1872 mining law, background radiation, BLM, Bureau of Land Management, Canada, cancer, Canyonlands National Park, clean water, clean-up standards, Daneros uranium mine, Daneros uranium mine expansion, dangers of nuclear, Denison, EnergyFuels, environment, Environmental Impact Study, Horsecollar ruins, KEPCO, Korea, Lundin Gold, Macusani Yellowcake, mining, mining remediation, Natural Bridges National Park, nuclear, nuclear energy, nuclear industry, nuclear power, nuclear reactors, nuclear waste, public comment, Public Lands, radioactive waste, risk management, Rock Art, Ron Hochstein, S. Korea, theft of resources, uranium, uranium mining, USA, Utah, water, White Mesa Mill
About how to comment here: https://miningawareness.wordpress.com/2016/07/27/attempt-by-canadian-miner-to-expand-uranium-mine-on-us-public-land-near-natural-bridges-national-monument-comment-deadline-monday-1st-august/ Deadline seems to be around 4 or 5 pm Utah time today, though it’s not clear. Comment asap today.
In the 2011 US BLM FONSI, the clean-up standard was supposed to be 0.1 mrem/yr for 2 weeks of camping. The 2016 BLM EA now has a volunteer clean-up standard of 100 mrem/yr for 2 weeks camping which is 1000 times higher radiation exposure. This is, actually, 2607 mrem per year (26 mSv), 100 times higher than the US EPA allows for operating nuclear reactors and other nuclear waste (25 mrem). One can’t assume that animals or future generations will only camp for 2 weeks at a time – radium 226 has a half-life of 1600 years. And, people should be shocked that their government allows campers to get 4 times more than US EPA annual (non-medical) radiation dose (25 mrem) in only 2 weeks.
Natural Bridges Monument is less than 10 miles from the uranium mine site
Even in 2011 the solution was to dump more dirt on the radioactive patches. They apparently still say they will do the soil cover, but they would not be held to the more protective standard, anymore. And, the miner, Energy Fuels, only intends to plant 70% of the 4% to 30% vegetative cover back, and only monitor for a few years, so there will be nothing to hold back erosion during major floods that strike the area. Sarah Fields of Uranium Watch was quoted in the Salt Lake Tribune last Friday, 29 July 2016, as pointing out that a 2013 flood washed away the system set up to control run-off at the current, much smaller, mine. She further pointed out that the BLM’s EA makes no mention of “more intense flood events“. “It’s in a very narrow canyon that will eventually erode and they have no plan for long-term care,” she added.
BLM-EF Attachment F Vegetation and Soil Survey
Oh, but it gets even worse: “Revegetation would also be considered complete if the BLM and UDOGM determine that the site is stable and revegetation work has been satisfactorily completed within practical limits, ” says both the BLM and Energy Fuels POO. “Practical limits” is a bald-faced loophole.
