

investments 1101:5investors 1236:2invite 1087:3invoice 1359:9invoices 1359:18involve 1284:5 1327:81340:8 1354:17

involved 1114:151121:23 1129:221183:13 1237:14,181241:5 1245:19 1257:31257:8,9 1270:111271:4,4 1272:11273:21 1276:6 1277:21286:20 1287:2 1294:61300:14 1324:121335:17 1346:21 1362:61365:19 1374:211375:13 1376:9

involvement 1245:211376:5

involves 1345:23involving 1223:2 1362:3in-house 1345:1,61351:16

in-place 1273:6,14,251274:20,20 1376:19

iodine 1199:14 1212:17ionizing 1140:4Iran 1183:17Iraq 1183:16 1186:171203:13

irreplaceable 1096:2irresponsible 1142:20irrevocably 1058:24irrigate 1079:5irrigated 1155:11irrigation 1059:221157:4

island 1117:20 1188:19isotopes 1099:20,24ISR 1374:21,22 1377:3issuance 1063:13issue 1058:1 1065:111104:23 1140:6,181169:22,23 1183:241191:4 1197:7 1205:41205:19 1261:171318:12 1332:6,211333:1 1338:11 1362:11

issued 1088:6 1122:41260:7 1316:14

issues 1051:14 1057:171067:6 1094:24 1097:81097:14 1126:7 1135:241153:17 1166:171181:18 1190:19 1195:51195:6 1197:23 1204:231225:12 1228:181261:17 1300:231304:16 1306:101309:14 1329:5 1331:221332:6 1333:2 1376:71386:4

issuing 1058:16items 1374:12,17Ivers 1131:4,5

JJacket 1294:1JAG 1048:2James 1049:2Janet 1048:21 1104:181388:4,20

January 1127:22Japan 1186:6 1205:17Japanese 1205:15JD5 1143:18Jeff 1350:23 1351:11JEFFREY 1049:12Jennifer 1064:20 1089:121089:13 1119:8 1149:9

jeopardized 1079:8

jeopardy 1160:8Jerry 1049:21jigsaw 1174:7job 1080:21 1088:111103:25 1131:181135:18 1148:5 1167:151186:21,24 1189:171197:10 1201:20 1203:61219:20,25 1235:2,7,71275:15,19,21,221276:1 1277:5 1328:11

jobs 1056:19 1061:131071:5 1072:21,251073:4,25 1074:21084:8,9,9,10,131085:12,13 1088:51089:20 1092:13,14,251098:2 1099:25 1100:231101:1 1104:2,4,4,7,101120:21,21 1130:221131:21 1132:21,231133:13 1136:20,21,211136:21,22,22 1140:181148:7,18,20 1149:3,41149:22 1163:14,151188:8,22 1195:101201:22,23,23,241205:9,10,19 1207:101209:21 1216:4 1219:221222:11 1223:3,221291:7

Joel 1137:1jog 1369:12John 1051:15 1106:91120:17,18 1151:241191:14 1306:17

Johnson 1104:18,19join 1152:3 1293:6,91296:1

Jolana 1172:17,241305:16

Jon 1123:13,15journalist 1210:9joy 1127:24Juan 1129:12Judge 1056:15 1079:131084:6 1089:16 1090:241094:17 1123:14 1129:71154:19 1168:201214:15 1296:101303:21 1322:13,15

1325:8 1362:11judges 1134:25judicial 1048:1 1171:131385:24

July 1318:25jump 1200:13 1232:10junction 1070:5 1093:31094:20 1102:151103:22 1105:8,22,241106:7 1107:7 1108:5,91109:23 1110:2,9,221112:3,6 1119:121127:7,22 1134:211136:10 1147:141148:15 1159:201201:19 1204:14,171274:3,6,9 1293:241295:5

June 1066:18 1260:2,31362:11

jury 1302:18Justice 1121:7

KKaren 1094:13Karl 1112:21Kathryn 1127:1,2Katie 1077:8,9keenly 1305:18keep 1070:10 1095:51101:22 1104:7 1108:241152:23 1175:151178:13 1191:111222:19 1223:111230:12 1256:15 1288:41300:25 1301:7 1307:231352:21 1359:14,24

keeping 1057:25 1259:171335:25

Kelly 1151:21Kemper 1077:8,9,9kept 1134:21 1178:81325:23 1326:2 1336:101359:22

kerosene 1382:11keys 1182:12kid 1202:4kids 1073:7 1144:12kill 1206:7 1353:231356:12

killed 1220:9 1354:5



killer 1358:1,8Killian 1108:9killing 1194:24kills 1162:23 1180:11kilometers 1366:4kind 1056:11 1059:81134:23 1140:1 1144:191179:15 1184:9 1194:11198:16 1255:7 1279:181291:25 1296:3 1299:21299:5,22 1304:241326:18 1329:12,201331:15 1347:18 1352:21368:7,9 1376:13,15,161376:20 1377:5 1382:151383:25 1384:16

kinds 1099:21 1185:121203:25 1295:18

Kleinfelder 1372:15knew 1187:5 1194:231202:9 1205:23,241241:2 1309:8,22,251312:7,8 1358:91359:21 1362:18

know 1054:5 1068:251076:8,24 1080:121081:25 1082:10,121083:8,16,20 1089:211098:7 1100:5 1111:121112:13,15 1113:12,251114:9 1118:21 1119:101119:11 1128:24 1129:21130:22 1134:251135:18 1139:24,251140:9 1144:21 1146:161150:22 1153:16,251163:12,16 1165:11168:5,7 1170:6,7,9,101172:12 1175:14,251179:2,4 1180:91185:15 1186:23 1187:11187:11,22 1189:81190:3,16 1191:22,251192:7 1193:15,17,181193:21,21,24 1194:161194:16 1201:1 1202:241203:11,12 1204:21206:6,7,11,15 1208:31210:14,18 1211:231222:19 1223:6,121230:5 1233:13 1236:8

1237:17,22 1241:1,8,91241:25 1242:7,161243:11 1254:171256:25 1257:6 1258:241259:2,3,7,10 1263:141263:14 1269:6 1272:71273:20 1274:8,18,181277:11 1282:121289:16 1291:17 1292:31293:1,3,7 1294:31295:3,25,25 1299:2,151300:6 1302:15 1303:21303:23 1305:6 1306:91307:2 1312:9 1313:21313:22 1314:6,8,91318:10 1322:231324:10 1325:10 1326:31327:13 1328:6 1329:121329:18 1330:151336:22,23 1343:241344:6 1347:15 1349:61349:10 1353:9 1354:11354:6 1355:23 1356:21356:3 1359:12 1360:21360:13,17,17,19,211361:3,3,9,10 1363:81364:18,21 1366:201367:11 1368:4,201369:2,8,18 1370:241371:10 1380:121382:25 1384:3 1386:25

knowing 1121:251217:21 1382:3

knowingly 1122:2knowledge 1149:1,151263:25 1275:11 1315:51362:8

known 1122:12 1128:11155:13 1175:251176:10 1179:161214:22 1220:18 1248:81278:9 1315:24 1316:21376:1

knows 1058:12 1106:231110:22 1206:9,121208:6 1218:3 1228:5

Korean 1203:8krypton 1199:15

LLa 1153:2 1215:2 1246:7

lab 1228:16lack 1054:12 1063:51084:7 1101:14 1120:61127:15 1177:16,181207:10 1224:24 1350:4

ladder 1263:14ladies 1096:5 1102:11lady 1132:20laid 1153:14Lake 1147:6Lakewood 1049:7lambs 1299:8land 1072:23,25 1080:131081:17 1096:3 1098:211104:10 1131:16,17,191136:10 1138:1,21187:1 1189:23 1208:131280:10,18 1281:4,5,81281:12,21,21,23,23,231282:7 1284:7,221285:15,22 1286:7,9,191294:12 1352:161375:21

landfill 1311:15lands 1104:25 1119:231121:4,10 1173:251189:21 1197:2 1281:111352:12,15

landscape 1075:19landscapes 1138:1,16language 1093:15 1175:31242:21 1254:14,20

large 1062:23 1101:101103:8 1165:21 1188:241191:5 1210:10 1219:111261:8 1262:5 1280:171287:6 1331:9 1336:211351:19 1352:19,201354:2 1366:1 1372:31382:9,23 1383:4,5

largely 1226:3,131367:10

larger 1188:25 1336:3,4largest 1067:1 1113:121298:9

lasted 1222:21lasts 1141:13late 1070:21 1162:171251:22 1266:2 1356:141359:19

lately 1299:18

laughable 1159:18launched 1182:14laundry 1150:11law 1049:10 1070:131094:7 1097:9 1106:101110:11 1125:2,21177:24 1262:231308:13 1357:3,9

laws 1069:24 1176:51181:22 1184:22,251185:13,16,17 1186:1,31189:24 1224:171229:23 1282:25 1283:11297:14 1386:24

lawsuit 1168:19 1176:2lawsuits 1076:24lawyer 1190:4lawyers 1053:11 1190:51216:10 1231:17

lax 1224:20lay 1081:21 1240:191337:1

layer 1130:16 1366:13layers 1080:4 1130:2,31156:25 1192:14,151222:5

laymen 1236:11layoff 1153:15layperson's 1105:6leaching 1114:7lead 1075:13 1080:151081:14 1264:14,191271:3,10,12 1330:81333:13

leader 1119:8leadership 1060:81294:8

leak 1076:5 1122:121176:22,23,24

leakage 1192:2,5,61310:5

leaking 1076:7 1122:13leaks 1122:19 1176:241177:2,3 1192:13

leak-proof 1176:20learn 1099:5 1176:91179:21 1182:201200:19 1217:7

learned 1070:22 1071:31106:1 1147:12 1177:151181:20



lease 1068:4,5leased 1060:16leases 1155:10 1197:2leasing 1196:20leave 1064:2 1071:7,141073:4 1096:2 1141:101156:8 1189:21 1206:211209:4 1212:2 1303:141305:9 1316:19 1383:13

leaves 1097:7 1229:12leaving 1062:19 1071:151072:18 1163:3 1208:111225:6 1228:21

led 1270:25 1380:25Lee 1048:21 1388:4,20Leetso 1134:11left 1071:8 1072:31107:12 1108:6 1123:71134:10 1144:23 1158:71159:10 1168:9 1178:241216:4 1217:11 1218:51225:7 1233:25 1273:11280:22 1301:3 1302:141304:1

leftover 1071:16legacy 1070:8 1073:51080:9 1105:15 1132:101141:10 1156:151157:20 1158:13 1160:51163:16,17,17 1208:111221:3

legal 1049:5 1236:121298:22 1385:24

legislation 1165:18legitimate 1170:8,11legitimately 1359:13length 1081:5lengthy 1303:25lesser 1241:10 1287:161348:8

lesson 1170:24lessons 1067:22 1217:8letter 1077:10 1090:121225:11 1285:1 1332:211333:21

letters 1333:3letting 1070:6 1198:5let's 1096:21 1145:11148:5 1178:9 1189:11224:1,1 1231:151232:10 1257:12,24,25

1266:1 1272:13 1290:101290:11 1321:15 1328:51344:19 1370:141371:10

leukemia 1106:41206:10

level 1059:15 1068:71097:1 1112:25 1113:41117:8 1120:3 1125:251139:12,21 1172:21187:21 1199:241217:17 1233:8 1238:161239:2,16,21 1278:41282:16,18,20 1298:191367:7 1386:20

levels 1147:23 1153:91167:10 1239:121240:22 1241:20,241366:8 1385:11,12

liability 1057:17Libby 1194:21,22liberty 1254:4license 1048:6 1051:131061:24 1063:131065:11 1068:181078:10 1095:13 1115:81115:13 1118:9 1170:161191:6 1195:15 1197:211220:24 1226:8 1227:211229:25 1230:4,81231:2 1243:16 1260:151260:17 1288:5 1309:131322:17,18,19 1323:121323:21,25 1324:71325:5,9,13,18 1337:51342:21 1345:161361:19 1378:19

licensed 1066:1 1118:7licensing 1065:19 1077:51079:14 1080:151095:21 1196:2 1220:141220:14 1323:201325:15,17 1347:6

lids 1146:19lie 1173:23lies 1216:3life 1059:2 1060:141075:3 1077:11 1079:11081:9 1088:5 1091:81092:24 1093:2 1094:191105:1 1121:1 1125:21

1127:8 1177:10,251178:16 1181:101183:13 1184:12,131190:7,22 1193:161205:24 1227:9 1292:111292:12 1345:241352:22,23

lifespan 1187:16 1191:10lifestyle 1176:13 1215:21lifestyles 1215:3lifetime 1067:21 1185:231204:4

life-span 1222:4light 1060:13 1323:111384:18

lighting 1384:1,7,9,10lights 1384:11,12likes 1310:3,4limbs 1299:9lime 1383:6limit 1061:25 1087:221226:16 1298:231310:14

Limitation 1182:6limited 1125:23 1258:121275:11 1326:20

limits 1087:10 1268:211385:20

Lincoln 1049:3line 1072:9 1074:51108:2 1181:10,191198:1 1201:2 1236:181236:18 1239:19 1240:91248:12 1262:121266:10 1286:3 1322:61323:19 1378:17

lined 1076:3Liner 1122:11liners 1176:20,21 1353:21353:4

lines 1072:1 1337:25link 1053:24 1054:151177:21,24 1178:31179:19 1243:23

linked 1061:1 1235:201243:21 1266:16 1343:5

list 1054:24 1055:51056:12 1081:181108:11 1132:3,5,61154:12 1267:6 1268:4

listed 1132:4

listen 1064:14 1204:111347:7

listened 1118:12 1304:41305:17 1368:5

listening 1073:23 1131:61151:9 1184:2,2,3,41240:4 1261:15 1291:61291:15

listing 1110:6literally 1204:16literature 1058:11 1061:2litigation 1092:9 1361:171362:18

little 1073:20 1081:101097:13 1101:171127:13 1130:171137:16 1144:2,51148:2 1157:19,241169:8 1172:3 1173:101175:8 1186:16,221193:4,5,5,5,8,131195:3 1196:5 1198:231208:15 1215:131217:13 1246:12 1255:91298:5 1310:5 1361:51364:10 1368:1

live 1064:18 1070:201075:24 1078:15 1093:31097:2,19 1101:111111:17 1120:19,201121:4 1123:15 1129:121131:6,10 1134:201136:2,9 1161:151163:13 1172:24 1175:71175:8 1204:14,17,201205:7 1207:5,71214:16,21,25 1215:161217:13 1221:9 1224:111224:14 1292:7

lived 1060:15 1070:211094:19 1105:6 1106:71127:7 1163:2,191172:25 1173:11,121181:7 1202:4

livelihood 1160:9livelihoods 1140:12lively 1149:9liver 1121:5lives 1095:1 1143:141146:20 1152:7 1293:10

livestock 1298:25 1299:6



living 1088:9 1119:121129:15 1134:201185:20 1190:8 1191:151210:12

LLP 1049:2loads 1369:15local 1071:6,16 1072:141072:21 1079:10,121103:12,24 1104:4,131125:7 1141:4 1144:101155:20,24 1156:21167:9 1172:1 1196:241218:2 1229:16 1292:31297:22 1364:22 1382:1

locally 1293:11locals 1367:2located 1077:13 1154:241215:19 1253:10,11,131274:10 1282:221285:14

location 1101:15 1273:101275:7

locations 1057:9 1288:221288:23 1319:22

locked 1093:13 1094:11lofting 1364:19,20loggers 1205:7logic 1080:24 1082:20logical 1082:13 1099:7logs 1205:16Lois 1090:23Lone 1157:5long 1057:13 1072:71090:5 1109:1 1111:41131:6 1135:17 1141:61141:13,20 1154:121183:12 1189:5 1192:81204:25 1224:21 1227:91234:16 1238:21,211249:23 1262:8 1282:51282:8 1286:5 1299:221300:6,7 1307:161320:9 1366:14 1387:11

longer 1058:2 1092:11108:3 1119:10 1179:201189:23 1192:181263:16 1287:131351:11

long-standing 1249:24long-term 1058:8,181063:23 1096:24

1109:16 1146:9 1156:161158:15 1159:12 1160:71217:5 1320:2 1351:25

look 1053:25 1081:111092:12 1103:5 1104:141112:18 1131:14 1134:81140:18 1164:231181:18 1182:7,171185:2,6 1186:81188:12 1192:10,221193:10,11 1194:1,121195:10 1196:10,14,141196:17 1210:14 1223:71223:11 1224:1,11237:4 1243:13 1246:171246:20,21 1251:14,151262:13,14 1269:7,151278:19 1280:18,241287:24 1291:191298:21 1313:161320:12 1321:5,181324:18,21 1325:21328:18 1329:10 1331:11331:15 1332:9 1336:211337:4,17 1338:81339:4 1365:21,221367:5 1370:8,111379:6 1385:16

looked 1066:23 1083:21099:17 1125:10 1135:41150:16 1171:121193:25 1196:5 1216:121221:11 1243:15 1277:61278:11 1280:191289:20 1299:151316:19 1321:4 1330:151330:21 1334:3,17,201337:6,7,10 1342:101348:5 1371:7,9 1374:71374:8 1376:17 1377:111377:25 1381:141385:17

looking 1068:14 1081:121111:5 1112:19 1115:11138:15 1148:7,171178:8 1184:20 1186:171187:1,6 1188:171191:9,24 1202:21222:13 1223:11,151239:15,19,21 1250:241256:8 1257:3 1259:12

1267:14 1280:12 1285:71287:14 1307:211311:18,19 1327:3,61339:3 1351:23 1355:51365:11,14,24 1368:11372:2,5 1374:8 1377:81377:19,23

looks 1084:17 1321:9,201321:25 1377:7

loop 1325:24 1326:2lose 1344:11losing 1215:20loss 1145:25 1226:181246:16 1291:14,18

lost 1132:23 1133:141174:3,4 1212:11

lot 1054:22 1056:151059:20 1074:1 1099:11101:20 1126:5 1129:201134:25 1135:6 1141:91144:2 1161:4 1164:1,21164:7 1166:4 1167:231173:3 1174:16 1183:161184:5,9,13,18,19,22,241185:25 1186:161187:18 1190:4,131191:20 1193:19,201194:16 1195:8 1196:121197:24,25 1199:11203:5,7 1204:111215:12 1220:3 1221:211222:11,12 1223:71227:5 1233:7 1288:21293:5 1294:6,17,211299:8 1330:9,211331:21,21 1332:5,161353:25 1368:9 1372:161376:23 1378:251381:14,24 1384:11,12

loud 1186:23 1339:24LOUIS 1050:2love 1094:20 1098:31165:10 1166:1 1204:181212:10 1221:9 1224:2

loved 1181:14lovely 1177:14loving 1204:19low 1074:20,22 1075:41084:15 1092:201123:24 1238:1,1,161246:9,10,13 1287:10

1305:24 1342:14lower 1067:13 1084:181084:21 1109:8 1247:71247:20,21,23 1248:31248:24 1249:9

low-carbon 1103:2Lucas 1049:3 1242:231248:12 1261:23 1266:91266:23 1267:5,91269:2,15,19 1270:41273:16 1275:241281:15 1284:14,191286:11 1315:17 1316:11316:10 1322:5 1323:71327:21 1331:23 1333:61333:8,10 1344:12,141346:10 1350:1,41373:2 1387:10,12

luck 1207:14lumber 1205:17lunch 1150:5 1198:6lungs 1162:22 1201:4Lyons 1049:13lyrics 1071:23

Mmachinery 1070:4machinist 1147:13Madam 1121:1magic 1384:5magnitude 1365:4,10main 1048:21 1049:101071:4 1093:10 1131:171131:20 1133:8,101246:6

maintain 1098:4,171219:17 1299:20,20

maintained 1096:13maintaining 1087:21maintenance 1063:41076:14

major 1066:19 1067:161157:9 1180:12 1183:141205:12 1218:18 1253:81329:6 1370:5

majority 1097:181166:18 1207:4

make-up 1330:3making 1055:9 1060:91061:11,12 1073:41082:4 1083:8 1092:10



1101:4 1108:18 1112:101135:14 1140:171167:25 1171:3 1205:181207:15 1233:101278:19 1285:11 1291:91291:13 1304:111353:20

man 1081:5 1179:51187:4

manage 1299:22managed 1210:10 1273:51281:23

management 1069:121078:1 1132:10 1139:91212:23 1225:1 1246:141281:23,24 1295:221325:20

manager 1143:19 1256:11271:15 1335:7

managers 1217:25managing 1281:4mandated 1168:23Manhattan 1112:23manner 1083:6 1104:91144:24 1196:4 1198:18

manufactured 1353:5manufacturers 1061:3man-made 1096:111122:22

March 1051:18 1069:101321:12 1322:13 1325:6

marginal 1079:9 1099:18Margo 1209:15,16Marie 1121:1mark 1096:2 1218:221219:8 1284:10

marked 1309:19 1318:151326:9

market 1063:2 1070:171084:15 1086:14 1100:31105:15 1123:24 1150:71155:5 1218:4,15

market's 1066:10married 1211:25Marv 1084:5Marvin 1084:2massive 1107:17master's 1149:7material 1062:251071:17 1079:221092:17,21 1162:14

1189:4 1201:10 1202:181207:6 1229:9 1239:11240:16,17 1301:181302:21 1303:5 1316:41329:3

materially 1376:9materials 1048:6 1071:181072:19 1076:131077:21 1079:151092:20 1100:4 1115:201117:8 1118:11 1119:81125:5,18 1199:101212:14 1227:9 1242:11249:4 1304:15,17,191305:5 1317:12 1365:71365:8

math 1081:10 1174:141306:5

Matt 1049:16 1152:24matter 1048:17 1078:221097:2 1158:11 1160:171176:25 1211:20 1216:81297:15 1316:9,251370:6

Max 1301:14,15,16maximum 1345:131366:4 1368:15 1369:191370:11 1371:21

ma'am 1305:12McKenner 1080:18,191080:23

McMullen 1168:201325:8 1362:11

McMullen's 1322:15mean 1164:23 1167:31175:15 1176:8 1219:211284:15 1291:241323:15 1344:13 1347:41347:17 1366:21

meaning 1076:161198:15

means 1061:18 1081:111096:16 1099:141189:18 1218:211221:23 1302:17 1308:91359:14 1365:6

meant 1058:14 1165:201186:4 1341:20

measure 1162:131367:11

measures 1060:10

1158:11 1213:11 1302:31386:23

media 1133:10 1362:21365:1

medical 1099:22 1128:31183:6 1206:13 1295:6

medically 1198:22medicine 1146:14meet 1109:8 1149:121167:4,5 1210:251220:21 1271:7 1287:7

meeting 1151:25 1176:211178:7,12 1233:141241:1 1262:17 1296:221296:23 1305:191350:10 1354:8 1356:51362:7,9 1377:221380:3,11

meetings 1115:24 1173:41361:23 1362:1,31380:13,14,17,18

melt 1078:23 1157:3,51193:3

member 1055:2 1083:121152:6,22 1177:71186:8 1209:17 1211:191213:16 1220:2,121313:1

members 1056:6 1102:161103:15 1119:131121:22 1155:18 1165:61178:20 1212:111217:23 1224:9 1245:51245:8

membership 1102:19memo 1312:10memorandum 1051:221282:2 1339:7

memories 1182:2memory 1237:3 1266:61369:12

men 1121:3 1199:21,251220:8

mental 1060:25mentality 1142:24mention 1081:241084:23 1126:9 1220:81228:16

mentioned 1125:141184:7 1185:9 1377:11385:18

mercury 1060:21merge 1260:1merged 1259:25mergers 1250:12mesa 1066:17 1069:8,181083:4 1086:12 1103:81103:22 1106:9 1111:221154:23 1158:201176:22 1180:111194:14 1198:121220:12 1245:15,20,221245:25 1246:3 1248:61249:25 1250:5,7,14,201251:5 1252:1 1258:21258:16,21 1259:21313:8

mess 1187:9 1194:20met 1058:2 1086:161097:10 1167:6 1274:211283:9,11

metal 1081:13 1180:14metals 1081:13,21metaphor 1137:16metastasize 1162:22Metcalf 1120:17,18,18meter 1183:4method 1116:14 1308:201376:19

methodology 1345:211345:23

methods 1080:5 1107:221217:25 1308:5 1309:41312:5,22 1313:61385:21

Mexican 1081:20Mexico 1214:18,20,241218:13 1220:10

Michael 1160:18,19Mickey 1144:15mid 1070:24 1228:16middle 1248:20 1339:3mid-pack 1130:16mighty 1150:14Migrants 1138:5Miguel 1063:17 1065:231066:2 1074:16 1075:91107:6 1143:18 1164:71172:25 1282:16,19,211282:24 1283:4,7,141296:21,23 1297:4,51340:1 1341:7



Milan 1214:17mild 1241:10mile 1188:19 1280:11miles 1075:18 1085:191101:12 1123:2,31136:10 1143:15 1151:31154:24 1156:24 1223:11279:8 1293:13,211300:1 1366:24 1367:251368:2 1382:18

mill 1048:6 1051:13,241052:4 1053:4 1056:211056:22 1057:14 1059:31059:7 1061:16 1062:141062:15,21 1063:20,241064:1 1065:1,19,251066:4,7,11,17 1067:4,51067:20 1068:1,3,5,121068:25 1069:4,8,10,181069:22 1070:23,251074:5,7,8,9,11 1075:31075:6,17,17 1076:1,6,71076:9,10 1077:5,7,141077:25 1078:9,211079:4,14,16 1080:6,161082:10,16,18,21,221084:16 1085:2,11,121085:13,16,23 1086:121086:14,20,24 1087:51088:1,7,13,18 1089:201090:4,9 1091:17,20,241092:5,9,13 1094:151095:9,18,21 1097:171097:24,25 1099:11,251100:25 1102:3,10,211103:15 1104:3,15,241107:1,2,7,19 1108:1,41109:19,24 1112:18,201113:13 1115:2 1117:191117:24,25 1118:4,6,81119:22 1120:6 1121:121123:10,12,17,17,201124:3 1125:1,12,18,211126:19,22,23 1129:101129:20 1130:7,191131:2 1132:12,13,131135:15,19 1136:12,181136:23,24 1139:221144:10 1145:6,161146:17 1147:111152:15 1154:9,15,21

1154:25 1156:15,181158:8 1159:18,19,201159:22 1160:5,161163:13 1164:11,181166:16 1170:8,91172:8 1176:22 1178:61180:12 1188:4 1189:201190:6,22 1191:111194:10 1206:24 1208:41208:24 1209:201210:20,22,22 1211:61211:22 1213:9 1215:101215:19,24 1216:251218:2,12 1220:14,151220:24 1221:141223:17 1224:11,15,181224:19 1226:15 1227:61228:13 1230:8 1231:21233:11 1234:4 1238:11239:13,24 1240:2,61241:19 1242:14,17,171242:18 1245:15,251246:4 1247:22 1248:11248:2 1249:25 1250:11250:7 1251:5 1252:1,31252:13,15,25 1253:3,61253:7,25 1254:11258:3,4,16,20,211259:2,9 1264:251272:18,25 1278:10,101280:2,17,22 1282:221285:8,20,24 1286:251288:13,17 1292:181293:3 1296:23 1297:81297:25 1298:11,20,221299:12,20 1302:7,141309:13 1316:201317:14 1319:5,9,211320:2,9 1322:2,41323:5,19 1326:241332:18,19 1334:5,181335:12,17 1336:6,181336:20 1338:14 1339:81339:12,13,19 1340:31340:15,17,24 1342:191343:2 1345:14 1346:31346:8,10,14 1347:181349:7 1352:12,22,221356:2,4 1364:221365:5 1366:8 1367:11368:4,6 1369:14,19,23

1369:25 1370:10,12,221370:24 1371:4,10,121371:13,23 1372:191374:1,5 1381:5,5,6,181381:23 1382:7,241383:25 1384:9,17,221386:15,16,19 1387:1

milled 1084:21 1141:131205:17 1214:20

millers 1121:8 1205:141206:8

milling 1058:5,201059:17 1062:7 1063:251081:23,23,24 1084:91084:13 1088:111091:11 1092:201096:15 1100:9,101111:23 1117:2,41134:8 1135:9 1146:21156:22 1158:3,6,12,251159:3,6,15,25 1160:121160:14 1161:7 1178:241204:24 1243:22,241281:25 1297:23 1301:61316:22 1358:7

millings 1194:9million 1062:15,171063:14,19 1090:8,9,101091:16 1107:3,81121:12,12 1122:16,181123:5 1125:13,141132:11,11,12,13,151159:17,20,21,221218:12 1225:4 1229:111298:15 1345:2,3,4,71349:3,24 1350:13,131350:18 1351:10,241371:15 1386:16

millions 1111:251136:17 1223:23

millirem 1239:17,221240:25 1241:1

mills 1062:12 1068:201078:4 1079:21 1088:191092:22 1099:3 1106:141106:21 1117:9 1121:111122:11 1171:22 1180:51221:22 1222:161239:11 1241:2,201258:14 1302:1 1373:131374:13

mill's 1063:10 1098:11124:21 1135:2 1326:13

mind 1174:5 1220:71284:25 1300:251352:19 1364:151381:21

minds 1251:6,7,8mine 1057:24 1068:11069:19 1072:2 1077:231106:9 1107:18 1108:51109:19 1111:3 1118:211124:16 1126:191143:18 1153:2,3,61184:6 1194:19,221200:3 1202:17 1204:21212:22 1217:241218:12 1244:9 1245:231247:24 1250:141264:12,21,23 1266:201268:18 1270:17 1283:31297:24 1298:16 1300:41300:5,6,8,22,24 1304:6

mined 1084:20 1214:201241:15

miner 1143:17 1244:3,91244:21,24

Mineral 1062:17 1065:21106:15 1107:191111:24 1196:19

Minerals 1049:10miners 1121:8 1151:151151:24 1206:7 1217:241219:12,13 1238:81241:17

mines 1066:15 1067:151068:6 1077:20 1082:11086:11 1117:5 1118:51153:1,11,12,14,191173:23,24 1174:41181:18 1219:12 1220:71220:10 1244:4 1245:91245:18 1246:5,151257:16 1258:121264:24 1268:9,161283:6 1336:3 1352:111352:19

minimal 1096:19 1225:5minimize 1161:20minimizing 1367:9minimum 1141:221149:12,14



mining 1049:12 1058:41058:20 1059:16 1062:71065:2,16 1067:101078:9 1084:9,131088:11 1092:141103:13 1111:4,231114:22 1117:1,61121:4,10 1133:171134:7 1135:9 1136:201146:1 1151:15,181153:23 1154:151157:20,22 1158:13,241159:3,6,15,24 1160:141161:7 1171:22 1173:211183:9 1194:5 1196:221199:9,11 1204:241206:15,18 1207:11210:17,18 1218:22,251219:7,16 1220:151238:7 1243:22,23,251244:8,12,13,14,151246:2 1257:14 1281:61281:9 1293:3 1297:221298:3 1301:6

mini-mall 1137:22minor 1128:23 1329:2,51370:4,6 1377:23

minute 1055:5 1074:121074:13,19 1075:81079:23 1098:18 1173:61187:16 1190:22 1192:71288:20 1333:24 1364:11383:11

minutes 1120:13 1173:51198:6 1211:4 1231:151276:5 1290:11,141334:4 1343:8 1371:241383:21,21 1387:6

miserable 1175:16misguided 1060:17mispronounced 1127:5misrepresentations1228:12

missile 1182:5,10missiles 1182:13,14missing 1085:1mission 1059:24 1064:71089:22 1117:12

Mississippi 1193:7Missouri 1299:25mistake 1201:3 1206:18

1234:3 1324:5mistakes 1115:25 1176:9Mitchell 1134:14,15,16mitigate 1124:20mitigation 1090:81125:24 1126:121136:16 1367:11 1386:4

mixed 1056:9mixture 1330:20Moab 1070:21,231081:20 1148:141149:23 1152:10 1181:71187:6 1191:15 1272:181272:25 1273:5,8

Moab's 1295:9mobile 1070:3model 1249:14,16 1259:11332:8

modeling 1239:181319:7 1333:4

models 1142:1 1249:191249:20

modern 1103:11 1243:251308:5

modified 1136:141361:15

modify 1359:9Molas 1130:17mom 1207:23moment 1053:7 1231:141269:15

mom's 1205:6Monday 1048:18monetary 1132:181226:4 1300:15

money 1061:11 1071:71071:11 1075:231088:15 1109:121121:10,19 1141:91206:20 1211:15,151218:18 1223:8 1229:131236:2 1287:4,161291:9,13 1294:6,181299:19 1354:1

mongering 1213:8monitor 1063:8 1113:81124:21 1154:10,161162:8

monitoring 1063:231078:9 1107:5 1122:61122:14,17 1130:12

1190:12 1242:101267:23 1285:9,10,131285:18,21 1286:41287:15

Monok 1051:19 1329:111329:15 1332:12

Monok's 1332:7monster 1134:11Montana 1149:7 1194:221194:22 1201:21

month 1178:3monthly 1051:21 1335:6months 1066:22 1069:111097:23,23 1153:71174:8 1223:9 1236:31253:1 1257:19 1266:71266:7 1285:17 1341:1

Monticello 1108:2Montrose 1059:141084:6 1085:20,211087:6,12 1088:131118:20 1122:7 1149:191151:1 1173:16 1174:151174:17 1176:16 1177:91178:12 1179:231215:10 1241:181283:14 1306:9,14,171320:8 1380:7

Moore 1049:5 1355:24moot 1332:18Morgan 1112:21morning 1055:191056:18 1061:221064:22 1073:221080:19,24 1090:241108:6 1123:14 1127:71134:15 1139:4 1178:81387:18

morph 1202:3Morris 1147:4Morrison 1239:25Moscow 1182:3,4Motel 1150:19mother 1128:23 1146:211202:5 1208:9

motivated 1097:141126:10

mount 1108:18mountain 1049:14,16,181112:1 1129:14 1130:181150:22 1151:21,25

1152:7 1157:1,5 1168:71168:19 1247:4 1257:21257:8,10 1267:121272:12 1284:111287:25 1295:9,101309:20 1318:161326:10 1329:24 1335:41338:20 1349:1 1354:151361:8

mountains 1078:16,231129:13,17 1131:101141:14

mounting 1108:24Mouse 1144:15move 1072:10 1073:151103:6 1107:14 1109:21134:21 1148:121219:16 1245:3 1254:71273:8 1275:9 1282:31285:15 1321:15

moved 1073:10 1078:251110:2 1127:23 1133:181134:18 1143:16,171147:8 1157:23 1194:81204:16 1215:2 1274:31275:6,23,25 1285:3

movement 1172:9movers 1273:23moves 1082:6moving 1089:7 1093:241137:23 1256:151292:23,24 1294:231325:22

MRIs 1099:23MSG 1060:21MSHA 1069:18 1153:121153:12 1154:11

mudslides 1150:24Mullen's 1322:13Multicultural 1220:12multinational 1061:9municipal 1248:7 1304:7municipalities 1304:9munitions 1203:12Murphy 1177:24Murray 1214:25

NN 1051:1 1052:1 1053:1name 1053:20,211059:13 1061:22



1070:19 1073:18 1077:91084:5 1089:13 1095:151120:18 1123:15 1127:21137:3 1139:7 1143:131145:9 1160:19 1181:61198:10 1209:161213:22,25 1214:161224:5 1245:12 1256:101296:17 1301:141305:15 1329:13,161343:19

nameplate 1258:18names 1245:11 1279:11name's 1134:16narrow 1085:4nascent 1376:13Nation 1314:19national 1060:9 1123:91132:3 1172:9 1184:251190:1 1337:14 1357:5

nationwide 1060:181155:25

nation's 1130:1native 1093:2natural 1077:15 1078:141079:2,7 1094:101106:20 1107:221122:22 1138:23 1139:81241:16

naturally 1096:14,251147:21

nature 1067:18,191087:18 1089:5

Naturita 1062:141074:16 1075:10,131077:20 1101:4 1107:21132:13 1145:11,121147:1 1151:2 1159:201173:15 1175:11 1189:21191:7,8,18 1209:171211:9 1367:3,3 1368:2

Navajo 1112:5 1314:191315:3

Navajos 1134:12 1199:1near 1060:15 1071:191074:16 1088:2 1121:41175:7 1214:16,171217:1 1253:11,131297:20 1299:24 1316:91361:19 1382:10

nearby 1062:14 1159:19

1192:21 1215:13,191240:12

nearest 1240:11 1367:24nearing 1202:16nearly 1071:22 1363:151363:17

near-term 1087:13necessarily 1240:81254:1 1255:18 1267:21285:25 1325:231327:16 1337:4 1342:121343:2 1357:10,16

necessary 1075:101095:23 1113:7 1188:51355:9 1384:25

need 1058:10 1067:51070:16 1073:25 1083:71089:21 1092:3 1094:101100:12 1103:5 1105:131120:20 1122:211130:22,23 1142:121144:23 1145:2 1150:161154:15 1170:24 1171:51185:6 1188:10,101196:17,17 1203:161208:22 1218:21 1219:81219:18 1235:231256:15 1258:20 1261:21274:12,16 1285:231286:9 1291:25 1299:131303:15 1331:1 1338:71339:20 1340:14,161344:6 1353:1 1365:31370:13 1373:19

needed 1075:7 1082:211092:19 1191:10,111276:11 1277:221285:15 1335:12

needing 1122:18needs 1065:10 1124:181125:6,9,10,11 1136:201165:11 1197:21 1209:11262:21 1294:231297:25 1298:1 1301:211306:20 1366:2

negate 1195:14negative 1077:151096:21 1156:17 1226:51227:13 1269:3

negatives 1333:19neglected 1063:6

negligent 1122:1negotiate 1253:24negotiations 1254:2neighborhood 1059:171059:21 1202:9 1350:121350:18 1351:241369:21 1383:8,10

neighboring 1155:11neighbors 1066:2 1077:21134:8 1157:15,181217:18

neighbor's 1366:20NEPA 1286:3,15,20,241288:8,9,11 1353:11,121353:15,16,21,221355:9,14 1356:111357:15,16,22,241358:9 1375:20 1379:13

NEPA's 1288:12nephews 1205:22nerve 1154:3Network 1065:15neurotoxins 1060:24never 1060:7 1067:231084:13 1105:101125:25 1126:1 1134:121139:2 1144:9 1153:71154:14 1161:7 1162:21163:2,3 1164:121177:9 1187:3,211189:4 1233:14 1250:151265:14 1268:241294:18 1318:2 1320:161325:12 1326:121341:14 1349:6 1350:71350:7,10,25 1370:23

new 1078:5,11 1086:171086:17 1092:4,151098:16 1103:6,241113:17,18 1122:251130:16 1138:251148:21 1154:5 1161:91172:4,14 1176:18,201200:22 1210:21,221214:18,20,24 1218:131220:10 1224:16,171250:1 1255:17 1258:81328:19 1359:6 1386:20

Newmar 1147:11newspaper 1108:7newspapers 1186:12,13

nice 1147:6 1193:22Niederkruger 1204:6,8night 1173:20 1192:101366:9,10,18,241367:10,18 1368:31383:25 1384:4

nine 1069:20 1257:191269:8

Nixon 1182:4Noalani 1059:11,13noise 1060:13 1366:81367:1,5,23 1368:10

nominated 1168:5noncompliance 1265:111266:4,17 1267:23,241268:11,23 1270:10

nonconfidential1315:19

nondisclosure 1110:21noneconomic 1226:91227:2,12 1231:6

nonore 1256:3nonpartisan 1201:20nonpotable 1075:6nonproliferation1259:14

nonworking 1178:3normal 1085:17 1177:251360:19 1385:3,8

normally 1187:201321:19 1360:151367:22 1379:1 1386:21

Norphis 1197:14Norquist 1351:12,17north 1101:15 1214:211340:6

northerly 1093:20Northern 1067:12Northwest 1205:7Norwood 1139:7,181150:23 1151:2 1154:231155:5 1158:18,181293:14,14,16,22

notable 1108:10Notary 1048:25 1388:6note 1270:8 1295:191310:12 1339:14

notes 1052:3 1093:91104:16 1127:9 1139:141171:3 1187:2 1211:11212:18 1356:5 1380:11



notice 1048:16 1260:7noticeable 1299:10noticed 1198:14 1260:4,6notices 1372:14noticing 1177:17notification 1177:221178:4 1267:23

notoriously 1207:1November 1048:4,191130:10 1237:6 1267:151267:22 1312:141338:24 1339:8,161387:20,21 1388:17

Nowadays 1206:2NPL 1132:2NRC 1109:9,9 1115:151168:1 1271:8 1278:61362:22 1374:10,251376:18,25 1377:241378:17,19,24 1379:1,51379:12

NRC's 1366:3Nucla 1048:21 1101:41131:9,10 1145:111146:25 1151:2 1173:141175:10 1181:1 1189:21204:12,19 1206:5,171207:16 1294:3 1305:191367:3

Nucla/Naturita 1084:81088:10

nuclear 1071:18 1072:221090:6 1092:2,4,7,101100:21 1103:2,41108:16 1111:14,151115:11 1121:9,15,171123:10 1146:13,131159:6,9 1171:19,211182:9,14,22,24 1183:11183:20 1212:9 1216:171216:18 1221:121223:16 1288:1 1298:11298:2,10,10 1301:101301:11,23 1313:71374:3

null 1086:5number 1056:23 1059:21062:18 1081:3,161082:3 1083:1,6,71090:18,19 1091:11103:21 1132:23

1139:15 1171:231188:12 1228:11 1241:61300:20 1329:221368:23 1385:15

numbers 1125:18 1237:51335:24

numerous 1126:61228:17 1353:18

nursed 1060:4nursing 1200:10nuts 1184:11

OO 1053:1oath 1055:6 1142:22obfuscation 1143:8object 1248:12 1266:91283:14 1322:5 1324:3

objected 1282:22objection 1225:81242:23 1248:211261:23 1269:22,231270:4,9 1273:161275:24 1281:151282:18 1286:11 1323:71323:10 1327:211331:23 1333:6 1346:101350:1

objections 1297:2 1333:4objective 1095:17objectively 1143:4obligated 1198:3obligation 1089:10obligations 1273:31274:22

observations 1078:19obsolete 1082:5obstacles 1185:19obtain 1088:15 1173:24obtained 1075:8Obtaining 1075:10obviously 1233:71238:23 1258:13 1275:81281:9 1287:15 1325:41369:11,16 1382:22

Occasionally 1233:24occupation 1244:10occupational 1069:24occur 1057:20 1067:231103:14 1157:7 1380:14

occurred 1057:9 1069:19

1122:24 1135:12 1347:6occurrence 1076:11124:11

occurrences 1081:8occurring 1063:71096:14 1147:21

occurs 1158:10 1212:201268:12

October 1066:14 1246:251388:18

odd 1131:7 1198:16offer 1056:6 1137:251152:14 1175:10 1213:41213:14,20 1266:12,141305:4

offered 1152:6 1205:241226:25 1267:13

offers 1129:16offhand 1328:15office 1049:21 1110:91130:9 1187:10 1195:251216:8 1355:25 1356:161356:19

officer 1053:2 1055:31056:2,8,9,25 1059:111061:21 1064:201070:18 1073:17,201077:8 1080:18,221083:22 1089:121090:14,17 1093:61094:13 1096:4 1102:131104:18 1120:12,171123:13 1127:1,41129:5 1131:4 1134:141136:7 1137:1,4,6,91139:3 1143:12 1145:81152:18,23 1154:181160:18 1168:4,14,181169:5,19 1170:5,18,221171:17 1172:17 1177:91181:4 1198:6,9 1204:61207:20 1208:15 1209:61209:13 1213:13,17,221213:25 1214:4,8,121221:6 1224:4 1231:101231:21,24 1236:201237:4 1242:25 1246:241247:3 1248:15 1252:81252:10 1253:16,201256:10 1262:1 1264:211266:12 1267:3,11