In the 2011 FONSI (Findings of No Significant Impact) for the Daneros Uranium Mine expansion, the BLM states that “A gamma survey by a certified Radiation Safety Officer shall be conducted on the waste rock dump after application of cover material and prior to seeding. The survey report shall be submitted to BLM. If the gamma radiation dose, assuming a 14-day exposure period, is found to exceed 0.1 mrem/yr over background, then UEC shall apply additional cover material to meet this standard” http://web.archive.org/web/20160731030027/https://eplanning.blm.gov/epl-front-office/projects/nepa/54345/73737/81003/Appendix_A_-_2011_BLM_FONSI-DR_Conditions_and_Requirements.pdf
Not only is this 0.1 mrem/yr much higher than they pretend, but this point disappeared from the recent FONSI which simply states: “This unsigned FONSI and the attached EA (DOI-BLM-UT-Y020-2016-0001-EA) for the Daneros Mine Plan Modification are available for public review throughout the 30 day public comment period, which closes July 18, 2016. [Now August 1st] Based on the analysis of potential environmental impacts in the attached EA and consideration of the significance criteria in 40 CFR 1508.27, I have determined that with the design features of the proposed Mine Plan Modification, the Proposed Action would not result in significant impacts on the human environment. An environmental impact statement (EIS) is not required. The decision to approve or deny the Proposed Action and if appropriate a signed FONSI with rationale, will be released after consideration of public comments and completion of the EA.” https://web.archive.org/web/20160731024343/https://eplanning.blm.gov/epl-front-office/projects/nepa/54345/75268/82977/UNSIGNED_FONSI_06.15.2016.pdf (What about animals and the animal environment? Why not return it to the background state it was at, or better. Canadian miner Energy Fuels, like other hardrock miners on public land, is getting uranium without even paying the US government royalties. And, apparently there is a loophole to avoid taxes, so they could return it to better than it currently is: “the PDA allows mining companies to take tax deductions on mineral deposits that they received for FREE under the antiquated 1872 Mining Law, the PDA constitutes a double subsidy. You take the gold, copper, silver, uranium or other metals from public lands for free, and then you get to deduct the value of part of those minerals from your taxes even though you never paid for them in the first place!” See more at: https://www.earthworksaction.org/earthblog/detail/budget_cuts_for_everyone_except_for_mining_industry_subsidies )
Instead, Energy Fuels proclaims in its 2016 POO: “However, despite the absence of federal or state standards, Energy Fuels proposes to voluntarily reclaim the DRAs to a standard dose of 100 millirem/year (mrem/yr) or less above background to a person camping on or near a DRA for 14 days for its mines in Utah.” (p. 4-7), which is actually 2,607 mrem (26 mSv) per year! This is over 100 times the 25 mrem (0.25) US EPA annual standard for public exposure to an operating reactor and nuclear waste.
The 0.1 mrem also appears missing from the BLM Environmental Assessment:
“188.8.131.52 Radiological Protection No federal or State of Utah radiological standards exist for reclamation of the DRAs at uranium mine sites. The Nuclear Regulatory Commission (NRC) has specifically excluded natural ores from regulation under the Atomic Energy Act (Section 6.2 of the Atomic Energy Act – 42 United States Code [USC] 2092 and as set forth in 10 Code of Federal Regulations [CFR] 40.13(b)). However, despite the absence of federal or state standards, Energy Fuels proposes to voluntarily reclaim the DRAs to a standard dose of 100 millirem (mrem) or less above background to a person camping on or near a DRA for 14 days for its mines in Utah. This standard falls within the radiation protection concept of ALARA (As Low As is Reasonably Achievable). The 100 mrem standard is supported technically by recommendations from the National Council on Radiation Protection and Measurements (NCRP). In addition, the standard is consistent with the numerical public dose protection standard set by the NRC for uranium milling facilities as set forth in 10 CFR Part 20.1301, Subpart D. The proposed inert material/soil cover on the development rock piles is expected to provide for compliance with this proposed reclamation standard at the Daneros Mine. A post-reclamation gamma survey and assessment of compliance with the voluntary reclamation standard would be conducted after mining and reclamation are complete.” (p.27) http://web.archive.org/web/20160731024049/https://eplanning.blm.gov/epl-front-office/projects/nepa/54345/73737/82821/Daneros_EA_06.09.2016.pdf
Now, what happened here? Between the FONSI of 2011 and 2016 it went from a requirement of 0.1 mrem per year by the BLM (assuming you only camp for 14 days) to a voluntary 100 mrem (assuming you only camp for 14 days). If someone stays a year, or animals stay a year, the 0.1 mrem is actually 2.6 mrem (0.026 mSv) above background – and they manipulate background. The 100 mrem is actually 2607 mrem per year (26 mSv) above background.