1269:24 1270:8 1273:181281:17 1284:10 1290:61290:10,13,19,231291:1 1293:20 1296:111296:13,16 1297:171300:10 1301:12,151303:14,19 1304:21305:3,11,15 1307:9,191309:16,19 1318:151322:8 1323:13 1326:81327:25 1333:15 1334:91334:23 1335:2 1338:241343:6,10 1344:10,131344:16 1350:3,14,161363:21,25 1364:31373:4 1383:20 1387:61387:9,11,13

offices 1167:1,3 1197:91306:7

official 1376:17,18officials 1112:9 1125:2,31125:7 1162:3

offsite 1194:15 1240:31273:24

off-site 1273:9oh 1177:23 1179:111236:11 1250:6 1303:81334:25 1363:20,22

oil 1151:18 1196:9 1197:11197:6 1200:10

okay 1090:14,17 1137:71140:9,10 1145:11146:10 1152:20,231164:16 1168:151186:24 1194:181203:19 1214:121221:15 1222:16,231231:14 1233:10,15,191233:25 1234:3,241235:2,18 1237:2,101246:1 1247:21 1248:221249:22 1252:231253:20 1254:8 1257:241260:11 1263:161264:10 1278:8 1279:171284:19 1285:3,71288:20 1289:5 1290:41290:10,23,25 1293:131295:6 1300:12 1303:141312:4 1314:18 1317:241319:3,25 1320:24



1322:3,18 1323:31324:13 1329:10,15,171334:7 1335:2 1338:251339:17,24 1341:191343:10 1344:101352:11 1356:101359:12 1360:1,151361:5 1362:10 1365:241367:5 1368:15 1369:91370:21 1372:7 1373:171374:24 1377:121378:23 1386:7 1387:14

Oklahoma 1229:7Olathe 1122:8 1215:13old 1082:8 1106:111128:22 1143:151144:14 1146:16,17,231147:10 1161:11 1200:31208:7 1210:22 1298:131302:7

older 1128:21 1199:20old-timers 1206:10Olivia 1049:3omissions 1352:51377:19,21

once 1092:7 1128:51157:22 1158:9 1189:211200:17 1201:161214:22 1227:6 1265:161270:15 1287:1 1381:17

ones 1057:8 1071:161099:14 1139:17 1145:41176:25 1279:6 1315:201352:15

one's 1161:22 1176:91199:5,5 1216:91222:17 1289:5

ongoing 1123:241156:22 1171:23,241215:8

online 1092:4,7 1179:51193:25

onsite 1157:11 1273:25Ontario 1365:18on-site 1062:24 1074:171118:8 1242:13 1343:11343:17

open 1065:4 1068:1,51112:7 1138:1 1211:221310:8

opened 1112:11 1153:2

1202:17opening 1204:1openness 1065:7operate 1074:9 1078:131126:23 1135:171152:12 1155:6 1246:71386:19

operated 1080:6 1246:151252:16,16,25 1265:211265:25 1266:1,2,81267:1 1275:5 1345:191346:3

operates 1062:221345:10,24 1371:23

operating 1068:201082:19 1227:6 1228:201242:14 1245:20 1264:11265:18 1268:101363:18 1372:171381:22

operation 1056:221062:21 1077:7 1089:91090:7 1118:9 1124:221125:17 1153:181155:13,21 1157:21175:12 1177:171218:19 1219:131245:15 1266:241277:23 1310:12 1368:41368:16,17,18 1386:10

operations 1057:141060:16 1067:191074:12 1075:171077:22 1078:6,101079:20 1081:241085:17 1117:2 1126:81158:20 1245:22 1268:81368:24 1375:4

operator 1063:19 1064:11136:21

operators 1159:14operator/applicant1307:6

Ophir 1085:19Opila 1119:8 1149:9opinion 1062:3 1063:91100:11 1133:1 1136:41171:6 1190:5 1213:71230:14 1243:24 1244:21244:17,18,19,201255:10,25 1256:8

1273:20 1274:251297:22 1328:1 1378:131383:2

opinions 1102:2 1227:11227:3 1379:17

opportunities 1085:131091:2 1108:23 1138:21138:13 1205:25

opportunity 1064:241065:8 1080:20 1084:111089:15 1104:20,21,211137:11 1154:20 1162:81169:12 1170:16 1172:11172:22 1207:221208:19 1260:11 1319:61332:1

oppose 1061:15,241074:5 1220:13

opposed 1056:18,211065:19 1078:5

opposite 1172:6opposition 1129:91135:6

optimistic 1074:201282:13

option 1150:9 1219:20options 1073:1 1250:25oral 1053:7,17 1054:161055:9 1090:21 1152:211172:21 1231:11,131301:13

orally 1083:25orange 1069:10 1203:101291:2

order 1056:11 1065:8,111068:17 1153:231173:24 1286:15 1288:61322:14,15,16 1323:121325:8 1362:11 1365:41365:10 1381:111382:19

orderly 1070:1ordinary 1216:20ore 1056:23 1062:231067:11 1079:16,241086:6,24 1087:8,101099:21 1100:1 1103:91103:10 1113:22 1114:11118:4 1121:8 1124:11124:16 1125:9,171146:5 1147:24 1200:5

1200:5 1237:11,14,181237:23,25 1238:4,7,131239:4,23 1246:101247:9,12,15,17,18,201247:21 1250:4 1251:51253:4 1256:3 1258:221259:17 1298:2 1336:31336:19 1338:15,161352:22 1365:6 1367:191369:14,15,17 1370:131371:2

ores 1246:3 1247:12,131247:16 1248:2,10,251248:25 1250:6,131255:16,20,23 1256:2,41256:6,7,20 1257:1,5,71257:7,13 1258:2

ore's 1336:23organic 1226:20 1328:101328:11 1330:20,21

organically 1155:1organization 1065:151201:20 1221:8

organizational 1216:18organized 1376:24organs 1199:14 1202:81202:21

original 1135:5 1163:171163:17 1168:16

originally 1132:4 1181:81275:4

originated 1162:14Osborn 1350:23 1351:11osteoporosis 1199:21Ottawa 1365:18ought 1095:24 1127:171379:20

Ouray 1056:17 1061:231124:10

outcome 1162:2 1170:12outcomes 1161:22,23outcrop 1239:24outdated 1119:5 1213:10outdoor 1384:1outdoors 1181:13outgoing 1157:17outline 1373:18 1375:51378:8

outlook 1084:16outmigration 1137:19outmoded 1114:21



outreach 1360:231379:15

outright 1220:9outside 1118:10 1151:91154:23 1229:171235:14 1236:16 1254:61386:1

outsiders 1175:9 1180:251205:20

outweigh 1130:25outweighed 1331:14out-of-town 1205:1ovaries 1199:15overall 1117:12 1158:251286:2 1292:23 1384:9

overallocation 1191:17overarching 1146:241150:16

overdesign 1371:16overlaid 1375:5overlooks 1133:8overly 1074:20overreacting 1332:15overseas 1219:17oversee 1160:11oversight 1069:11177:12 1178:14 1179:51179:18

overworked 1196:15Owing 1123:23owl 1205:11owned 1253:22 1280:241300:6 1313:7

owner 1064:1owners 1078:11 1107:11128:11

ownership 1069:121126:19,19

owns 1067:2,4 1283:3oxide 1180:5,6o'clock 1173:20 1231:18

PP 1053:1Pacific 1205:7package 1116:8packed 1210:3page 1051:3 1085:11086:4 1115:7 1152:221179:6 1226:1 1228:151228:22 1229:5,10

1272:10 1337:251338:19 1349:5 1356:61356:21

pages 1051:2,2 1225:251226:4

paid 1078:3 1121:71126:1 1159:24 1169:151175:2 1249:3,17

pan 1140:19,24Pandora 1246:7 1257:151257:18

Paonia 1122:8paper 1179:24 1272:9papers 1315:11Paradox 1084:25 1085:11085:10 1091:8 1114:81122:7 1123:18 1130:61130:20,23 1136:121143:18 1147:18 1152:71154:21 1174:19 1189:21215:25 1216:2 1250:11278:15 1363:9 1367:11384:5

paragraph 1272:171273:17 1310:17

parameters 1268:23paraphrase 1262:19,21parcel 1142:4parcels 1288:20 1289:19Pardon 1356:17parent 1235:24parents 1106:7park 1229:16Parker 1061:21,22,231089:12,13,13 1090:161207:20,21 1208:17

parks 1210:11PARSONS 1049:12part 1060:17 1071:251081:1 1094:21 1103:111113:19 1114:6,71116:12 1119:19 1120:11143:20 1147:1,181169:7 1171:11 1175:121175:21 1180:8 1181:211182:3 1199:7 1201:141215:14 1234:18,221235:13 1243:201246:19 1247:5 1258:91262:5 1263:2 1268:131277:7 1287:19 1290:8

1297:5 1305:8,221309:16,18 1311:71317:9 1322:8 1325:101327:24 1331:131334:19 1338:4 1339:51342:1,20 1344:21346:11,16 1347:91349:13 1353:1 1354:221355:22 1376:4

partial 1349:9partially 1280:20,201319:20

participate 1068:14participating 1150:4,6participation 1068:151229:19,24

particle 1162:19,211199:22

particles 1059:161072:18 1078:201113:14,24 1162:91179:7,8,8 1199:4

particular 1086:3 1097:41101:13 1158:181170:19 1176:14 1186:71189:7,22 1190:91194:17 1195:4 1246:191276:11 1302:1 1333:221360:1

particularly 1053:251061:9 1124:11 1161:31239:4

particulate 1078:221154:13

particulates 1156:23,25parties 1048:16 1055:141065:17,19 1167:241364:16 1388:13

partner 1077:11parts 1059:20 1122:251195:18 1234:101314:17

party 1050:3 1315:15pass 1071:19 1130:181379:23

passed 1108:6 1110:171184:23 1185:141189:13

passing 1140:10paste 1308:15,18,24,251309:8,23 1310:18

1311:13,21 1312:211313:3

pasture 1155:11,12patent 1139:11pathway 1369:5pathways 1113:231114:7 1372:9,10

patience 1344:23patient 1198:16 1203:4patients 1108:4patronized 1179:9patted 1179:10pattern 1060:3 1062:221070:6,9

patterns 1078:16 1108:21138:12

pay 1063:21 1073:111169:24 1175:141188:14 1201:151229:14 1249:6,151371:18

paying 1064:3 1072:211076:17 1115:251169:21 1219:22

pays 1057:20 1169:3,111358:15

PCB 1153:22PDF 1055:24peaks 1078:18penetrating 1140:5penny 1126:2people 1053:11,15,231054:19,22 1055:91061:13,14,15,15,191063:8 1065:11 1068:171069:7 1077:1 1082:131084:12 1089:10,20,241090:20 1092:241097:15,19 1098:7,91100:6,12 1101:6,111108:18 1110:18 1111:81111:17 1117:14,161123:5 1125:13 1129:161129:20 1131:2,101132:22 1133:4,10,221133:24 1134:3,5,71135:15,18 1136:2,2,91137:21 1138:3,151139:20 1140:211142:24 1143:6,7,8,221144:22 1145:3 1146:23



1147:2 1150:4,201151:7 1152:11 1161:41161:17 1162:18,241163:12,18,19,201164:2,3,3,21 1165:141166:20 1169:141172:13 1173:9,14,141173:15 1174:3,81175:2,7,10,11,201176:6,11 1180:171181:19 1182:16,251184:20 1185:19,251186:2 1187:18,201189:3 1190:4,131194:24 1195:12,241196:2,4,7,9 1197:9,161197:16,25 1198:4,171198:18 1200:7,11,181201:6 1202:25 1203:131203:24 1204:3,10,121204:19 1206:121207:17 1208:231209:20,21,24 1210:1,71210:14,16 1211:3,51212:2,7,10 1213:11220:16 1221:4 1227:151229:1,2 1233:8,81234:6 1236:10 1241:81242:4,18,21 1245:241249:15 1255:241256:19 1259:101261:15 1263:25 1264:91268:5 1291:11 1292:141292:23 1293:2,91294:13 1295:23 1296:31297:10 1298:21,241299:6 1300:19 1301:231301:24,25 1305:201330:9 1359:2 1367:221374:20 1379:20 1381:91381:18

peoples 1119:24people's 1140:12,121198:25 1386:3

percent 1092:1 1102:171103:3,18 1111:161138:9,11 1141:151145:17,17,18,19,201147:19 1149:2,161152:15 1171:101201:22,22,24 1306:1,4

1306:24 1307:1,4percentage 1101:10perception 1109:211360:16 1361:2 1362:2

perceptions 1105:51360:4

perfect 1174:25 1295:15perform 1125:23performed 1138:10period 1058:7 1092:151099:6 1183:12 1185:81236:15,22,23 1238:211238:22 1262:7 1265:191270:16 1271:16 1282:41287:13 1318:18 1341:21342:3,8 1345:16,201347:6

periodically 1278:5periods 1063:5 1181:201247:23

peripheral 1099:25permanent 1072:241085:12 1227:8

permanently 1072:16permissible 1113:1permission 1068:17permit 1057:6 1058:1,121058:16 1059:1 1076:101082:7 1085:22,251086:2,5,19 1087:111088:1,4,6 1089:2,7,71093:4 1097:11 1122:51129:10 1160:151206:23 1213:111264:17,19 1281:51282:6 1286:6 1287:61287:18 1288:7 1319:171319:18 1324:141327:19 1330:8 1336:71336:8,20,24 1345:191368:19 1370:4 1371:131386:8

permits 1270:11 1317:181328:24 1358:3 1372:1

permitted 1114:121180:19 1216:15 1267:21283:6 1305:24 1347:4

permitter 1235:6 1385:8permitting 1058:231059:7 1060:5 1061:161089:11 1097:10 1103:7

1195:4 1264:11,141266:16,24 1280:151282:4,5 1301:1 1314:41318:20 1319:4,91325:13 1332:14,191333:3 1335:6 1337:131354:1 1359:25 1360:191369:24 1374:21,251381:8 1382:3 1385:23

perpetuity 1189:51191:12 1192:8,11,191194:12 1197:23

perplexing 1109:3person 1075:21 1100:151110:8 1145:19 1162:221167:5 1173:6 1179:171187:21 1196:251198:15 1203:5 1236:81245:13 1255:251269:12 1290:22 1293:71309:25 1348:171355:25 1359:6

personable 1177:14personal 1059:141065:21 1098:241127:20 1176:5 1200:151208:25 1255:9,25

personally 1097:131146:4 1147:4 1151:101153:25 1204:1 1212:11

persons 1061:7,111245:10

perspective 1058:231065:21 1112:191116:16 1331:10

perspectives 1129:8pertaining 1106:181115:21,22

pertinent 1223:20Peterson 1290:15,16,171290:18,22,25 1291:4,51293:21

Ph 1270:2,12pharmaceutical 1061:10phased 1310:12,18,21,251311:6,7,8,17

PhD 1050:2phenomenon 1366:25Phil 1119:5 1306:11Phillips 1198:9,10,10phone 1168:24 1213:21

1213:23 1214:2,5,10,131224:5 1293:19 1307:101332:23

phonetic 1197:14phosphorus 1199:24physical 1060:251109:22 1280:4 1283:9

physician 1128:3physicist 1060:7physicists 1375:25pick 1111:23 1163:41303:8

pickaxe 1200:4,14picking 1187:3pickup 1371:5piece 1180:14 1279:23pieces 1106:2 1174:6pile 1070:24 1071:241072:3,6,13 1271:21274:2 1298:11

piles 1076:21 1095:51098:20 1302:6

piling 1243:9pillows 1203:18pilot 1181:24 1182:1Pinon 1048:6 1051:13,171051:24 1052:4 1053:41061:16 1062:21 1067:51068:11 1074:5 1077:131078:20 1079:3,14,171080:15 1085:3 1086:131088:18 1091:17,241094:15 1102:20 1104:31104:24 1112:18,191115:1 1120:5 1123:171132:15 1145:151154:21 1158:8 1160:41178:6 1215:10 1220:141220:24 1226:15 1231:21248:14 1278:10 1279:81279:9,10,14 1283:221309:13

Pioneer 1278:24 1282:151283:9,12

pipeline 1335:111342:10 1343:3

pipelines 1342:161353:16

Pirazzi 1152:6pit 1068:1pitted 1292:25 1296:2



pitting 1291:10place 1072:19 1073:141084:25 1085:2,101086:17 1094:221095:23 1112:121114:16 1115:2 1127:251128:7 1131:3 1144:151154:8 1163:21 1168:131169:9 1187:24 1196:231206:1 1207:5 1210:211223:21 1260:19,221272:6 1276:11,12,131294:9 1295:17 1388:8

placed 1091:14 1106:201136:19 1341:16

Placerville 1133:11147:8,25

places 1068:24 1084:181109:7 1114:22,251136:4 1221:11 1292:191304:11

plague 1218:6plain 1216:25plan 1051:17 1057:191098:19,22 1106:201123:20 1124:15,24,251125:10,12,24 1126:251189:7,11 1190:101218:15 1276:6,7,9,111276:14,15,20,22,241320:3,7 1321:121322:3,12,14,16,22,251323:9,10,24 1324:4,61324:11,20,21,241326:4 1334:7,11,121348:2 1361:15 1372:171381:12,21,22,231384:1

planet 1296:7 1300:2planned 1077:4 1093:11345:10 1346:3 1361:161382:15,20

planner 1306:9,17planning 1071:1 1103:71174:16 1176:171363:12 1380:2,6

plans 1073:14 1087:131113:22 1136:151189:16 1242:6,7,91257:17 1325:251326:17,21 1334:13

1372:20 1383:191384:20 1385:9,91386:2

plant 1087:18,22 1092:71092:10 1097:7 1123:231136:21 1155:7 1189:181190:20 1192:3 1194:71212:9 1265:10,18,201265:25 1268:241270:22 1298:101301:23 1372:25

plants 1084:22 1092:2,41159:9 1171:22 1182:251183:1 1194:5 1208:211212:22 1268:22 1298:21301:10

plastic 1080:4 1222:5plateau 1246:3,10 1247:91247:11 1248:2,251257:13 1258:1

play 1115:8 1138:201166:5 1181:21 1216:41354:21,24 1355:3

player 1155:22please 1064:15 1073:121136:23 1177:3 1205:31220:22 1221:2 1234:151248:19 1267:21 1269:41269:16 1272:171317:20 1326:7 1333:141337:22

pleased 1064:24plume 1069:10 1346:22plummeting 1215:7plus 1088:19 1091:231092:21 1155:21

plutonium 1199:171303:6

PL-AR 1272:10pockets 1126:16,21point 1055:8,22 1057:221099:5 1118:22 1144:31144:6 1162:16,231168:24 1170:5 1171:161191:17 1192:8,201195:8,20 1202:11204:25 1205:18 1209:91218:13 1219:4 1231:181235:25 1236:241251:15 1256:5 1261:181262:11 1270:14 1272:3

1291:8 1292:21 1305:141305:14 1332:18 1358:71362:21 1375:14

points 1061:25 1119:151225:13

poisoned 1223:4poisoning 1194:24poisonous 1072:5poisons 1060:20 1193:10pole 1284:22 1285:3police 1177:9 1381:8policies 1220:6policy 1184:25 1201:11337:14

politically 1097:14pollute 1075:20 1085:18polluted 1078:131208:12,12,12,13

polluting 1101:24pollution 1059:231060:13 1117:191165:16 1319:5,101327:7,11,14,15,171328:7 1330:16 1369:61369:24 1370:1 1372:11372:14,21,24 1385:13

pollutions 1215:18pond 1096:9,15 1114:171342:11 1383:9

ponds 1076:2 1080:21096:8 1124:6,81146:18 1192:5 1310:131345:17

pool 1146:18 1258:12poor 1078:1 1125:241126:13 1133:9 1238:8

populace 1144:10population 1088:201123:5 1138:4 1149:161152:15 1184:17

portion 1071:17 1096:151270:21 1274:241339:22 1357:2 1362:181375:10

portions 1253:7pose 1242:2posed 1271:8poses 1129:10position 1062:201119:16 1143:4,61253:8 1261:11 1263:13

1355:15 1376:12positively 1145:17possibilities 1278:31324:18 1343:16

possibility 1138:171304:9 1334:17 1347:231362:15 1381:4 1384:21

possible 1057:23 1061:41079:3 1089:17 1100:131109:23 1110:24 1124:31156:18 1163:23 1185:31189:18 1228:2 1303:11304:5

possibly 1088:5 1126:141191:19 1200:25 1254:21257:3 1271:18 1302:161325:21 1330:111334:21

post 1220:5postcard 1177:21 1178:2posted 1300:19potable 1074:13 1079:4potassium 1199:16potential 1051:141071:13 1081:5,71113:9 1114:15 1117:21123:18 1142:1 1192:21217:4 1227:25 1238:251242:19 1274:131275:20 1276:171279:22 1289:191295:21 1304:4 1309:141324:21 1335:171339:12,18 1363:11381:14

potentially 1126:71237:16 1352:20

poultry 1155:7pound 1218:16,22 1219:31219:8 1246:14

pounds 1306:1pour 1153:24power 1084:22,24,241092:8 1123:10 1138:61142:11 1146:9 1159:91171:22 1182:24 1183:11183:3,21 1195:61208:21 1212:9,21,221222:13 1284:22 1285:31298:1,10 1301:10,23

powerful 1179:5



PowerPoint 1324:19Powers 1112:1PPE 1201:3PR 1278:10practical 1259:1 1385:20practicality 1300:2practice 1157:16 1249:241249:24 1352:1,4

practices 1082:5,17,241083:5 1093:11,12,161104:8 1308:6

Pray 1330:1,8 1331:31385:4

pre 1108:13 1154:6,7precautionary 1061:18precedence 1064:9precious 1094:25precipitation 1343:5predict 1095:6 1202:16predictor 1063:25predispose 1170:19predisposition 1169:21preface 1131:23prefer 1207:7preferably 1061:17preferred 1273:24pregnant 1217:16preliminary 1335:101343:16 1351:22

premature 1127:17premise 1055:18preparation 1314:111376:9

prepare 1235:15prepared 1051:21 1191:81234:5 1321:21 1322:11351:15,17 1376:3

prepares 1321:19preparing 1125:11230:16 1351:14

presence 1129:191138:17

present 1053:10 1063:81096:25 1100:7 1106:241107:17,24 1138:131212:18 1297:12

presentation 1240:51334:15

presentations 1239:15presented 1141:61166:19 1240:22 1377:9

presenting 1170:13presents 1094:17present-day 1132:2,7preservation 1094:241235:11,13 1237:71356:16,19 1357:5

preservatives 1060:23preserve 1089:231269:23

preserving 1117:13president 1145:101151:24 1165:181198:11 1245:18

press 1051:8 1246:17,221247:5

pressing 1095:3pressure 1070:2 1197:61220:15

pressured 1070:17presume 1322:20pretty 1183:25 1186:131191:3 1195:21 1245:231328:20 1332:171336:24 1361:181365:14 1367:12,241376:18 1383:4,51385:11

prevailing 1123:231130:5

prevent 1062:10 1080:81099:8 1229:4

preventing 1361:18previous 1161:181362:23

previously 1090:201214:22 1231:25 1232:41250:11 1358:12

price 1082:22 1105:121109:1 1114:2 1123:241124:2 1126:3 1159:191184:16 1218:21,251219:2 1246:13 1247:231324:13 1325:4 1336:2

prices 1087:19,201218:20,25 1247:251248:4

pride 1127:24Priestley 1048:23 1388:41388:20

Primarily 1156:20primary 1095:17 1146:6

principle 1061:18print 1061:2 1084:5printed 1227:21prior 1148:25 1149:201161:2 1210:17 1330:191380:24

Priorities 1132:3priority 1120:22prison 1196:25 1197:3,3pristine 1292:20pristineness 1181:14private 1065:21 1073:31151:17 1159:8 1173:251189:21,23,23 1201:11273:3 1280:20 1281:81284:7 1286:9,191352:15,16

privy 1176:1pro 1386:1probability 1057:121059:4

probably 1074:23 1089:41093:24 1108:101114:24 1142:6 1164:31171:2,10 1181:91188:18,19 1197:51199:17 1235:221241:12 1258:181261:14 1280:7 1285:171287:13 1292:7 1293:31293:4,4 1298:31300:18 1307:16 1321:11321:2 1324:20 1325:21334:19 1339:5 1354:51365:14 1367:19,201368:1 1376:6 1377:21

problem 1067:241093:19,22 1094:11109:17 1124:20 1132:11132:2 1146:12,231147:20 1148:161166:22,23 1167:71180:12 1189:22,23,241190:1,2 1216:71269:12 1301:19,24

problematic 1075:11problems 1066:61067:16 1081:7 1161:121165:15 1167:101172:10 1194:111199:19 1202:10,10

1206:13 1216:15 1218:61220:19 1225:101362:23 1382:24

procedure 1095:241127:13 1196:2 1332:10

procedures 1095:201242:8,9,10 1381:15,16

proceed 1125:8proceeding 1234:141260:4,6 1261:191272:24

proceedings 1262:251314:14 1387:19 1388:7

process 1053:6,171058:24 1060:5 1065:41065:18 1067:8 1073:161077:5 1078:2 1079:211079:24 1080:14 1087:41088:23 1089:7,81091:6,10 1092:15,161092:18,21 1095:41096:16 1097:101114:13 1115:9 1117:41117:25 1118:7 1119:151123:25 1125:181127:16 1128:5 1139:131152:21 1169:8,181170:3,25 1171:12,131171:20,23 1172:7,211173:9 1174:16 1176:141176:17 1177:17,191178:12 1196:201199:11 1221:24 1230:61248:10 1249:4,16,171256:5 1257:13 1258:11261:10 1281:111282:10 1287:10 1288:91301:1 1307:2 1328:21328:19 1330:231331:12 1332:13,14,171333:25 1344:201353:15,22 1358:131362:23 1372:20

processed 1086:24,251103:11 1118:171229:10 1258:15 1306:21307:4 1330:2

processes 1128:9 1291:8processing 1056:221066:13,16 1079:81086:6 1087:10 1088:18



1092:19 1098:201099:19,21 1100:4,101103:13 1114:11,121120:9 1124:6 1155:71195:5 1246:3 1248:71248:23 1249:25 1250:51253:4 1255:25 1259:41281:5,7 1320:3 1327:21365:7

procurement 1105:10,171107:11

produce 1103:2,211114:4 1154:25 1155:61218:20 1247:12,15,171253:9 1258:18 1317:141317:17 1336:3 1383:5

produced 1118:5,24,251251:24 1272:24 1325:71329:21

producer 1067:1,21218:25

producers 1352:20producing 1258:131322:4

product 1079:9 1114:31183:23 1188:10,20,221188:23 1238:201297:24,25 1299:241301:7 1353:5 1365:12

production 1086:151087:14,16,19,231092:5 1155:21,241158:3 1159:7 1190:231247:7 1248:24 1255:151317:15 1320:19 1323:51324:22 1325:211326:25 1336:4 1368:191381:24

productive 1068:61073:5

products 1189:21 1301:91365:16

professional 1048:231129:14,23 1175:31388:5

professionalism 1120:3professionally 1179:251275:14

professionals 1100:81292:8 1296:4

profit 1070:16 1126:1

1149:13 1188:7 1196:121218:16,20 1219:21247:19 1291:14,18

profitable 1058:191079:21 1084:161218:22 1219:9

profit-allowing 1188:6profit-making 1188:5profound 1203:15program 1105:10,171107:11 1108:15 1155:31155:16 1201:181319:16 1328:14 1329:81331:7 1336:8 1357:4

programs 1108:17progressives 1216:9prohibition 1079:19project 1049:12 1077:161091:7 1094:17 1096:11109:12 1112:23 1113:81116:6,8,21 1173:171176:11 1216:221234:10 1235:3 1237:151237:19,22 1242:41251:8 1255:7 1257:21257:10 1263:221271:10,11,12,15,161273:21 1274:241277:12 1280:16 1287:41287:25 1316:121319:16,18,19 1325:221325:25 1328:25 1330:81331:2,16 1336:211338:5,5 1351:31353:13,21,23 1354:171354:23 1356:12,13,241358:1,2,13,16 1359:151360:7,11 1363:4,91365:20

projector 1373:3projects 1331:21 1351:191352:17 1359:25

project's 1357:20promethium 1199:23promise 1082:13 1106:241140:21

promised 1191:22,22promises 1215:6 1216:3promising 1217:10promote 1060:1 1164:14promoted 1257:4 1300:5

promoting 1079:111180:2 1257:6

promotors 1088:6proper 1173:2 1177:18properly 1095:3 1170:131201:10 1285:141332:20 1333:201338:10

properties 1067:3 1199:61253:12

property 1060:151085:16 1110:25 1124:11124:5 1126:20 1215:71227:14 1239:18 1240:91254:3 1279:23,251280:6 1285:11,161352:17

proponent's 1251:8proposal 1076:4 1105:51113:9 1137:15 1217:31231:2 1249:23 1326:11330:4

proposals 1230:91286:25

propose 1141:21proposed 1056:201063:14,18 1074:71075:3,8 1076:201077:13 1080:1 1094:151095:9,9 1104:241130:6 1154:21,251156:15 1159:17 1160:41160:16 1220:21 1225:51225:6,19 1233:111256:21 1330:1 1338:51369:13 1385:15 1387:1

proposing 1298:22prosper 1102:5prospered 1079:10protect 1058:14 1060:11060:10 1064:171069:24 1070:15,171089:22 1097:5 1105:41122:3 1123:21 1131:161131:19 1162:1,161166:3 1170:9 1185:181187:24 1189:191190:10 1196:101197:17 1216:20 1222:81222:22

protected 1109:1

1124:18 1139:2 1222:51368:12,12

protecting 1061:7 1064:71117:13 1122:1 1191:2

protection 1078:141109:15 1117:171166:13 1200:16

protections 1157:161187:25

protective 1116:8protects 1064:12protesters 1211:18protocol 1055:18prove 1061:17,181072:11 1076:111202:24

proved 1111:16proven 1079:20 1080:4,91131:25 1155:20 1189:41197:12

provide 1061:13 1075:51088:17 1124:19 1164:21220:3 1224:25 1228:91234:20 1249:25 1258:31258:6 1308:5 1346:61346:13,17,20,241352:8

provided 1061:3 1111:191136:13 1227:201230:21 1233:231234:13,18 1264:171270:1 1316:11 1317:61317:8 1347:3,8,241348:1,11,20 1350:91355:20 1375:2 1378:181378:25 1380:20

providing 1117:161155:14 1158:4 1372:24

provision 1114:5proximity 1280:11,23psychology 1227:15public 1048:25 1049:241051:2 1053:5 1054:141054:16 1056:4,71057:6 1059:25 1060:11060:3 1065:5 1068:131068:15 1070:141083:12 1091:2,41095:14,16,22,251103:16 1104:221105:20 1108:25 1109:3



1113:10 1115:24,241116:8,20,25 1117:171119:13 1120:2,8,23,241121:22,24 1122:1,41123:11 1124:201129:11 1130:111136:16 1140:15 1158:11166:10,11 1168:241169:13 1172:211176:21 1177:1,4,71184:5 1189:15 1197:21213:8,14,20 1216:131228:23 1229:19,231230:11,19 1231:11,131240:3,22 1250:241261:19,24 1269:211278:13 1293:16 1297:81297:14 1301:13,191305:20 1307:10 1313:11315:10,14 1319:121352:12 1360:4,15,231361:2 1362:2 1375:121379:15,15 1380:151386:1 1388:6

publicize 1164:8publicly 1315:24 1316:2public's 1229:21 1230:15Puerco 1298:6,15,17pulling 1293:15pulls 1206:18,19pulmonary 1154:4pulverized 1221:20pump 1335:11 1342:4,91342:13

pumping 1335:101354:25

pump-back 1277:19pun 1134:1purchase 1109:23purchased 1355:7purchasing 1138:6purely 1066:9purpose 1116:19 1208:221296:20

purposes 1099:22 1381:8PURSUANT 1048:16pursue 1215:3pursuing 1088:3pushing 1188:9put 1053:11 1054:81106:1 1120:21 1139:24

1144:25 1153:241156:13 1180:3,201187:24 1189:8,9,111196:20 1197:251198:24 1203:18 1218:31219:2 1269:8 1276:91281:7 1285:10,13,181286:6 1306:12 1309:61319:15 1332:231333:21 1342:2,191359:4,13 1372:15,161374:17 1375:161376:14,23 1377:6,161379:10,12 1382:211384:14,20

puts 1156:15 1174:7putting 1072:21 1164:111189:17 1193:121195:12 1247:25 1272:31286:24 1332:21 1351:21351:18 1375:1 1384:22

puzzle 1106:1 1174:7puzzling 1174:13pyramid 1180:9p.m 1198:8,8 1231:20,201290:12,12 1344:21,211387:19

P.O 1049:13

QQuade 1093:6,7qualifications 1350:5qualified 1108:14qualify 1108:8 1244:11quality 1060:14 1086:181091:8 1092:24 1093:11105:1 1117:16 1133:91190:12 1194:5 1265:121265:12 1292:11,12

quantifiable 1227:131228:1

quantified 1121:21quantify 1226:2 1228:2quantities 1060:22quantity 1113:3quarreling 1307:19quarterly 1236:4Queen's 1352:16question 1096:8 1100:181113:4,4 1115:7,171116:3,10,24 1117:24

1118:14 1119:2,151145:15 1164:4 1171:141188:4 1191:13 1219:241234:15,16 1236:171241:3,4 1243:11248:16,19,21 1250:21250:16,18 1259:6,161269:3 1270:9 1273:191274:14 1281:181283:24,25 1285:221300:14 1313:14,211315:17 1317:20,21,231318:11 1321:8 1323:91323:16 1324:4 1327:231333:8,9 1334:2,91337:23 1342:22 1350:11356:9 1361:2 1366:5,71373:5 1385:22 1386:6

questionable 1166:7questioned 1360:2questioning 1095:201186:18 1248:131266:10 1305:17 1322:6

questions 1055:9,111075:2 1095:3,181115:3,6 1184:51185:21 1190:9,11,111211:21 1231:19 1271:81300:11 1322:1,101323:14,15 1324:131333:22 1363:19,231364:7,11 1383:11387:7

quick 1196:16 1211:1quicker 1055:7 1249:13quickly 1102:25 1303:25quiet 1138:1 1366:18quite 1070:22 1102:211114:1 1149:11,121160:21 1171:231174:13 1184:121243:19 1291:111330:15 1377:1

quote 1087:4 1112:20quoted 1333:11

RR 1049:2 1053:1race 1183:11racked 1069:23radiated 1132:25 1133:6

1303:9radiation 1068:221096:22,23 1106:181108:16 1112:25 1113:21115:22 1122:6 1123:41128:24 1131:24 1132:31139:21 1140:1,3,4,51147:21 1157:6 1179:151193:11 1194:151198:17,22 1199:2,121199:24 1203:1 1207:71217:17 1223:17 1225:11237:10,13,17,231238:4,17,22 1239:111239:12,16 1240:221243:12,21 1264:81302:4,6 1327:8,191328:14 1329:8 1331:71336:8 1375:23 1376:2

radiations 1199:18,22radio 1099:22radioactive 1048:61057:3,8,15 1062:241079:18 1080:2 1096:251099:20,21,24 1105:181107:5,14,20 1109:191111:10,14,18 1112:41112:14,22 1113:141115:20 1117:8,251118:2,7,11 1119:81123:21 1124:171133:12 1138:18 1162:81199:10 1201:101202:18 1207:5 1212:141212:16 1226:12 1227:71227:9,12,23 1241:151248:8 1298:7,141299:4,5 1301:181302:14,17,21 1303:41304:11 1306:2,3,10

radioactively 1110:25radioactivity 1058:6,7,91059:4 1121:2,31224:10 1306:231386:11

radiological 1349:22radionuclides 1141:201180:19 1304:8

radium 1199:22 1265:7,91265:16 1270:3,13

radius 1151:8



radon 1068:2,7 1147:211147:23 1148:2 1153:51153:9,13 1154:121180:20,23 1215:221238:10 1271:1 1288:7

raffinate 1330:19railroad 1085:2rain 1180:23rainwater 1095:7 1193:1raise 1056:4 1323:5raised 1095:18 1144:121204:14 1212:131353:20

ramp 1324:1ran 1147:9 1194:25ranch 1143:16 1294:9rancher 1155:11ranchers 1147:17,181215:20

ranching 1133:18 1134:61158:20 1175:111226:20 1295:21

Randy 1061:21,23range 1187:4,5 1295:221337:2,16 1347:21

ranger 1181:12 1186:221186:25

ranges 1121:11 1241:8rapid 1082:7rare 1104:21rate 1075:5 1085:51087:16,21 1110:181114:14,19,21 1125:201241:22 1370:12

rated 1159:10rates 1327:2 1368:19rating 1200:9rational 1056:11ravages 1060:11raw 1086:23 1087:81096:16 1205:16

Ray 1150:19reach 1121:17 1233:51235:25 1250:151347:15

reached 1123:4 1152:101347:13

react 1198:17reacting 1364:15reactor 1108:16reactors 1103:6

read 1054:7,15 1077:101100:14 1112:8 1116:221143:25 1179:231186:12,18 1228:101243:19 1248:181261:21 1267:211272:14,16 1285:11310:2 1313:2 1317:191317:21 1318:191329:20 1331:25 1332:11335:7 1337:24,251338:23 1339:5,22,241349:12 1368:5 1371:20

readable 1054:4readily 1219:14reading 1054:6 1115:41176:1 1182:20

readings 1128:5,8,25ready 1083:20 1127:181149:2 1261:16 1296:12

reagent 1367:20 1371:1real 1061:13 1080:91105:15 1109:15 1110:41110:13 1158:251176:12 1182:21 1188:91190:9,11 1193:15,161193:16 1196:161201:25 1206:3 1211:11217:17 1218:5,231226:10,13 1227:221283:12 1292:141301:20 1303:3 1328:41328:5,6 1359:19

realistically 1259:9reality 1063:9 1109:201111:9 1141:12 1207:21207:3 1224:14 1261:71301:21

realize 1068:21 1097:221169:9 1287:1

realized 1291:6really 1064:25 1066:7,211066:23 1067:5,61070:7,12 1073:251074:20 1098:8 1100:61104:22,22 1105:91106:22 1134:7 1140:171143:5 1151:18 1154:101161:6,7,16 1162:21163:3,3,8,8,17,201164:4 1166:16,25

1172:12 1175:22 1180:41182:17,20 1183:5,151184:6 1185:17 1187:181187:25 1188:4,12,241190:17 1191:23 1192:11192:23 1193:231194:21 1195:101196:10,17 1198:151202:14,24 1206:21215:24 1219:181224:12 1226:16,181230:24 1242:20 1250:21255:6,8 1256:241275:9 1288:15 1291:71291:15,19,24 1292:51292:10 1293:3 1294:181296:1 1304:22 1307:71318:10 1330:231353:14 1363:20 1366:21370:5,23

Realtor 1109:25 1110:71134:17 1135:19

Realtors 1110:15Reams 1145:8,9,91151:24

rear 1120:13reason 1065:7 1068:101088:3 1094:21 1159:81160:15 1168:2 1170:21182:15 1208:201260:16 1261:4 1283:121285:7 1289:16 1297:111297:24 1317:25 1318:31336:15

reasonable 1058:211092:8 1216:23 1330:31338:8,9

reasonably 1058:221324:23,25 1328:21

reasons 1058:25 1074:61074:22 1087:251102:22 1104:14 1126:91145:24,25 1174:11283:16 1304:181368:22 1370:13

RECA 1106:12 1108:141175:2

recall 1173:18 1239:101245:11,12 1252:12,141254:17 1265:4 1267:241312:25 1313:25

1318:10 1320:17,211322:15 1330:7 1332:201332:22,25 1335:19,211342:15 1348:3,231354:8 1360:2,5 1361:61364:8 1369:9 1371:251382:25

receive 1095:10 1108:111124:3 1132:17,181214:15 1249:3 1282:161348:18

received 1053:5 1090:191117:9 1168:24 1178:41268:5 1269:11 1282:191350:21,25

receives 1269:12receiving 1108:15 1229:61307:7

recess 1120:16 1198:81231:20 1290:121344:21 1387:17

recharge 1074:21,221075:4

reclaim 1107:3,8reclaimable 1383:2,3reclaimed 1072:231106:16

reclamation 1051:241084:11 1106:211107:15 1117:6 1125:151273:25 1276:14,15,171310:7 1347:12 1353:111354:22 1355:4,6,131375:5

recognize 1064:41067:18 1129:251130:22 1147:201246:22,23 1267:151268:2 1329:14,18,19

recognized 1063:16recognizes 1357:5recollection 1243:11,181330:12 1332:3

recommend 1090:111094:18 1120:5

recommendation 1119:71170:15

recommendations1119:21

record 1053:2,21,221056:1 1061:20 1065:6



1068:23 1077:10 1078:61080:7 1093:8 1132:31137:8 1155:20 1158:71247:10 1269:18 1272:91272:10 1284:9,15,171296:21,25 1297:4,61309:17,18 1322:91323:13 1334:24 1344:41348:24 1387:15

recorder 1186:23 1187:4records 1143:23 1159:5recourse 1099:141157:19

recover 1107:14 1328:91331:11

recovery 1374:23recreate 1206:4 1207:51295:7,8

recreation 1079:111085:14 1213:3,3,3,41226:21,24 1296:5

recreational 1138:21147:6

recycled 1125:17red 1078:17 1130:18redesigned 1270:23redirect 1267:4 1387:9Redlands 1127:24redox 1146:7reduce 1188:11 1328:121385:14

reduced 1235:17,181388:9

reducing 1330:2reduction 1153:15Reed 1134:14,16reels 1382:9reevaluating 1171:21refer 1249:19 1285:201318:18

reference 1265:1 1315:161372:5

referenced 1147:11referencing 1228:131328:3,4

referred 1279:10,121306:18 1360:9 1361:3

referring 1119:1 1243:21243:6,8 1283:201316:4,6 1343:211344:5

refers 1096:6 1285:19reflect 1177:16 1178:141251:18,25 1261:71262:3

reflects 1251:21refresh 1237:2 1332:21361:5

refurbishment 1253:8refuse 1140:25refused 1230:2regard 1093:12 1095:251337:5

regarding 1095:201123:17 1189:7 1213:91304:5,14 1306:101314:19

regardless 1326:22regards 1120:10 1158:21199:1

region 1062:7,19 1063:11064:8 1065:22 1066:161071:19 1073:8 1078:151078:25 1079:10,241085:17 1088:8 1104:61104:11 1107:121108:20 1117:2 1130:11131:8 1132:23 1160:201161:5 1163:8,121164:7 1214:21 1220:161220:17 1223:3 1253:41300:18 1380:9

regional 1065:16 1117:81117:21 1155:2,22,231156:12,12 1158:221160:3,8 1364:23,24

regionally 1105:1region's 1079:4 1158:25Regis 1149:7registered 1048:231139:10 1388:5

regret 1220:25regs 1096:12regular 1053:14 1063:41096:18 1098:131142:15

regularly 1093:15regulate 1113:7regulated 1096:111117:5 1149:4

regulates 1117:3 1329:4regulating 1078:9

1276:25 1329:3regulation 1090:61224:20 1262:18

regulations 1064:6,101068:2 1086:17,18,211098:13 1099:12,131103:12 1106:181113:18 1115:17,19,211115:22 1116:101126:17,24 1151:61153:19 1154:8 1158:21161:10,11 1166:81172:4,8,14 1181:221184:23 1185:12,16,171187:13,14,23 1189:121189:25 1197:8 1210:211219:15 1220:221224:17 1264:8 1266:171266:19 1268:191336:25 1337:1 1357:151374:6 1377:25 1378:11386:18,20,22 1387:2

regulator 1120:2 1160:11regulators 1062:9 1080:81216:6,19

regulatory 1057:241078:12 1095:201107:25 1115:11 1120:41127:12 1148:201149:10 1168:221171:12,20 1216:171221:12 1223:161268:14 1282:24 1288:11374:3

regulatory-driven1261:10

Rein 1056:13,16reinstated 1093:4reissue 1170:16rejected 1158:9 1273:14related 1051:16,191052:6 1088:11 1093:221249:22 1375:211388:12

relationship 1069:21089:4 1131:24

relative 1057:15 1289:111364:11

relatively 1087:191367:17

relatives 1174:3,4,9,10

relay 1127:20release 1051:8 1069:9,131077:21 1246:18,221247:6

released 1059:16 1094:91118:23 1298:13

releases 1076:7releasing 1062:241094:11

relevance 1248:131266:10,11 1269:231323:11

relevant 1142:8 1262:171262:24 1264:3 1266:151266:22 1267:2 1276:20

relied 1062:1,4 1159:71316:16

relies 1217:6 1264:6reluctant 1255:9 1281:41281:10

rely 1156:4,4 1196:111339:21

relying 1087:7 1248:11383:12

remain 1080:2 1106:241113:16 1227:101235:21 1260:191316:22

remained 1260:211330:17

remaining 1066:151280:22

remarks 1070:10 1089:161089:18 1204:11

remediate 1278:1remediated 1110:61157:8 1158:10 1277:9

remediation 1074:31122:14 1162:6 1221:231223:24 1224:23 1277:51277:19 1349:21

remedy 1080:9remember 1178:71186:21 1188:18,191189:20 1194:1,181237:1 1251:11 1257:141263:13 1301:9 1304:131343:19 1360:6 1361:91361:10 1362:9

remembers 1188:16remind 1366:6



reminded 1142:211306:20

remote 1255:5removal 1128:5,9remove 1092:16 1139:11277:20 1330:17

removed 1179:20 1202:81202:10

removing 1328:11renew 1323:10renewable 1146:7renewal 1226:8 1227:21renewals 1230:9renewed 1103:20renowned 1294:8reopen 1209:8repair 1110:20 1229:151365:8

repeat 1099:6 1234:151334:2 1337:23 1373:25

repeated 1105:101124:13

repeatedly 1115:24repeating 1070:9repels 1175:23rephrase 1346:12replaced 1084:22replacement 1119:11report 1051:10,211074:10 1084:4 1107:51112:1 1116:7 1132:101133:11 1225:13,16,241226:8 1230:19 1233:31233:9 1236:4,131251:2,24 1252:6,71255:11 1259:22,241260:13,17,21,241261:3,21 1262:3,6,91267:23 1272:11,22,231283:19 1284:2 1289:141289:19 1303:131308:17 1312:7,11,121312:18 1313:12,16,241314:2,10,12 1315:191316:14 1326:12 1335:61339:15 1342:181343:12,14,16,21,251344:5 1350:10 1369:61369:6,7 1371:211372:9,10,16 1373:161374:11 1375:2,9,11,17

1375:19 1376:3,241377:4 1378:21,21,221379:2,4,6,11,161380:15 1381:3 1383:24

reported 1069:14 1133:91153:11 1187:101233:15,17,17 1270:151299:7 1385:18,20

reporter 1048:23 1054:201083:23 1209:221248:20 1249:101310:24 1341:24 1388:5

reporter's 1048:31120:14 1343:7 1388:2

reporting 1268:111270:6

reports 1232:24 1254:151302:20 1374:2,10

report's 1343:22repository 1273:91304:12 1309:6

representation 1102:19representative 1356:24representatives 1052:41162:4 1179:11

representing 1209:18reprocessed 1096:18reproductive 1199:13request 1120:5 1231:31331:25

requested 1229:251262:13 1327:151336:14

requests 1071:1 1328:16require 1074:11 1151:61231:5 1255:17 1319:181337:1 1369:15 1370:2

required 1062:111071:12 1074:9 1095:231116:4 1125:24 1126:111126:18 1151:7 1159:161213:11 1218:15 1226:91228:8 1229:13,241230:12 1231:4,71236:13 1278:1 1281:251288:3 1337:16 1370:1

requirement 1068:211075:6 1087:8 1122:101226:3 1287:7

requirements 1057:7,101058:2,17 1093:14

1097:9 1126:12,171141:23 1161:211210:25 1220:221304:25 1357:12

requires 1086:231093:15 1094:8 1096:231185:1 1200:15 1225:181322:19 1349:17

requiring 1100:101122:5 1224:22

research 1071:1 1179:21226:19,25 1227:5,171227:22 1228:6,71301:17

researched 1057:111178:19 1179:6

researching 1173:19resented 1206:2Reservation 1112:5reservations 1164:20reservoirs 1157:4reside 1094:20resided 1124:14residence 1134:171367:24

residences 1071:20resident 1056:16 1061:231065:23 1077:121089:14 1123:16 1139:71145:12 1160:201296:19

residents 1064:131072:22 1088:101145:16,21 1155:21160:8 1210:8,131214:25 1240:111280:23

residue 1383:13residues 1087:5 1118:16resiliency 1156:16resistance 1164:10resolution 1102:20resolved 1362:18resort 1111:21,221150:19 1212:25

resorts 1213:2resource 1094:25 1097:51151:16 1281:9

resources 1048:5 1049:41049:8 1071:7 1078:141079:7 1083:14 1105:4

1139:9 1224:25 1232:121253:12 1314:19

respect 1064:6 1089:211092:24 1131:1 1205:51377:6

respectfully 1080:171091:3 1092:25 1120:4

respirators 1200:16responded 1385:25responders 1125:21382:1,9

responding 1361:9response 1125:6 1152:91242:7 1243:17 1320:181320:23 1322:1 1380:221380:24 1381:2,4,10,121381:19

responses 1234:13,19responsibilities 1076:141143:21

responsibility 1073:81105:3,20 1115:121120:23 1121:251203:21 1208:18,251245:25

responsible 1064:31065:16 1117:7 1130:111144:24 1221:2 1291:221314:11 1329:4

rest 1188:19 1210:121222:2 1331:16 1332:21332:21,24 1333:21

restarts 1250:5restate 1250:3restaurants 1150:12restitution 1175:3restricted 1235:15restricting 1336:5result 1081:24 1115:4,141135:12 1149:10,221156:22 1161:151182:23 1184:16,17,221185:4 1188:20 1194:21215:21 1217:201224:17 1388:15

resulted 1226:10 1265:101313:19 1346:8

resulting 1215:7results 1058:10 1173:211175:14

resume 1296:12



resumed 1048:17 1051:51308:1 1387:20

resuming 1249:23retention 1096:8,9,14retired 1128:14,16retirees 1137:21 1207:12retrospect 1280:7,12return 1065:2reunion 1106:3reveal 1161:24revenue 1063:5 1212:19revenues 1103:25reversal 1137:19reversed 1230:6review 1091:3 1115:151116:6 1119:6,191120:4 1143:4 1158:51189:15 1196:1 1234:231254:16,22 1284:51285:4 1333:5 1352:41353:17 1359:20

reviewed 1115:161177:20,20 1278:61327:24 1349:111373:20

reviewer 1119:16reviewing 1115:131179:17 1327:18

reviews 1377:8 1383:19revise 1260:24 1271:7revised 1230:21,241243:17

revision 1231:3,5 1272:2revival 1138:14revolve 1093:11re-invigoration 1138:13re-licensing 1196:22re-underscore 1301:5RFI 1226:11rich 1111:2Richard 1048:18 1182:41263:7,11

richer 1148:1Rico 1133:1rid 1101:25 1178:91182:9 1383:13

ride 1295:10ridge 1048:6 1051:13,171051:24 1052:4 1053:41061:16 1062:21 1067:51068:11 1074:5 1077:13

1078:20 1079:4,14,171080:15 1085:3 1086:131088:18 1091:17,241094:15 1102:21 1104:31104:24 1112:18,201115:2 1120:6 1123:171132:15 1145:161154:21 1158:8 1160:41178:6 1215:10 1220:141220:24 1226:15 1231:21248:14 1278:10 1279:81279:9,9,10,14 1283:221309:13

Ridgway 1070:201077:12 1085:191089:14 1120:191123:15,16,21 1124:101129:13 1133:2

ridiculous 1058:3Rifle 1132:12right 1053:21 1054:171056:2,5,9 1082:81100:6 1103:19 1105:31108:12 1128:4 1143:191144:5 1147:10 1157:131160:2,9,24 1165:121171:17 1180:101191:18 1193:171195:16 1196:18,241197:20 1201:5 1206:251209:15 1212:1 1214:91217:11 1219:6 1225:21230:1 1232:10 1233:71240:7 1246:14 1257:221258:17 1259:191260:10 1264:4 1266:61269:24 1280:8 1288:221289:6 1290:13,181291:2 1293:4 1294:91295:11,16 1296:7,91303:17 1314:121316:10 1323:18 1325:81328:15 1336:2,161353:14 1363:161366:11 1367:4 1368:201378:13 1384:4,121385:6

rights 1075:13 1088:151088:16 1189:241229:21 1230:12 1292:31334:17 1339:9,12

1353:14 1355:4,19,221383:17

right-of-way 1285:18rigorous 1177:121178:13

ring 1145:1rinsed 1192:20Rio 1280:19 1298:6,15,17ripped 1066:4rise 1102:25 1170:25rises 1124:2risk 1062:1,4 1063:31072:8 1075:21,221079:17 1081:4,4,5,61085:6 1094:16 1113:51113:8 1114:23 1120:221122:14 1123:8 1156:151158:23 1160:6 1162:251174:12 1210:4 1229:11229:2 1239:2 1242:21243:13,15

risks 1059:8 1073:101081:11 1113:121114:15 1130:241156:17 1158:6 1228:241242:11,15 1243:13

river 1066:2 1072:41074:16 1075:9,18,191077:21 1079:24 1107:61118:23 1121:181130:21 1141:181181:12,12 1186:22,241186:25 1191:16,17,211192:21,23,25 1193:3,61193:7,7 1211:111229:16 1273:101298:18 1299:1 1340:11340:1 1341:4,7,16,181342:14 1354:20 1355:2

rivers 1060:12 1071:191076:22 1085:4 1091:221096:18 1122:201165:24,25 1185:111191:15 1192:21 1193:81221:16,17 1340:20

RN 1198:12road 1050:2 1094:81135:3 1136:10 1161:251198:20 1201:16 1212:21212:21 1260:121292:20 1367:4 1371:13

roadblocks 1136:19roads 1150:22 1180:11367:12

ROBERT 1050:2Roberts 1096:4,51209:11,15,16,16

robust 1382:4Robyn 1077:11 1080:171207:20

rock 1078:17 1114:221132:13 1144:1,2,51200:5 1205:25 1277:21277:8,14,16

rocks 1368:7Rocky 1049:16,181112:24

Rogers 1051:12 1073:171073:18,19,22 1285:25

role 1115:7 1117:151127:13,14 1138:201166:12,13 1268:8,101268:11,13 1271:6,7

rolls 1368:7Ron 1245:11,16room 1053:19 1055:151056:3 1067:3 1101:111152:20 1171:4 1172:191181:5,5 1188:171204:7 1206:12 1209:71213:13 1231:131301:13

rose 1159:20rough 1365:3roughly 1370:19 1371:23round 1165:9route 1071:21row 1144:21rules 1106:17 1115:19,211115:21 1126:24 1154:81158:2 1174:17 1189:121230:14 1235:25 1370:21378:3 1386:18,20,221386:24

rumor 1132:24run 1053:10 1067:211082:23 1102:9 1139:21152:12 1154:6 1165:211319:17 1320:8,91336:18,19

running 1083:4 1186:251193:1 1206:22 1218:16



1343:7 1352:22,231366:23 1369:14

runs 1332:8rural 1137:23,25 1138:131158:17 1215:3

rush 1197:23rushed 1172:7Russia 1092:1Russian 1253:22,25Russians 1186:13rusted 1180:15ruthenium 1199:16R&D 1256:6

SS 1053:1sacrificed 1292:13saddles 1293:23safe 1057:25 1058:7,221091:7 1095:11 1112:251113:4 1148:19 1149:41149:14 1174:23,251185:10 1189:5 1220:131222:6 1298:18,191301:2 1302:19,21

safeguards 1113:17,19safely 1072:16 1141:171189:12

safer 1151:11 1161:141179:11,12 1220:6

safety 1058:3,21 1061:171069:19,25 1070:1,2,31090:1 1091:14 1095:141095:16 1097:8,91098:5,12,14,15,17,191102:7 1117:6 1120:241122:4 1123:11 1129:111129:23 1130:111153:17,19 1175:41198:2 1213:11 1242:61242:8,9 1244:41301:20 1384:8

Saffler 1160:18,19,191168:11,15 1169:4,7,191169:25 1170:6,211171:15,18

SAG 1368:4,6Sal 1153:2 1246:7salaries 1104:1 1138:9salivating 1180:4salt 1182:5 1255:20,22

1256:2,6,20,25 1257:5,7Sam 1152:18,18 1181:4sample 1153:8samples 1153:6San 1063:17 1065:231066:2 1074:16 1075:91107:6 1129:12 1143:181164:7 1172:25 1282:161282:19,21,24 1283:4,71283:14 1296:21,231297:4,5 1340:1 1341:7

sand 1141:18SANDLER 1049:16sands 1092:18sane 1075:21sanity 1182:10sat 1139:23 1151:191153:4 1177:8 1178:81212:7 1252:17 1374:15

Saturday 1096:7 1184:1save 1183:1saved 1073:1 1109:12saving 1054:10saw 1106:14 1142:211143:6,8 1196:14,141222:20 1247:8 1254:101332:16 1350:10 1363:71380:23

saying 1064:23 1073:251100:25 1101:6 1111:81111:11 1142:18,191172:10 1184:201208:23 1219:3 1251:11259:11 1260:231275:21,22 1297:201306:22 1319:16 1349:91365:24 1369:9

says 1058:1 1068:221077:12 1117:121128:19 1130:14 1185:61191:3 1206:13 1223:191247:6,7 1256:251262:19,20 1267:221273:17 1313:181323:22,23

scale 1188:25 1189:1scare 1182:16scares 1163:1scariness 1133:15scary 1162:23scenario 1324:23 1325:1

1325:7,11 1345:10,241346:13,21 1347:1,9,171347:25 1349:14,15,191349:23 1370:3

scenarios 1325:2 1348:3scenery 1131:14scenic 1073:5 1185:11schedule 1151:25scheduled 1367:21schematic 1198:23scheme 1075:23school 1105:24,251106:10 1148:9 1200:131207:24,25 1208:2

schools 1105:22,231212:24

science 1082:5 1139:81184:10 1365:5

scientific 1077:161078:19 1098:241142:15 1174:5,51183:7 1184:14 1226:11

scientist 1139:10scientists 1095:19scourge 1296:6,6scrubbers 1306:25scrutinized 1135:161378:7

scrutiny 1282:16,201288:18

sealing 1091:23season 1129:24 1130:2seasonal 1212:19seat 1140:22sec 1385:1second 1057:22 1059:61060:8 1075:16 1078:251128:15 1137:3 1139:251150:13 1178:2 1229:81296:13 1298:9 1303:251335:20 1380:4

secondary 1063:5 1104:4section 1106:17 1115:231116:11,14 1225:15,161225:18 1226:16,211243:12,13 1363:21380:24

sector 1108:25security 1058:15 1123:9sediments 1141:17see 1054:7 1059:19

1060:3 1072:14 1078:171094:5 1096:21 1098:231101:2,8 1107:171108:7,8 1114:51116:17 1124:251131:22 1142:4,231143:7 1148:5 1149:3,31150:17 1165:11,251166:1,2 1169:4,221175:1 1176:3 1180:11186:18 1196:6,71241:16,23 1242:3,181250:13 1259:8 1262:131266:1 1272:13 1292:101319:17 1321:2 1328:191331:15 1338:22 1352:41363:16 1367:6 1369:51370:14 1372:20 1375:11377:4 1379:21,22

seeing 1094:4 1137:181186:14 1207:111342:15 1372:4

seek 1118:10 1141:141259:8

seeking 1141:1 1142:111200:23,24

seeks 1091:10 1141:21seen 1071:14 1074:231108:2 1120:2 1133:81145:21 1150:4 1177:91185:24,24 1187:9,181187:19 1188:1,161224:20,21 1225:81269:16 1285:2 1300:181320:16 1330:12,131349:6 1368:24 1379:11380:20

seepage 1091:21segues 1097:14seismic 1217:1selected 1168:4,5selenium 1265:7,9,191270:3,13

selenium.PDF 1267:15self-insured 1201:1self-reporting 1051:91269:20

sell 1173:17 1206:251365:12

selling 1110:13 1365:16seminars 1294:15



send 1118:15 1169:51218:10,10 1352:1

sending 1214:14 1383:9sends 1101:13SENES 1375:25senior 1075:12 1306:9,16sense 1090:10 1105:71109:14 1132:151260:25 1261:6 1320:71331:5 1366:4

sensitive 1084:7sent 1069:9 1130:101234:19 1246:181306:16 1307:6 1376:7

sentence 1333:14sentences 1226:22sentiment 1137:12separate 1081:2 1128:91266:25

separated 1080:3separation 1256:3September 1086:8,151354:8

Sequoyah 1229:6series 1269:7serious 1057:17 1081:61105:18 1156:131206:13 1231:5 1255:7

seriously 1095:19 1129:31195:11,18

serve 1117:15 1151:141155:4 1203:24 1259:18

serves 1151:17 1208:221266:6

service 1052:3 1080:171354:9 1356:11,221358:6

services 1117:18 1150:11349:22 1381:9

serving 1147:15session 1053:3set 1053:5 1090:91114:18,21 1116:141149:14 1166:2 1223:181231:19 1260:16,171325:5 1336:13 1388:9

Seth 1305:24sets 1327:1setting 1323:12settings 1385:25settled 1063:18 1110:19

1163:19settlement 1300:22settlements 1300:15,16set-aside 1336:7seven 1082:14 1086:61358:4

severance 1218:7severely 1060:131085:16

sewage 1101:14 1102:1shakers 1273:23shallow 1075:25shame 1217:20shape 1156:9share 1126:4 1174:24shareholders 1291:22shares 1126:1Sharon 1214:5 1224:6Shattuck 1081:22 1194:71194:8 1304:14

Shaw 1178:7Sheep 1049:14 1112:11151:21,25 1152:61168:7,19 1247:41257:1,7,10 1267:121272:12 1284:111287:24 1309:201318:16 1326:101329:24 1335:4 1338:201349:1 1354:15 1361:8

sheet 1053:18 1054:251303:15

sheets 1055:20 1172:221213:17

Sheridan's 1071:24sheriff's 1125:2Sherman 1049:22shift 1066:19 1067:91093:12,17,19

shifting 1093:20 1138:12shined 1172:11ship 1101:11 1250:13shipment 1229:8,8shipped 1252:20 1304:20shipping 1249:24 1250:41250:6,19 1251:5

ships 1205:15shock 1186:10shockingly 1114:14shoot 1100:25 1363:22shop 1147:9,14

short 1130:14 1159:181208:1 1252:17 1254:121286:22 1306:131307:16

shortcut 1187:23shortcuts 1186:2shortcutting 1196:13shorthand 1388:8shortly 1228:20shortsighted 1299:21short-term 1158:13shots 1061:3shoulders 1214:11shouts 1117:20show 1067:22 1104:81153:12 1159:5 1201:41264:7 1266:20 1297:31372:6

showed 1218:25 1288:23showing 1195:9 1317:81318:6 1330:24

shown 1060:8 1155:251156:23 1158:3 1220:201381:3

shows 1077:17 1104:91216:16 1295:171297:12

SHPO 1356:15,18,221357:1,6

shrink 1197:15,18shut 1071:15 1195:11221:24 1228:161257:23

shutdowns 1248:3shutting 1087:20shuttles 1186:25sic 1323:24sick 1061:13 1098:101198:19 1201:8 1217:19

sickness 1164:20,25sicknesses 1199:3,13side 1055:16 1088:25,251142:6 1149:8 1162:241178:18,24 1179:211200:4 1207:25 1259:41294:10 1295:191372:24

sides 1209:23Siembra 1215:2sign 1177:21 1209:101320:25 1355:10

signal 1384:22signature 1388:17signatures 1320:22signed 1054:25 1110:201112:9 1165:18 1209:111213:14,16 1254:3

significant 1062:181066:23 1113:23

significantly 1063:31218:1

signs 1302:15 1355:14sign-up 1053:18 1054:251055:20 1172:221213:17 1303:15

Silas 1231:24Silkels 1152:18,191181:4

silo 1182:11silver 1081:13 1302:8Silverton 1130:9similar 1057:7 1205:191229:9 1380:20

simple 1110:8 1145:15simply 1057:22 1126:201140:2,7 1142:4 1152:41156:13 1275:25

single 1081:1 1087:171117:6 1162:19,21

singular 1198:15sir 1213:21 1214:14sit 1054:18 1152:1,1,81177:5 1238:21 1363:21

site 1062:16 1063:241068:1,3 1074:151077:19,25 1085:31091:8 1099:11 1101:121106:19 1107:9 1109:51109:6,13 1112:6,11,141115:1,6 1117:191118:1,16 1119:51121:15 1122:171125:23 1130:6 1135:191135:20,23 1147:111165:13 1178:231179:20 1189:22 1208:51214:17 1215:191220:21 1222:2 1223:161242:18 1252:4,81258:4 1259:17 1273:81273:8 1277:6 1278:111278:14,17,21,24



1279:7,9,10,13,14,15,241280:3,4,5,8,10,16,191280:22 1282:15 1283:91283:17,21,21,221284:1,4,7,13,21,211285:4,8,20 1299:201302:7 1314:20 1363:51381:1,6,6 1382:7

sites 1076:1,6 1078:131079:18 1107:18,19,201109:19 1113:22 1132:31157:21 1195:2 1221:221278:9,12,15,19 1279:51279:5,22 1280:251290:1 1291:17 1292:18

site-wide 1076:5siting 1114:1 1283:101285:9

sits 1366:12sitting 1055:14 1129:71131:6 1236:10 1379:19

situ 1374:23situated 1216:25situation 1069:4 1109:31177:6 1202:2 1217:121230:6 1275:3,101367:2,6

situations 1238:31357:13

six 1068:3 1125:191134:18 1144:141218:18,20 1223:91225:25 1244:9 1257:191285:17 1380:16,18

sixth 1147:3,17six-month 1234:23size 1125:16 1197:191336:4 1345:14

Sjoberg 1094:13,14ski 1129:14 1132:24,251133:6,12

skill 1054:12 1132:1skilled 1072:16skimp 1126:10skin 1202:20skip 1181:5,6 1226:3sky 1383:25slammed 1196:8slate 1210:24sledded 1146:20Slick 1132:13

slid 1192:1slides 1192:15sliding 1152:23slightest 1113:2sliver 1081:18Slope 1080:12 1103:231104:3 1130:21 1138:5

slopes 1132:25slow 1172:3 1206:81208:15 1345:5

slowly 1193:14,14,14,14slump 1292:22slurry 1368:9SMA 1051:7 1052:2small 1070:7,20 1082:21102:17 1141:4 1151:151151:24 1165:201176:25 1177:1,3,16,201192:22 1199:221205:24 1216:1 1257:251354:3 1367:17,24

smaller 1067:12 1319:151319:17

smart 1172:13smile 1072:5Smith 1360:7,10,11Smith's 1360:4 1361:25snapshot 1082:2sneaks 1089:6snow 1078:23 1129:231130:3,16 1133:91157:3,5 1193:3

snowcapped 1078:18snowpack 1129:22,24snowpacks 1157:1soak 1215:23social 1065:25 1066:41225:17,20,23 1226:91227:2,16,23,25 1231:7

society 1081:5 1186:11190:10 1196:10

socioeconomic 1067:171067:20 1111:6 1133:241156:18 1158:12 1164:61195:6

socioeconomically1365:1

soil 1060:12 1085:181156:5,7,8,10 1160:2,101162:15 1225:7

soils 1077:17 1091:22

1106:16 1107:3 1109:41109:7 1113:14 1138:171139:10 1156:221157:14 1225:4

solar 1072:24 1084:231100:19 1146:9 1222:131363:4,9

sold 1110:7 1135:191183:3 1219:6 1253:7

sole 1115:12solid 1101:13solids 1270:2,12solution 1109:16 1310:61328:12

solutions 1301:21solve 1148:16,17somebody 1154:91191:22 1203:161242:13 1300:12 1306:61373:18

somebody's 1072:101177:10 1359:6

someday 1257:121326:23

somewhat 1085:251144:20 1337:20 1338:21340:22 1363:11

son 1220:1song 1071:24songwriter 1071:23Sonoran 1111:19soon 1091:24 1092:21121:17 1257:18 1295:61323:18

sooner 1144:22sorry 1127:4 1137:91209:14 1234:161254:19 1255:211262:23 1267:181275:17 1276:24 1285:51300:10 1308:171310:10 1313:101317:22 1318:221329:13,16,22 1334:251341:24 1345:221348:10 1356:8,221361:21 1363:21,24

sort 1187:21 1244:71292:22 1293:8 1327:11331:2 1352:6 1367:101371:1

sorts 1144:18 1375:22sought 1250:10sound 1366:13,151368:12

sounding 1202:14sounds 1257:19 1260:9sour 1158:15source 1078:24 1092:81093:1 1124:9 1129:251146:8 1157:17 1341:131341:14 1370:4,5,6

sources 1074:14 1103:241124:17 1157:111212:19 1305:5,61340:2 1341:15 1342:71343:13,18 1344:11372:18

south 1164:24 1340:6southwest 1077:20Southwestern 1097:17Soviet 1182:2,14 1183:121186:11,12

so-called 1126:2 1137:251216:9

Spaanstra 1049:21344:11

space 1293:25Spam 1178:9speak 1054:19 1065:81084:7 1089:15 1097:171127:9 1129:8,91137:11,14 1198:51207:22 1225:12 1298:51300:3,16 1303:24

speaker 1161:1 1293:19Speakerphone 1056:24speaking 1113:181139:14 1172:18 1244:4

special 1085:22,241129:15 1241:7

specialize 1375:24specialized 1366:1Species 1354:18specific 1124:19 1374:131381:16

specifically 1126:181137:16 1144:161212:16 1225:15

specifications 1272:3specificity 1099:12specified 1223:21



specifies 1118:4speculates 1261:24speculation 1066:9speculative 1066:71126:2

speculators 1291:9spell 1053:20 1252:101256:10

spend 1062:11 1133:71285:17 1332:4 1344:19

spending 1236:1spends 1121:14spent 1054:3 1088:141129:1 1136:17 1173:31173:19 1174:16 1195:11208:2 1211:4 1215:121330:24 1358:16

spikes 1302:7spill 1210:4 1298:7spilled 1125:9spills 1085:17spinoff 1182:24spirit 1140:25 1141:31307:14

spoil 1138:19Spokane 1202:5spoke 1137:5 1209:231299:24 1303:211305:13,16,21,24

spoken 1163:13spot 1163:22spots 1186:16spotted 1205:11spread 1101:15 1135:11spreading 1194:15spring 1078:17 1124:121150:25 1212:20

springs 1193:4spur 1148:13squeeze 1206:2ss 1388:2stability 1159:1stable 1085:12 1156:12stack 1227:21 1308:221309:1

stacked 1311:21stacks 1185:15,15,16staff 1117:15 1224:251335:10

staff's 1262:16,24stage 1323:4 1356:14

stages 1103:7 1265:17staggering 1121:22stake 1140:11,13stakeholders 1104:221116:2

stakes 1130:24stamina 1387:4stamped 1321:6stand 1142:21 1159:41197:20 1203:181216:10 1291:1 1301:25

standard 1058:21 1109:81109:10,10,11 1149:151332:10 1352:3

standards 1077:241098:5,12 1142:151143:2 1149:13,141171:21 1265:12,15,221277:6 1298:19 1359:19

standby 1247:25 1253:2standing 1198:181302:16

stands 1155:3stapling 1321:23stars 1192:10start 1053:6 1055:51064:23 1073:241081:12 1086:13 1098:11101:23 1145:1,51165:7 1193:8 1211:161231:16 1322:19,251323:5 1327:16 1328:51357:25

started 1055:20 1082:181133:17 1146:2 1153:31167:21 1171:25 1175:61181:23 1182:211186:17 1273:12 1275:4

starting 1145:13 1182:81210:23

starts 1093:20 1189:91193:1 1310:2 1318:20

start-up 1268:22state 1048:25 1056:171057:4,9,24 1058:121064:9,13,18 1065:101067:17 1068:171069:14 1076:16,17,251077:23 1080:7 1082:241083:20 1087:3 1088:251089:23 1094:21 1099:3

1099:14 1103:12,251109:14 1110:11,151111:1 1114:22 1115:121115:18,20 1116:6,101118:25 1121:161127:12 1136:131141:23 1142:3 1162:41162:24 1166:6,81167:23 1168:21 1172:21175:12 1195:25 1198:31216:19 1218:7 1223:201223:23 1224:251228:23 1229:5 1241:161246:12 1266:191277:17 1281:8 1282:11282:1,2,24,25 1287:211288:4 1296:16 1309:221309:25 1310:3,41312:9 1356:15,181357:9 1359:18 1360:231377:9 1378:10,231379:5,10 1380:141381:10 1383:151385:12 1387:1 1388:11388:6

stated 1074:17 1084:141086:10 1179:2 1297:81332:23

statement 1080:251081:2 1089:22 1099:101099:18 1102:11 1116:41117:12 1125:1 1203:231236:3 1340:12 1373:61373:7

statements 1087:121088:16 1100:7 1139:161185:1 1252:13 1291:141291:18 1358:20

states 1057:19 1061:31067:2 1084:19 1086:41091:12 1092:5 1093:231094:8 1103:3 1121:61123:8 1135:22 1144:31144:16 1151:181165:14 1167:11,121173:13 1181:241183:22 1189:13 1278:61294:14 1346:4 1365:151374:3 1375:1

statewide 1155:25state's 1066:20 1067:7

1069:1 1115:15 1228:12state-approved 1155:6state-of-the-art 1083:51176:18 1274:7

stating 1060:7station 1285:9,11,13,191285:21 1286:4

stations 1142:5 1287:15statistical 1057:11statistically 1142:8status 1116:2 1339:11statute 1225:18 1226:31231:7

statutory 1151:7stay 1104:12 1148:81204:5 1217:15

staying 1336:15steam 1343:7 1387:13steel 1146:6 1210:3Steele 1233:20,22,25stemming 1300:23step 1051:17 1110:81321:12 1382:22

stereo 1366:20sterile 1202:22sterilized 1202:23Steve 1051:23 1052:61119:7 1232:14 1233:91233:17,17 1234:201321:18,20,25 1339:71358:24 1359:8

stewards 1104:101131:16

stick 1206:16stickers 1153:24stigma 1085:15 1088:61109:18 1110:23 1111:91218:5 1226:19,231227:8

stigmas 1111:5,7Stills 1049:9 1054:51055:24 1137:2,5,71168:9 1231:22,251232:2,7 1236:221237:6 1243:4 1247:1,51247:11 1248:18,22,231249:11,14 1252:9,111252:14 1253:211256:12,15,18 1262:21264:23 1265:1 1266:141267:7,10,13 1269:5,25



1270:10 1272:8,131274:1 1276:2,3 1282:81284:8,12,16,201286:14 1290:4,81296:12 1307:14,211308:2 1309:11,18,211310:25 1315:7,221316:6,11 1317:19,221318:13,17 1322:121323:18 1324:5,61326:6,11 1328:51329:21,25 1332:41333:9,13,17 1334:101334:22,25 1335:51337:24 1338:7,18,211339:1 1341:25 1343:81343:11 1344:4,22,241346:11 1348:24 1349:21350:6,20 1354:14,161361:7,21 1363:23

stirred 1183:18stock 1088:4 1299:1,3stockholder 1263:23stockpile 1113:221123:25 1237:251238:14

stockpiled 1124:5stockpiles 1062:231114:1

stocks 1126:2stood 1054:19 1134:241139:19

stop 1080:14 1123:101127:18 1170:8 1195:161197:1 1203:3 1212:71291:25 1296:2 1297:101312:4

stoplight 1384:16stoplights 1384:15,20stopped 1186:6 1228:191229:5,7

storage 1107:20 1146:91328:10 1330:181335:11 1342:11

store 1241:25 1330:191342:12

stored 1062:24 1073:10storms 1124:13 1130:15stormwaters 1114:6story 1209:23straight 1230:13

Strategic 1182:5strategies 1138:21,22strategy 1235:11,141237:7

stream 1147:10 1383:6streams 1085:4 1191:20Street 1048:21 1049:3,171049:22 1133:8,101388:21

strength 1158:17,19,22stress 1091:14stretch 1298:25 1301:2strict 1072:17strides 1091:13stringent 1103:121158:11 1219:14

strive 1140:14strong 1124:12,181130:14 1148:21 1160:31229:3 1333:3

strongly 1056:21 1065:91068:16 1090:111224:24 1231:3 1332:201332:23 1333:3,11,20

strontium 1199:23struck 1221:25structure 1083:17structures 1141:19struggle 1217:11 1354:5struggles 1332:13struggling 1135:3stuck 1097:25studied 1135:24studies 1058:9 1061:41111:6,7,12 1156:231183:7 1190:20 1197:41226:12 1227:3,221241:18,21 1254:201383:23

study 1098:25 1099:61111:19 1122:6 1129:231135:7 1141:25 1142:81142:10 1180:211190:23 1218:111226:10 1283:13

studying 1173:191202:25 1224:9

stuff 1070:7 1096:71144:17 1153:241192:25 1222:4,14,221223:12,13 1292:19

1301:7 1307:4 1320:11377:23

stunning 1195:21stupid 1206:1subcontractors 1159:16subdivisions 1133:22subject 1070:16 1096:101126:23 1160:221180:25 1247:22,241316:9 1362:6

subjected 1165:81176:12 1288:181353:21,22

submission 1315:11submit 1070:9 1071:231092:25 1225:141241:23 1247:1 1266:231269:9,14 1284:81296:20 1308:9 1309:111318:13 1324:7 1328:20

Submittal 1267:22submitted 1065:141066:25 1068:121104:15 1114:16 1230:41230:23 1241:18 1267:51309:7,22 1312:11,131318:6 1321:5 1325:181339:15 1344:251351:15

submitting 1110:91378:20

subsequent 1105:171128:11 1361:20

Subsequently 1106:11153:13

subsidiaries 1141:9subsidies 1159:7subsidize 1160:13subsidy 1159:14substance 1174:221241:15

substantial 1103:241227:17 1329:1 1331:9

substitute 1210:10subsurface 1192:18subways 1122:25succeed 1212:5 1275:21succeeding 1212:8success 1158:16successful 1176:6successfully 1156:6

1157:8succumbed 1128:17,23sudden 1192:24 1302:11sue 1070:18,19 1110:181167:14,15,17

suffer 1221:1suffering 1079:251220:16

sufficient 1063:211064:16 1275:2 1336:171336:19 1352:21

sufficiently 1280:2suffocating 1206:81212:4

sugar 1133:20suggest 1385:9suggested 1087:2,131162:7 1366:3 1385:16

suggestion 1165:31331:18 1332:15

suggestions 1211:2,31374:16 1385:25

suing 1176:7suitable 1163:21 1278:201279:25 1280:17

Suite 1049:3,6,10,171388:21

sulfuric 1079:16 1180:81180:16 1306:3

sum 1159:23 1213:6summarized 1243:14summary 1160:11168:22

summer 1066:18 1112:41222:21 1341:2

summers 1106:8,101215:12

Summitville 1194:18,19sun 1222:12Sunday 1283:3Superfund 1062:161077:19,25 1165:131208:5 1214:17 1222:11302:9

supervision 1351:18supervisor 1232:171234:9

supper 1150:3supplied 1157:4suppliers 1365:6supplies 1057:16 1059:5



1091:25 1339:18supply 1074:8 1075:2,91075:15 1092:3 1335:111336:19 1338:121339:13 1341:21 1343:11354:22

support 1065:18 1079:51102:3,20 1144:101145:6,15,20 1164:11229:20

supported 1078:191155:3

supporting 1156:2supportive 1147:181152:15

suppose 1233:5 1329:7supposed 1106:91131:20 1153:6,9,211166:12 1167:241169:11 1170:7 1185:251189:25 1194:19 1222:41222:17,22

supposedly 1220:5suppression 1114:13sure 1054:10 1060:91081:12 1083:251088:21 1093:13 1097:61098:22 1099:16 1100:31138:20 1162:201165:23 1167:181191:19 1203:241204:18 1221:161233:13 1261:6 1263:241271:19 1274:19 1278:61279:20 1290:6 1297:31313:14,25 1318:111341:11 1345:5 1353:191360:8 1366:17 1371:161373:4 1377:18,201379:6

surely 1209:3surety 1114:18 1274:131274:17 1344:25 1345:21346:7,11,17,20,251347:8,25 1351:3

surface 1130:3 1192:19surmising 1330:131372:5

surpass 1140:13 1141:22surpassed 1222:15surprises 1230:10

surrounding 1095:181099:11 1109:181130:23

survey 1145:14,141147:19 1226:11

survival 1156:19 1198:25surviving 1171:8susceptible 1113:21162:19 1199:12,221201:12 1203:1

suspect 1206:23suspend 1369:17suspended 1270:2,12sustain 1074:12sustainability 1074:191079:12 1156:11,161160:7

sustainable 1108:231141:6 1293:11 1295:22

Sustained 1262:1swam 1146:17swear 1142:22sweatshirt 1291:3sweetly 1178:22swimming 1146:18switchgear 1153:20sworn 1056:7 1231:251232:4

SX 1328:12 1331:121382:10

sympathize 1120:191165:10

sympathy 1127:11synonymous 1279:15system 1057:12,211096:20 1110:151113:11 1154:4,4,41265:5 1266:8 1277:201311:20 1335:11

systemic 1059:5systems 1063:6,8 1076:51094:10 1122:11

S-H-P-O 1356:18

Ttable 1055:3 1149:81152:5

tabs 1359:22,24tag 1159:19tailing 1345:15tailings 1070:23,24

1071:24 1072:3,151073:9 1076:2,9,201080:1 1091:20 1095:51098:19 1105:23,251109:24 1110:5,101112:6 1114:17 1124:161128:1,4 1141:131146:17 1174:131178:19,24 1192:51215:19 1216:251223:17 1258:8 1259:141271:1,13 1273:1,91274:1 1298:11,201299:12,20 1302:61308:5,8,10,15,18,22,241309:1,5,6,8,23 1310:61310:6,12,14,16,19,211311:1,3,8,13,20,21,211312:5,21 1313:3,61345:13 1347:5,131348:6 1349:17 1353:21353:7 1364:19 1383:7

tails 1310:8tainted 1110:25take 1055:6 1064:91068:23 1069:17 1071:71072:7 1076:13 1099:71100:14 1120:15 1135:61153:8 1163:4 1164:161173:7 1186:2 1188:121200:3 1203:17 1205:161208:25 1211:101218:19 1220:181231:15 1233:191242:14 1246:17,211249:12,17 1251:131253:8 1258:22 1260:91261:16 1262:8,12,141269:15 1287:241290:10,11 1294:141296:4 1302:4 1306:121316:21,23 1320:121328:1 1339:22 1344:81345:22 1348:5 1367:13

taken 1067:25 1068:81129:4 1132:9 1134:121166:12 1167:11 1170:51195:11 1201:11 1202:61202:7 1203:5 1208:101208:10 1209:1 1286:41286:5 1317:3 1388:8

takes 1060:10 1100:211133:11 1211:151218:17 1293:5

talent 1138:6talk 1065:20 1080:231081:6 1100:15,151152:11 1164:23 1165:51165:6,17 1166:251167:2 1199:8 1204:101252:3 1291:17 1292:21292:14,17 1298:11300:4 1315:7,12,21,221315:23 1378:8 1379:201384:2

talked 1135:20 1144:151161:4 1166:20 1190:131190:24 1191:16 1240:91240:22 1333:241362:12 1363:4

talking 1064:25 1101:61113:19 1140:2,191161:17 1167:211183:23 1190:18,191191:21 1192:2 1197:221201:21 1206:5 1237:251240:1,3,6,25 1251:21252:5 1256:11 1264:221289:13 1297:20 1318:51318:9 1339:8 1343:121344:19 1350:111361:22 1364:111372:11

talks 1182:5,6 1259:131339:11

tangential 1245:23tank 1328:9,10 1329:91330:18

tanks 1316:21,24 1317:91318:6 1365:25 1366:11366:1

tap 1177:4tapes 1296:19,21target 1265:8Tarlton 1052:6 1087:21118:14,25 1119:71149:8 1195:22 1305:41359:8 1360:3 1361:241363:4

task 1260:15taught 1117:19tax 1103:25



taxes 1218:8 1219:21taxpayer 1088:151108:17 1121:19 1159:71188:13

taxpayers 1062:111064:2,12 1076:161078:3 1106:22 1107:21107:8 1114:22 1122:171122:21 1141:101157:21 1159:2,13,241160:12 1201:14

teacher 1207:23 1210:10teachers 1208:2 1292:61296:5

team 1119:19 1178:21team-building 1294:8tear 1371:14tear-down 1386:16technical 1051:141054:12 1074:21 1119:61119:16 1216:20 1272:21309:14 1376:7 1378:201378:22

technically 1119:19techniques 1091:23technologies 1328:20technology 1082:4,4,121082:17 1091:13,181103:11 1144:111147:14 1148:221176:19 1184:141205:16 1255:14,17,191255:22 1256:11 1257:51265:2 1328:22 1331:14

telecommunication1138:11

telecommuted 1138:12telephone 1118:121172:20 1213:191231:11

telephonically 1049:181049:23

tell 1055:8 1081:101100:12 1119:4 1132:221149:4 1171:7 1199:31228:25 1262:111302:16 1351:23 1366:91369:11

telling 1073:7 1161:41186:14 1293:13

tells 1063:2 1109:14

1110:21 1123:251208:24

Telluride 1085:191131:7 1133:1,7 1147:71147:22,24,25 1148:141149:23 1150:25,251152:10 1155:5 1164:61181:7 1189:3 1292:151294:20 1379:211386:12

Telluride/Moab 1150:15ten 1229:18 1231:15tend 1199:20tendency 1302:22tenfold 1104:12 1133:13tenth 1106:3term 1192:17terms 1069:6 1081:61125:4 1126:11 1138:41199:2 1240:13

terrible 1059:18terribly 1361:11Terry 1059:12,13,14tested 1153:22testified 1112:241181:17 1232:5,111245:4 1258:10 1262:161262:23 1264:101269:11 1270:23,251271:13 1277:1 1281:161282:14 1283:17,251304:13 1308:4 1313:51314:14 1322:7 1323:81337:12 1353:11 1356:11358:12

testify 1173:22 1245:71256:25 1341:12

testifying 1306:211331:24

testimony 1114:9 1143:71161:1,18 1162:211166:18 1180:22 1183:21184:2 1189:6 1191:141191:15 1218:101221:17 1239:101244:16,22,25 1251:171251:23 1256:181261:12 1262:2 1265:31265:4,24 1266:31271:25 1275:1,241276:10 1277:21 1278:8

1282:14 1299:161300:13 1305:4,101343:4 1344:24 1350:61352:25 1353:8 1355:211364:8 1368:6 1373:251375:11

testing 1121:9 1153:221303:7

Texas 1093:23 1365:241366:2

text 1055:24 1314:11349:15 1372:19

thank 1059:10,111064:14,19,20,231070:17,19 1073:151077:7 1080:16 1083:211084:6 1090:25 1093:41096:3,6 1102:111104:19 1120:111123:12 1126:25 1129:41129:7 1131:3,51134:13 1136:25 1137:71137:10 1139:2,41143:10,11 1145:71152:16 1154:191160:16 1172:16 1173:11173:8 1180:6 1198:41207:18,21 1209:51213:12 1214:13 1221:51231:8 1249:11 1252:71252:24 1257:111279:17 1284:24 1296:91296:9 1301:11 1302:221303:12,19 1307:8,171321:23 1333:231334:13 1340:191363:19 1385:8 1387:31387:5

thanks 1073:23 1094:121102:14 1104:17 1136:61137:14 1139:5 1319:81363:20

theoretical 1328:4theory 1224:12thereof 1116:12thermodynamics 1094:7thick 1242:6thin 1080:4 1377:1thing 1065:9 1083:181088:22 1096:14 1113:11127:21 1142:17 1154:7

1178:17 1180:2 1193:41194:25 1195:191198:16 1200:1 1201:131206:15 1223:15 1235:71238:23 1297:18 1300:31303:22 1309:2 1311:171331:3 1338:15 1368:91371:1 1380:1 1384:231386:14

things 1075:14 1081:141081:23 1082:251093:23 1099:2,81112:15 1143:241144:12,18 1146:151148:23 1150:16 1166:21178:1 1184:18,191187:19 1188:9 1190:161191:25 1193:11,13,191193:22,22 1194:11196:13 1198:14 1199:31200:21 1201:9 1202:121203:10,25 1207:2,181213:4 1219:5 1221:121221:25 1223:19 1238:21249:15,17 1259:4,111262:7 1293:2 1299:171300:25 1303:6 1307:221314:5 1315:8 1318:191319:22 1328:171330:25 1331:4 1357:191364:14,15 1366:181368:8 1370:25 1374:181375:22 1381:16 1384:11386:23

think 1055:10 1058:31061:11 1066:10,11,201067:7,24 1068:191074:22 1077:4 1082:161083:3,7,9,15 1084:251087:25 1088:3,211089:3 1094:16 1097:31098:10 1099:241114:24 1117:221118:24 1119:171127:16 1129:2 1131:201131:25 1132:21 1133:51135:1,4,8,13,171140:13 1143:3,51144:14,25 1145:181146:24 1149:151150:15 1155:23 1168:5



1168:9,19 1171:8,101177:13 1181:16,181182:1 1183:8 1184:61186:19,23 1187:15,201188:3,21,24 1189:201190:11,13,21 1191:11191:12 1192:5,16,231197:12 1200:1,1,131203:3,3,4,21 1213:91216:24 1217:2 1219:51219:24 1220:2,71222:10 1235:221239:21 1240:5,15,211241:7 1244:1 1256:51256:20,23 1260:141261:8,15 1263:101280:12,16 1282:181283:20 1284:17 1286:11297:6 1299:21 1300:241301:20,21,22 1303:91303:22 1304:181306:11 1307:17 1317:21324:10,20 1325:111328:1,10,15 1332:141335:20 1342:25 1344:81347:2 1352:8 1357:201361:12,20 1362:51363:7 1365:21,231366:3 1367:23,251370:10 1371:221376:15 1379:8 1380:41380:22 1381:2,71383:22

thinking 1178:9 1186:241193:13 1306:20 1307:11377:9

third 1060:17 1150:131338:19 1341:20

third-party 1116:14,18thorium 1084:22 1199:23thorough 1149:11,121158:4

thoroughly 1116:61135:4

thoroughness 1120:7thought 1163:6 1169:121179:3 1195:8,201275:19 1285:101288:24 1307:5 1357:171373:7,22 1376:231384:25 1385:1

thousand 1087:141088:17 1101:211102:16 1104:2 1132:211133:13 1192:3 1298:141304:6 1317:15,171325:14 1326:241336:20

thousands 1081:251096:1 1122:15 1140:121157:7 1299:14 1300:11301:8 1321:1

thousandth 1141:15threat 1156:19 1158:251193:16 1293:141295:19

threaten 1183:22threatening 1193:21threats 1089:25 1193:23three 1051:17 1081:21082:3,8,12,14 1083:7,91083:11 1086:3 1092:131097:23 1106:8 1111:71111:12 1128:9 1145:221155:17 1173:5 1187:111188:19 1219:2 1226:221229:20 1253:1 1282:91282:12 1306:141310:20 1314:231321:12 1339:18 1340:21342:24 1343:131344:19 1359:101367:25 1368:19 1375:3

three-inch 1227:21three-year 1262:7threshold 1364:18,20threw 1321:3thrives 1133:3thriving 1133:19 1138:7throw 1216:11throwing 1330:9thrown 1376:8thrust 1131:20Thursday 1184:1Thurston 1064:21,22thyroid 1199:15 1202:6,61202:7,9 1212:16

Ticaboo 1252:4,9,251254:10,21 1255:4

tied 1332:6ties 1294:4,24tight 1075:15

Tim 1196:25timber 1151:18time 1053:4 1054:31059:10 1064:141073:15 1080:5 1082:61082:17 1084:7,161086:16,22 1088:11089:4 1090:19 1098:161102:22 1105:15 1106:31106:5 1110:6 1113:241123:12 1124:1 1128:181129:1 1131:22 1133:71135:7,14 1136:61137:18 1141:161143:11 1144:3,61145:12 1152:121153:10 1157:241160:12,17,23 1163:51166:19 1172:16 1173:31174:16 1178:18 1184:11185:8 1186:13 1188:41189:5 1194:17 1197:131197:25 1203:111204:10,23 1206:9,231208:1,6 1209:251211:20 1212:221213:12 1218:241220:25 1227:25 1234:41235:3,8,18 1236:24,251237:7 1238:21,221242:15 1243:191245:20 1246:111249:10,12 1251:161252:17 1253:2,4,61256:5 1258:13 1261:181262:11,15 1263:211265:15 1269:16 1271:91271:16,23 1272:41273:22 1275:121277:17,19 1279:3,211280:14 1282:4,91286:6 1287:4,13,16,181290:5 1292:23,241294:13 1296:1 1297:21298:13 1302:231303:12,25 1306:131310:9,24 1312:201318:18 1325:4,61327:18 1330:7,241332:5 1339:22 1341:21342:3,9 1344:8

1350:24 1351:6,121353:25 1354:1,3,161358:2,7,16 1359:4,191360:6,13 1361:13,231361:25 1362:211367:21 1374:5,191379:14 1384:24 1388:8

times 1071:14 1075:111125:19 1135:2 1139:201162:20 1180:141185:25 1186:171187:11 1196:12 1206:31206:16,17 1218:18,201219:2 1223:10 1225:71298:19,22 1342:23

time-limited 1054:21tiny 1193:4 1212:4tired 1137:21 1345:4title 1076:13,15 1273:2,8titled 1267:14 1309:13tobacco 1142:21,231306:21

today 1053:5 1065:81066:3 1070:8 1073:241077:10 1082:6 1083:101084:7 1086:9 1089:151102:23 1106:13 1121:31121:13 1134:16 1135:81137:11 1139:171145:10 1168:3 1169:101170:2 1184:2 1206:51207:22 1208:8 1225:121232:22 1241:21 1277:91291:12 1303:251379:19 1380:21

today's 1336:25 1337:1Todd 1152:19 1181:5Tokyo 1123:1,3,4,5told 1135:21 1139:201141:24 1170:1,141173:16 1174:23 1175:11177:2,11,23 1184:111299:1 1306:19 1350:191356:11,21,23 1375:181377:21

Tom 1080:18 1143:25tomorrow 1344:151355:24 1387:17

tons 1087:11,14,16,21,231088:17,19 1092:6,61141:7 1225:4 1258:15



1258:17,19 1298:141304:6,23 1305:231307:3,3 1317:15,181320:3 1323:21 1324:11325:14 1326:241333:25 1334:201335:13,18 1336:6,101336:13,16,20 1370:141370:21

top 1153:23 1367:9top-of-the-line 1295:13Toronto 1126:3total 1191:9 1201:23,241270:2,12 1297:121349:5 1383:11

totally 1078:10 1083:111181:14 1194:201203:25

touches 1141:3tour 1175:13 1278:21,24toured 1278:12,151279:6

tourism 1079:11 1085:141129:18 1133:4,141149:23 1150:9,171158:22 1175:231180:12 1211:16,171227:14

tourist 1133:3 1149:241295:3

tourists 1175:13 1207:121223:4,6,6 1295:4

town 1071:14 1072:21108:6 1112:13 1139:181143:15 1205:24 1208:11209:17,18 1211:191213:1,2 1215:131217:15

towns 1107:13 1108:2,31133:2 1205:8

toxic 1059:9 1060:221074:4,7 1101:171138:16,16,17 1214:71221:21 1222:14 1224:71298:16

toxicity 1270:3,12toxins 1059:16TR 1378:24track 1143:23 1155:201195:4 1359:14

tract 1154:5

tracts 1068:4,5trade 1126:2traditionally 1379:3traffic 1085:6 1136:171304:25 1384:15,16,17

tragedy 1223:1tragic 1058:5trails 1295:9train 1155:16 1304:20trained 1125:8 1200:81219:11 1382:8

training 1174:5 1200:101200:15 1242:11,141262:17,21,24 1381:181381:25

transcript 1048:31388:11

transfer 1112:11transferred 1207:25transformers 1153:20translate 1076:15transmission 1299:5transparency 1065:61229:19

transparent 1065:3transpired 1274:24transport 1092:22 1108:5transportation 1079:151103:14 1113:101124:23,24 1125:4,51130:13 1157:12 1210:51304:3,16 1338:171371:9 1384:24

transported 1210:2transporters 1121:8transporting 1071:18trash 1101:12 1102:11146:19

travel 1078:21 1129:171156:23 1366:14

Travers 1190:18Travis 1049:9 1244:71250:3 1260:23 1275:31339:4 1357:18

treacherous 1150:24treasure 1075:22treasured 1075:19treat 1124:6treated 1118:23 1195:71212:15

treatment 1087:5

1099:24 1118:161264:15 1265:2,2,5,101265:18,20,20,251268:22,24 1270:22

trees 1180:9,11 1205:14tremendous 1135:51202:11

trends 1138:20trespass 1160:9trespassing 1157:18Tribal 1198:25tribe 1165:6 1315:2,2,3tribes 1164:23 1314:231314:24

tributary 1341:15,18trickles 1193:5,5,5,9tried 1144:4 1152:111161:5 1163:10 1182:251287:3

trigger 1286:2 1288:101357:10

triggered 1285:231288:12

triggering 1340:11triggers 1286:18,20,24Tri-Party 1121:13Troker 1197:14trouble 1073:21 1199:21300:9

troubled 1068:25troublemaker 1205:1truck 1136:16,22 1221:151221:19 1370:211371:23

trucked 1085:8truckloads 1112:4trucks 1070:3 1071:191124:25 1292:191304:16 1367:8 1368:81368:15,23 1369:10,141369:21 1370:15 1371:11371:2,5

true 1082:1 1139:251140:8 1195:11 1246:11281:12 1286:231288:16 1388:11

truly 1058:17 1160:10trust 1055:15 1098:4trustee 1273:5truth 1173:17 1186:141229:7

truths 1228:21try 1083:25 1127:91135:9 1148:17 1161:191163:10 1164:7 1182:151185:12 1187:231192:10 1196:16 1197:11206:25 1259:7 1282:61293:6,9 1343:111364:8 1366:6 1373:61386:22

trying 1054:3 1100:241109:5 1114:3 1116:221131:16 1141:161151:24 1152:121170:18 1172:13 1182:81182:9 1185:21 1204:51211:6 1212:5 1249:111254:6 1276:4 1285:171295:24 1296:3 1307:151319:25 1330:171331:10 1375:8

Tuba 1112:5tumbler 1368:7turkeys 1155:8turn 1066:12 1124:81133:1,20 1150:181158:15 1206:24 1373:3

turned 1109:13 1147:131330:5

turning 1066:16 1222:23turnoff 1384:17turnout 1134:15turns 1081:9 1222:24TV 1144:15tweaking 1319:23Twenty 1141:7twice 1153:9 1265:161369:20

two 1056:23 1058:251061:25 1062:2 1080:41081:16 1083:6 1092:131110:1 1111:10 1122:231122:23,24 1126:91142:5,5,9 1147:41155:15 1171:161173:11 1183:5,8,131188:9 1197:3 1198:181212:11 1217:241226:22 1227:11 1230:81245:8 1265:23 1266:241278:15 1279:5 1283:16



1287:25 1288:23 1289:11289:7,8,11 1296:191298:13 1308:13 1309:41310:18 1311:4,7,18,191311:23,25 1312:21314:16,17 1327:1,1,21328:24 1337:8 1339:61345:14 1351:101352:16,18 1357:131359:10 1370:24

two-year 1270:15type 1065:1 1066:81068:18 1097:21 1100:91100:10 1140:1 1151:181234:23 1244:15 1255:41296:4 1304:17 1331:81352:3 1384:6,22

types 1108:16 1183:101244:13 1255:16

typewritten 1388:10typical 1060:23 1069:211159:19

typically 1161:9 1239:211240:8 1277:18,251278:4 1281:5 1358:241377:22

T-i-c-a-b-o-o 1252:11

UUh-huh 1237:9 1246:191296:11 1322:21,241354:13 1356:7 1364:121366:16

ultimate 1334:18ultimately 1066:91161:14 1168:1 1169:161248:16 1273:7,141283:21 1330:17 1351:51379:9 1386:21

umbrella 1310:13Umetco 1109:5 1143:201209:22

UMITRA 1143:21unable 1148:12unAmerican 1157:15unaware 1109:241121:22

uncle 1146:16uncles 1205:22uncommon 1268:22undecided 1145:20

undeclared 1183:15Undeniably 1075:25underdesign 1371:17underground 1121:161123:1 1219:12 1238:71244:8,9,11,13,15,21,23

underlying 1074:151261:6

underperform 1143:2underscore 1297:19understand 1072:201083:23 1087:1 1089:191097:21 1109:20 1111:11112:12 1139:6 1151:51170:21 1175:6 1204:191206:17 1207:8,111210:2,24 1212:101220:23 1232:1 1236:251248:13 1250:2 1294:31302:25 1304:211313:14,21 1320:251330:23 1331:2 1332:141341:17 1358:231359:12 1375:11,151376:11,12 1380:131381:13,17 1385:23

understanding 1062:131090:5 1095:2 1098:211124:2 1181:21 1228:41244:6 1263:24 1273:221282:2 1315:1 1350:111351:20 1357:7,8

understands 1102:241206:17

understood 1105:141111:8 1177:25 1359:41385:5

undertake 1195:25undertaken 1067:171128:9

undertaking 1119:251357:6

underused 1293:25underwater 1270:20unemployed 1140:211223:9

unemployment 1103:191205:9 1223:8

unequivocally 1078:5unfair 1324:10unfortunately 1070:6,12

1157:19 1224:201225:10

unilaterally 1261:3unimportant 1293:1uninhabitable 1123:7unintended 1204:22Union 1049:6 1081:19,221128:14 1182:2,151183:12 1186:11,12

unique 1129:15 1131:3unit 1119:8 1216:181225:1

United 1067:2 1084:191091:12 1092:4 1103:31121:6 1123:8 1135:221144:3,16 1151:171165:14 1173:131181:24 1183:221294:14 1346:4 1365:15

units 1190:14universities 1227:22University 1149:6,7unknown 1197:17unpolluted 1072:25unprocessed 1086:24unproductive 1054:111175:17

unreasonable 1075:41216:22

unreclaimed 1273:1unregulated 1135:13unremediated 1107:18unreported 1069:9unrestricted 1106:16unrivaled 1129:16unsafe 1215:4 1298:23unstable 1158:24unsuccessful 1175:17unsustainable 1208:211292:5

unusual 1275:3 1387:17unwanted 1092:17unworkable 1331:181332:16

update 1260:12,161261:3,9 1262:9,141312:17 1317:11 1318:2

updated 1066:21 1067:61091:7,18 1093:13,151317:25 1326:12

updates 1317:12

updating 1098:12upgrade 1324:9upheld 1087:9upper 1187:22upsets 1210:6,13upside 1135:16upwards 1149:21Upwind 1157:13uranium 1048:6 1053:41056:21,23 1057:141058:4,20 1059:7,151060:7 1062:7,12,18,231063:2,24 1065:11067:1,1 1070:7,22,221070:23 1072:3 1074:21074:8 1077:14,18,251078:4,5 1079:16,211080:9 1081:9,121083:13 1084:9,12,151084:17,20,22 1085:21085:11,15 1086:141087:19 1088:7 1090:71091:25 1092:171094:15 1095:4 1098:191099:3,19,20 1100:11102:25 1103:9,10,131103:20 1104:24 1105:21105:6,9,12,13,16,231107:1,7,10,16 1108:41108:21 1110:3,231111:3,4,23 1113:131114:3,11,12 1117:1,181118:4 1119:22 1120:61120:20,25 1121:8,211123:24 1124:4 1128:11129:10,19 1130:71132:19,25 1133:151134:4 1140:22 1141:71141:13 1142:141143:17,23,24 1144:11144:17,19 1146:1,3,101146:13 1147:15,20,241153:16 1154:21,251156:15,22 1157:61158:2,6,7,8,12 1159:31159:6,10,15 1160:5,111160:14,16 1161:71164:22,24 1171:221174:13 1175:241178:19 1179:25 1180:41180:6,21 1182:20,21



1183:10,21 1184:61188:10,13 1189:201196:19 1198:16,221199:2,9 1201:41203:12 1204:24 1206:61206:6,7,20,21 1208:41208:20,24 1209:4,251210:1,2,19 1212:10,141213:9 1214:18 1215:101215:19 1216:18,251217:23 1218:15,211219:7 1220:24 1221:141221:15,19,22 1222:161223:17 1224:11,14,181225:7 1230:8 1237:111237:14,18,23 1238:41238:13 1241:6,141243:22,25 1244:3,111244:14 1246:14 1247:71247:18 1248:3 1253:181253:21 1255:151258:12 1281:24 1293:41297:25 1300:20 1301:11301:22 1302:1 1308:101324:13 1325:4 1346:31358:6 1364:22 1373:13

uranium's 1156:141158:23

Uravan 1062:15,171065:2 1077:19 1081:191106:15 1107:18 1108:31109:4,5 1111:241122:17 1132:111143:15,20 1147:151165:12,13 1174:3,9,101176:1,2 1194:9,101196:19 1225:8 1304:19

urge 1077:6 1080:131090:11 1094:17

USA 1245:19 1349:151350:5,7

usage 1096:9USA's 1091:25USDA 1139:9use 1054:18 1066:111079:22 1085:22,23,251086:11 1091:101093:11 1094:24 1095:91099:23 1106:171112:20 1137:16 1144:41182:25 1185:13

1189:18 1211:7 1212:161229:2 1230:13 1235:141236:16 1253:25 1254:11261:13 1308:181318:18 1339:191364:19 1375:211383:15

useable 1280:21uses 1073:1 1183:7,81212:11

usual 1339:4usually 1081:6 1234:211234:22 1359:10,19

Utah 1069:15 1070:211091:21 1176:23 1246:61246:8 1252:22 1282:1

Ute 1314:23utilize 1116:13utmost 1095:25 1119:25U.S 1103:6,8 1121:131138:10 1176:4 1205:161214:19 1219:13,171275:5 1358:5

Vvacant 1133:6,10vacation 1206:3vaccinate 1060:18vaccinated 1061:7vague 1359:1,3valid 1135:14 1281:9Valle 1215:1valley 1085:1 1091:91114:8 1122:7 1123:181129:12 1136:12,241153:1 1154:21 1163:191174:19 1189:2 1214:231215:2,25 1216:21220:11 1221:3 1227:91240:11 1250:1 1278:151294:7,10 1295:231363:10 1384:5

Valley's 1367:1valuable 1103:9value 1088:8 1100:141182:20,21 1246:10

values 1060:15 1085:161183:5,6 1196:101215:7 1226:13 1227:14

Van 1056:13,15,161057:2

vanadium 1081:211146:1,3,4,7 1147:10

Vanek 1172:17,18,24,241305:13,16,16

vapor 1180:16variance 1109:9variations 1312:3various 1099:10,201103:7 1185:12 1324:181343:15 1380:12 1381:4

vast 1095:8 1207:4vegetables 1155:1vegetation 1375:21vehicle 1372:3vehicles 1371:3 1372:2,2vendors 1365:11ventilation 1238:8,9verbatim 1176:23Verde 1215:1verdict 1306:14vermiculite 1194:22versus 1273:24veteran 1204:21veterans 1203:6,14VI 1048:3 1225:18viable 1133:21 1159:4vicinity 1077:17 1120:20video 1296:20 1297:3Vietnam 1181:251182:11 1186:5 1203:81203:9

view 1068:23 1163:111243:21 1255:3 1261:201261:24 1278:2 1283:131287:11 1353:201362:23 1375:14

violation 1077:23violations 1069:24,251228:17 1270:2,5,6

Virginia 1111:2,5virtually 1205:9 1207:9visible 1130:17vision 1184:20visit 1217:14vital 1129:25vitality 1130:1voice 1187:4,9void 1086:5voir 1344:6volatile 1158:14VOLUME 1048:3

voluntary 1357:9,14,14voting 1137:22vu 1134:23vulnerable 1248:3

WW 1048:18 1049:21wade 1230:22wages 1219:17wait 1061:19 1083:71088:10 1097:241127:18 1139:241261:16

waiting 1097:25walk 1054:23 1055:4,191064:2 1121:4 1209:131229:16 1384:4

walking 1119:14wall 1200:4Walter 1265:12want 1054:11,18 1064:221065:20 1070:10,111073:24 1093:12 1098:81098:8,9 1101:231111:17 1118:18 1133:51134:7 1136:1,2,31143:6 1148:7,18,191149:3,3,18 1156:6,91164:4 1167:25 1173:171185:14,20 1199:31207:4,14 1209:211210:15 1212:24,251213:11 1220:1 1222:11223:5 1246:20 1276:31281:7,13 1285:161286:6 1290:8,191292:7,8,14,17 1293:2,71295:8 1296:14 1297:111301:5 1302:2 1303:101303:17 1307:11 1332:41339:24 1364:7 1371:51371:16 1376:141378:10

wanted 1166:7 1198:131221:13 1223:251279:19 1288:5 1298:51300:3 1301:4 1303:131316:8 1329:18 1331:31357:11 1360:13 1363:71375:18 1377:4

wanting 1306:9



wants 1053:25 1181:11206:3,24 1217:13,141231:11 1301:131307:10

war 1105:13,16 1182:231183:11 1186:7 1203:71203:8,8

warming 1094:9warn 1242:3warned 1303:1warning 1242:211384:22

warrant 1254:11 1255:6Warren 1360:3,6,10,111361:24

wars 1183:14,15wash 1255:20,23 1256:21256:6,20 1257:1,5,7

Washbush 1306:17washed 1192:20Washington 1121:151166:20 1202:5

wasn't 1054:9 1195:111217:12 1227:201252:19 1254:191274:22 1298:9,101330:5 1331:17 1333:11360:12 1378:24 1380:31385:19

waste 1066:12,171072:23 1073:4 1074:41078:2 1079:18 1086:251091:20,21 1101:131107:17 1109:191111:14 1112:5,11,141117:25 1118:2,7,91124:3,17 1150:121194:9 1210:4 1212:231214:7 1221:22 1223:181223:24 1224:7 1226:121227:7,12,23 1229:61248:8 1258:4 1298:111298:14 1299:22,231304:8,10 1383:6

wasteland 1215:17wastelands 1137:22wastes 1073:11wastewater 1124:7watch 1165:22 1207:91387:15

watched 1094:23

1144:12 1211:24 1212:21212:2 1215:5,15

watching 1144:14 1202:2water 1057:16 1059:51071:25 1072:5,13,171073:6 1074:8,9,13,141075:2,6,7,9,10,12,151075:17 1076:231077:17,24 1078:23,241079:23 1080:131085:18 1087:5 1088:151088:16 1091:7 1092:181093:18,21,25 1094:231095:4,8,11,17 1096:2,81096:17,19 1097:11103:16 1104:25 1107:51113:14 1114:8,11,121118:5,15,22,22,24,251124:7 1129:25 1131:141131:19 1136:161150:11 1156:5,211157:2,11,14 1160:2,101162:9 1165:19 1167:91177:3 1185:10 1190:191190:19,21 1191:3,7,81191:10,11,19,22,231192:13,18 1194:51195:5 1208:12 1211:71211:8,10 1215:41217:1,5,6 1222:201229:15 1264:15,181265:10,12,17,20,20,241268:22 1270:11,18,221277:20,24 1298:18,181298:20,23 1299:1,2,3,41304:8 1329:6 1330:31334:16,18 1335:121336:17 1338:11,141339:9,12,12,18 1340:31340:24,24,25 1341:31342:4,6,9,12,13,13,231343:1,13,18,20 1344:11344:2 1353:13,13,141353:17 1354:22,251355:1,4,7,8,19,221383:2,13,15,16,17

waters 1079:4,5 1106:191107:9,20 1119:231138:16

watersheds 1130:21waterways 1085:7

water's 1222:22 1336:23wave 1140:2waved 1177:5way 1055:7 1059:231061:14 1101:25 1102:51128:20 1145:181148:23,25 1160:111161:6 1162:4,91164:13 1173:2,91174:6 1182:22 1186:31186:4,20 1189:41192:8 1213:4 1229:21230:21 1244:11 1254:51257:9 1272:15 1289:21289:6 1294:1 1313:21313:22 1331:11 1357:31357:4 1370:7 1371:141375:11 1376:11,161377:8 1378:9,14,16,161379:3 1385:5

Wayne 1093:6ways 1078:13 1107:161163:10,11 1240:16,171374:6

weakest 1063:3wealth 1060:1,2wealthy 1150:14weapons 1182:9 1183:101188:12 1298:2 1301:11

wear 1344:16wearing 1120:14weather 1142:5 1369:161370:13

web 1109:18 1115:1,61178:23 1179:20 1381:1

Wednesday 1184:11244:23,25

week 1150:2,3 1312:151312:16 1314:161369:14 1380:25

weekend 1059:19 1261:9weekly 1155:19weeks 1306:14week-long 1294:15weigh 1275:10weight 1323:15Weisheit 1191:14welcome 1104:161151:13

welfare 1058:13 1071:10wells 1191:19 1196:9

1229:1,3,4,15 1343:11354:25

well-being 1060:14went 1110:6 1128:41166:19 1179:5 1182:241186:11 1190:12,201193:25 1196:25 1197:21197:3 1236:21 1237:81260:12 1271:20 1272:51273:4 1287:14 1294:11298:18 1306:7 1314:11363:13 1373:211376:16 1378:15

weren't 1166:16 1186:41186:15 1236:161271:10,12 1362:19

west 1056:13,15,161057:2 1077:13,181078:18 1124:13 1130:41136:20 1137:251157:21 1165:111190:19 1207:6 1363:5

Westerly 1124:10western 1049:12 1056:191067:2,15 1075:201079:24 1080:12 1091:11091:20 1092:12 1093:21103:19,20,23 1104:21130:1,21 1138:5,221151:15,17,24 1175:211198:11 1215:10 1250:6

Weyerhaeuser 1205:12we'll 1053:2,7,13,151054:18,23 1055:5,131055:20 1072:111164:16 1167:4 1249:121256:16 1267:10 1285:51316:8 1344:23 1353:191377:12 1378:8 1382:121382:13,14 1387:17

we're 1053:6,9,111055:12,21 1064:251066:3 1094:4,51097:25,25 1098:41107:24 1112:151113:18,19 1120:141131:12 1137:13 1140:11140:3,18,21,23 1144:61144:23 1145:4 1148:71149:2,13 1150:81155:13 1156:5,20



1161:13 1173:161183:23 1185:13,211188:11,16,21 1190:51191:21 1193:17,181194:2,12 1195:91196:14,15 1197:14,181197:22 1198:7 1201:61202:2 1210:19 1212:41212:5,5 1214:141216:1 1217:11 1219:31222:2,19 1223:31225:17 1231:16,251239:15 1249:11 1261:71267:14 1287:251290:13 1291:22,23,241291:25 1292:5,241293:8,8 1295:7 1300:81300:25 1303:8,91311:18,18 1315:151338:19 1344:8 1347:31360:25 1361:171367:25 1371:111379:19 1387:13

we've 1054:21,221071:14 1104:151114:10 1120:12 1144:31144:6 1145:5 1149:91155:12 1184:14,171185:9,10,10 1209:11212:2 1215:3,5,151217:8,22 1221:141222:3,14 1224:8,13,191224:21 1225:8 1231:141254:3 1295:4 1299:141299:15,17 1300:3,251313:17 1316:19 1327:11334:16,17 1357:131368:18 1380:201383:16,20 1385:21387:6

whatever's 1196:23whatsoever 1347:21whereof 1388:16Whirlwind 1118:211250:14 1264:11,231265:6 1266:20 1270:171300:4,4,8,22,24

white 1066:17 1067:31069:8,17 1083:41086:12 1143:141151:20 1176:22

1180:11 1194:141245:15,20,22,251246:3 1248:6 1249:251250:5,7,20 1251:5,251258:2,16,21 1259:21263:5 1313:7

wholly 1122:11 1280:241387:16

wide 1155:5widely 1100:13wide-sweeping 1141:25wife 1128:17wild 1049:16,18 1185:111294:25

Wilderness 1185:11wildfire 1381:16 1382:161382:23

wildfires 1080:1 1382:20wildlife 1052:3 1060:121096:3 1103:17 1150:131354:9 1356:11,221358:6 1367:11 1375:21

Williams 1139:3,4,81151:23

willing 1076:10 1097:241143:8 1167:5,201169:20 1208:251210:25 1216:6,101355:10

wind 1059:19,19 1078:161084:24 1094:5 1100:191123:2 1141:25 1142:81142:10,11 1146:91157:10 1202:191364:18

windblown 1113:231215:4

winding 1085:4windows 1366:24winds 1059:18 1078:221094:3 1123:23 1124:101124:18 1130:5,141138:16 1382:17,23

windstorms 1382:17,18winning 1186:15winter 1078:17 1129:241130:15

winters 1133:9wintertime 1150:231156:24

wisdom 1166:7

wish 1080:20 1172:201213:20

wishes 1125:15 1209:71213:14 1231:13

withdraw 1269:5 1276:21333:9

witness 1060:6 1122:231242:25 1246:251253:18 1267:8 1281:161286:12 1323:8 1327:251331:25 1338:251350:15,17 1363:221364:2,4 1387:51388:16

witnessed 1177:151188:1

witnesses 1051:3 1184:31184:4 1304:5

witnessing 1107:24woefully 1062:2woes 1148:17woman 1110:4 1137:121294:9

women 1121:3 1199:121199:19,20,25 1202:91202:13,16 1294:11

women's 1202:13wonder 1068:12 1168:111187:18 1351:201366:25

wonderful 1104:211134:19 1144:18 1173:81174:25

wondering 1115:14Woods 1147:4,6word 1131:22 1260:91261:13

worded 1332:21 1333:31333:11,21

wording 1355:23words 1092:23 1101:141317:1,4 1320:61333:10 1377:6 1378:6

work 1053:12,12 1065:151072:22 1088:25 1089:21093:3 1094:10 1098:31100:23 1104:231108:21 1115:151116:17,18 1129:121130:23 1136:251138:10,12 1140:23

1143:18 1149:7 1151:121153:14 1155:181161:11 1167:4,61174:2,8 1176:191181:1,10,19,20,21,221196:3 1197:16,17,251204:5,23 1211:131232:14 1233:7 1242:161245:24 1249:201256:20,25 1264:181273:11 1275:11,131277:7,16 1278:31286:23 1295:2 1300:211330:25 1352:4 1360:41360:16 1373:6 1375:91378:5

worked 1091:5 1106:81112:23 1119:13 1139:91143:17,20,22 1153:1,51173:14 1180:131181:17 1182:10 1196:81200:9 1201:6 1205:61210:9,10 1234:101241:19 1244:9,201277:11 1281:6 1296:81350:7 1351:12 1370:251385:5

worker 1200:2 1201:21223:7

workers 1060:19 1069:251072:16 1103:15 1108:51108:16 1112:22 1113:91151:1 1200:8,22,241201:15 1219:19,211240:23 1241:19,211242:10,11

workforce 1138:101219:11,17 1365:9

working 1153:3,13,161175:4 1187:17 1216:11270:24 1276:8 1300:241339:17 1358:13 1359:21359:5,6,21 1360:7,11

works 1170:25 1171:61174:6 1233:13 1286:11371:22

world 1084:18 1099:41103:1 1129:17 1133:121137:20 1144:1 1164:91182:10,23 1183:1,111183:19 1184:18,19



1185:4 1193:17 1203:71204:17 1294:8 1298:91334:20

worldwide 1102:241183:24 1303:4

worried 1075:14worries 1137:10worry 1305:25 1306:4worse 1062:20 1069:51071:15 1219:10

worst 1142:20 1346:251347:3,9,17

worth 1191:7wouldn't 1096:161097:11 1119:181132:18 1178:5 1249:191249:23 1255:6 1257:151260:25 1274:11,221287:8 1324:25 1325:171330:25 1352:21 1358:11367:22

wrap 1176:15Wright 1343:20Wrights 1154:22write 1071:22 1171:11187:2 1373:15 1378:1

writing 1053:6 1290:211364:14

written 1053:22 1054:141065:13 1071:241080:25 1081:1 1083:241084:4 1090:15,181104:15 1225:141251:13,22 1253:111259:24 1312:10

wrong 1085:2 1095:81177:21,24 1188:7,71202:12 1224:10 1293:41329:16 1376:15

wrote 1077:11 1143:251272:2 1285:25 1335:14

Wynkoop 1049:17Wyoming 1257:2

XX 1051:1 1052:1x-rays 1099:23

Yyard 1211:9yeah 1146:23 1149:12

1214:11 1222:101246:25 1263:151296:15 1301:16 1318:81363:7 1366:20 1367:251383:22

year 1069:10,20 1092:6,71112:3 1121:14 1122:181130:11 1138:9 1222:31222:20 1239:16,17,221240:25 1241:1 1265:211294:2 1305:23 1307:31322:13 1323:24 1324:81339:14 1341:1,21342:6,9,17,18

yearly 1320:10years 1062:24 1066:221067:21 1069:5 1070:231071:1 1080:3 1081:81081:10 1082:8,11,121082:14,14 1083:9,111086:7,9 1089:2 1091:21092:9 1094:16 1096:21101:20,21 1105:21106:11 1110:1 1112:231122:15,24 1124:14,211127:25 1128:7,211131:8 1132:5 1134:191135:1 1139:18 1141:71144:14 1145:22,241146:16,17,22 1148:131151:19 1153:4,41155:21 1157:7 1158:211160:21 1161:5,251163:2 1164:9,221171:24 1173:1 1175:151175:20 1176:2 1181:31181:9,10,12 1182:81184:15 1190:25 1191:41191:7 1197:3 1198:201200:19 1201:5,71202:25 1205:141207:23 1208:2,51210:18,20,21 1211:251214:19 1216:8 1222:71222:8 1224:8,9,231229:19 1241:7 1244:101252:18 1255:181271:17 1275:6 1277:121282:9,13 1291:71294:12 1295:251298:13 1299:13,14,19

1300:18,21 1301:81302:11 1339:6 1340:231341:10 1345:111347:16 1358:2,41371:12 1373:13 1374:21386:9

year's 1094:24yellow 1134:11 1294:11335:8 1349:12

yellowcake 1079:171085:7 1100:2 1124:11124:16 1146:201174:22 1178:25 1180:31180:4 1182:18 1183:201238:18,20,23

yesterday 1054:3 1305:4York 1122:25young 1137:21 1138:31162:22 1202:11

you-all 1083:22 1328:71372:23 1373:211382:15 1384:14 1385:4

yttrium 1199:23

ZZach 1051:12 1285:25zinc 1081:14 1199:16Zoellner 1143:25zoning 1085:23

$$1 1104:12 1106:221122:18 1159:24

$1,100,000 1088:14$1-1/2 1121:7$1.1 1078:3$100 1218:22 1219:8$104 1219:3$11 1063:14 1122:161159:17 1349:241386:16

$124 1218:12$13,000 1069:23$143 1090:8$15 1091:16 1125:13,14$152 1358:15$180,000 1300:23$2 1121:14,18$3 1104:12$35 1218:16,20$40 1246:14

$504 1107:8$86 1107:3

00053278 1318:130053906 1321:70054980 1361:70090888 1284:90135734 1329:230140897 1344:50147872 1309:120148045 1338:190148360 1335:30148403 1354:14021772 1272:1009 1153:3 1154:5

11 1171:10 1201:22 1225:31306:24 1307:1,41323:4 1356:6

1,000 1108:11 1320:31,000-ton-per 1368:171,000-ton-per-day1319:5,9 1323:41336:18 1338:131340:16 1342:191369:23,25 1370:12,221371:10,13

1,000-year 1098:221,056 1051:21,230 1051:21,232 1051:41,247 1051:81,267 1051:91,272 1051:101,284 1051:111,290 1051:21,300 1107:181,307 1051:21,308 1051:51,309 1051:131,318 1051:151,326 1051:171,329 1051:191,335 1051:211,337 1337:251,338 1051:221,348 1051:241,354 1052:31,361 1052:5



1,364 1051:51-9 1272:101:16 1198:810 1082:14 1086:231102:18 1123:4 1138:111139:20 1155:211182:13 1224:8 1231:171239:22 1240:251252:18 1290:11 1310:81371:12,23 1383:20,21

10th 1130:1010-hour 1371:2210-minute 1120:151344:19

10-17-12 1051:810:26 1120:1610:42 1120:16100 1072:20 1074:181081:8 1141:7 1142:121155:10 1225:7 1241:1

100-year 1081:8,111098:19 1106:20

104 1075:81045 1048:21105 1363:211 1090:9 1132:151148:11 1230:231298:14 1345:3,4,7

11-25-09 1051:13 1309:1511-8-10 1051:221100 1298:14112 1220:8119 1132:1112 1048:2,4,19 1143:151223:9 1230:23 1236:31266:7 1284:18 1350:121350:18 1368:2 1387:20

12-14-07 1051:1112:51 1198:8120 1062:17 1132:111228:15

13 1350:13,18 1351:241387:21

1318 1048:214 1351:24140 1149:22 1228:221383:11

141 1190:22 1384:19142341 1348:25144 1074:1215 1063:19 1090:10

1192:13 1198:6 1211:41252:18

150 1123:21500 1258:17 1304:71324:1,9 1333:251334:20 1335:13,18

1500-ton-per-day 1334:41334:14,18 1368:171370:23

1525 1049:221536 1049:1716 1126:416th 1388:21160 1280:13168 1229:1017 1246:251700 1049:3175 1074:1918 1087:10 1097:231173:1 1181:12 1211:141258:9 1312:14

18.4.3 1116:1118.6.1 1115:2318.8.6 1106:17185 1229:51850 1133:1719 1051:8 1086:2 1247:31247:4 1337:25

19th 1380:5,101909s 1070:211911 1049:101940s 1219:101949 1220:91950s 1070:241960s 1144:201963 1127:22,221966 1194:231971 1108:131972 1182:3,61974 1090:51975 1148:91977 1143:16 1144:131978 1223:181980 1084:10 1218:131980s 1107:12 1132:51981 1181:81982 1374:5,7,121984 1070:25 1219:11220:9

1988 1212:11990 1121:6 1194:25

1990s 1228:141996 1271:191999 1134:18

22 1136:10 1225:181229:11 1258:101259:13,18 1279:81323:19 1349:5,14,151371:24

2,000 1258:19 1370:14,182,000-ton-per-day1370:11

2.2 1201:242:00 1173:19 1231:172:11 1231:202:26 1231:2020 1051:9 1069:5 1092:11103:3 1142:7,9 1153:41192:4,14 1198:201201:5 1211:25 1252:181267:11,12,13 1294:121337:25 1366:24

20-year 1147:220.2 1293:13,21200 1155:1 1156:241241:2 1371:21

2000s 1228:162001 1304:142002 1226:72003 1229:25 1374:7,9,112005 1226:7 1227:211230:4

2007 1267:15,20 1343:121358:9 1359:23

2008 1218:24 1235:101236:23 1237:6 1296:22

2009 1066:25 1071:21074:11 1145:121148:10 1231:4 1236:231251:12 1259:24 1266:21266:2 1273:12 1309:211312:7,8,14 1316:151339:16 1348:211380:10

2010 1051:21 1230:231236:23 1251:12,221335:6 1338:24 1339:81354:9

2011 1251:22 1317:71318:6,25

2012 1048:4,19 1051:181246:25 1260:2,3,5,81265:25 1321:13 1323:11323:10,20 1360:11361:14 1387:20,211388:17

2013 1324:1,8 1388:182014 1079:192016 1086:8,152017 1112:721 1051:10 1272:8,12216 1388:2122 1051:11 1284:10,11220 1371:21222 1368:24 1369:1023 1051:13 1309:19,20238 1049:1024 1051:15 1318:15,161349:3 1350:13

24/7 1067:2125 1051:17 1132:5 1138:91153:4 1164:9 1326:91326:10 1370:15,17,21

25-11-203 1225:18250 1222:726 1051:19 1329:2427 1051:21 1267:201335:4

28 1051:22 1112:231338:20

28th 1069:2029 1051:24 1349:11369:15,20 1388:18

29th 1066:18

33 1074:13 1086:4 1136:101306:1,4 1356:21

3,000 1173:183.13 1116:143.9.1 1262:18,19 1266:173:00 1173:20 1231:173:15 1231:183:59 1290:1230 1052:3 1053:23 1086:81131:7 1145:24 1148:131175:15,20 1181:31192:4 1200:19 1201:51210:18,20,21 1224:231275:6 1295:25 1325:21354:15 1373:13



1387:1230s 1146:330th 1388:17300 1079:23 1241:21369:1

303 1049:1731 1052:5 1305:20 1361:81361:14

3200 1049:3349 1049:1335 1105:2 1123:5 1154:2436 1208:5 1382:19

44 1092:6 1225:16 1226:161226:21 1387:12

4,000 1088:194-5-11 1051:154:10 1290:1240 1067:21 1160:211163:2 1310:14 1325:21345:11,17,18

40s 1135:10 1146:340,000 1305:23 1306:140-year 1075:3 1125:211191:6,10

400 1112:443 1159:2244 1049:645 1120:13450 1239:17

55 1318:25 1371:125-3-10 1051:195-31-12 1052:55:35 1344:215:49 1344:2150 1092:6 1121:12 1123:31128:21 1132:131182:14 1216:8 1218:141224:9 1383:10

50s 1091:11 1135:101153:21 1184:8 1275:5

50-mile 1151:8500 1087:11,16,21,231121:12 1159:21 1304:61304:23 1307:3 1323:51326:22 1335:25 1336:61336:10,13,16 1342:221368:20

500-ton 1340:24500-tons-per-day1190:23 1336:9

500-ton-per-day 1280:171316:20 1326:13 1337:61340:15 1342:21 1343:21368:16 1369:13,191370:10 1371:12 1386:9

53 1106:1156-year-old 1143:14

66 1075:18 1260:4,81266:7

6:56 1387:15,1960 1151:3 1155:101218:14 1241:6 1369:211382:18 1383:10

60s 1091:12 1153:211181:23 1184:8,23

600 1049:6 1388:216215 1050:265 1367:86500 1258:1568-household 1155:2

77 1075:18 1086:4 1145:181225:15 1267:15 1354:8

7th 1049:227,000 1298:19,2270s 1154:6,7 1181:231184:8,24 1219:11

71 1111:16 1220:572 1145:17 1148:10750 1323:21 1324:8

88 1338:24 1339:88,000 1081:118-13-09 1051:248:30 1387:17,218:35 1048:1980 1054:9 1080:1 1102:171241:6 1310:11 1366:41370:15,16

80s 1184:9,24 1253:11313:7

80-mile 1298:25800 1192:4800,000 1080:3 1081:101222:3,8

80202 1049:17 1388:2180203 1049:4,2380228 1049:780303 1050:380540 1049:1381 1145:20 1147:191149:2,16 1152:15

81301 1049:1182 1374:884 1146:16,20,2285 1062:15 1092:131159:20

86 1132:12880 1142:4,9 1365:1989 1146:17,22

99 1103:18 1145:17,181363:5

9-7-10 1052:390 1384:1893 1298:15

Pinon Ridge Hearing Transcripts Part 5

Documents

san miguel

salt wash

san miguel

pinon ridge

rein van west

sheep mountain

pinon ridge

nuclear regulatory