Whereas the BLM’s EA refers to 150 to 300 mrem (1.5 to 3 mSv) in a nearby town as the average background radiation, the average background gamma tested by Energy Fuels POO, 2016, p. 3-20 for the actual site is 5 microR per hr, approximately 5 microrem (for gamma), which is 43.8 mrem (0.438 mSv/yr): “Gamma survey data for the Daneros and Bullseye portal areas and the South Portal area are shown in Figures 3-5 and 3-6, respectively, and additional information is presented in Attachment E. Background gamma radiation in the Daneros Mine area is approximately 5 microroentgen (µR/hr). Areas containing development rock from historic or recent mining activities, exhibit higher gamma activity with values of up to 370 µR/hr present in localized areas. Historic development rock present in the South Portal Area from previous operations exhibit gamma radiation values of approximately 50 to 100 µR/hr.”
So, it could be 2.6 plus 44, i.e. 47 mrem (0.47 mSv), or 2,607 mrem (26.1 mSv) plus 44 mrem or up to 300 mrem, plus 2,607 mrem, i.e. 2,907 mrem (29 mSv) Clearly the choice of background level and the choice of cleanup standard make a big difference. Even the 47 mrem is almost twice the EPA standard for operating reactors and waste, and the 2907 mrem standard is over 100 times greater. So much for camping for your health. Know before you go!
What kind of risk are we talking about? According to the US government funded, BEIR VII report, when a population is exposed to 100 mSv (10,000 mrem), approximately 1% will get cancer. So, the 29 mSv would be almost 1/3rd of 1%. Approximately half will die of these life-shortening cancers. Life-shortening effects are of the order of 14 to 15 years, meaning that people will die, on average around retirement age. BEIR VII’s high end estimate was 3%, meaning this would be close to 1%. A recent government funded study of nuclear workers suggests an estimate of 15% or greater excess cancer risk due to 100 mSv exposure alone. So, the 29 mSv would be almost 1/3rd of 15%, i.e. approximately 4% excess cancer rates, from this exposure alone. These are unacceptable and unnecessary risks. See: https://miningawareness.wordpress.com/2015/12/19/another-look-at-the-recent-low-dose-radiation-exposure-study-inworks/ ]
Says the BLM (2016): “Underground uranium mines do not require licensing under NRC regulations and, therefore, mine operators are not required to meet the standard dose limit for the public specified at 10 CFR 20.1301(a)(1). However, the NRC standard (100 mrem/yr over background) is considered a guideline for the protection of human health and safety and is incorporated into the MPOM. The proposed inert material/soil cover on the development rock piles is expected to provide for compliance with this proposed reclamation standard at the Daneros Mine. A post-reclamation gamma survey and assessment of compliance with the voluntary reclamation standard would be conducted after mining and reclamation are complete.” (p. 72) http://web.archive.org/web/20160731024049/https://eplanning.blm.gov/epl-front-office/projects/nepa/54345/73737/82821/Daneros_EA_06.09.2016.pdf
In 2014 “Energy Fuels modeled a typical DRA (or waste rock pile) for the northern Colorado Plateau region (see Section 6.0 in Appendix E) to determine the radiological dose that could be received at a reclaimed (regraded with soil cover and vegetation) and un-reclaimed (i.e., no soil cover) DRA over 14 days (longest period that a person can legally camp on public lands managed by the BLM). The modeling results (see Table 25) indicated that a 100-mrem dose limit based on 14 days of exposure could be met without applying any soil cover. The modeling effort also evaluated the dose received by a person on the DRA for 2,000 hours per year. Under that scenario, a relatively thin soil cover would be needed to maintain the dose at less than 100 mrem/yr above background.” (p. 72.) http://web.archive.org/web/20160731024049/https://eplanning.blm.gov/epl-front-office/projects/nepa/54345/73737/82821/Daneros_EA_06.09.2016.pdf Remember that for the 2011 FONSI that the soil cover was to help bring it down to 0.1 mrem per year, which it still could until erosion occurs. And, floodwaters barreling down the canyon could quickly erode soil cover, whether thick or thin. Since they’ve just upped the “standard” by 1000 fold, it is doubtful they will try to do better, even though this Penny Stock Mining Co., worth just over 2 dollars US per share appears to have the Lundin mining group-family and the South Korean Government (via KEPCO) behind it.
From Energy Fuels POO (Plan of Operations), 2016, 2013:
pp. 4-8: “The proposed inert material/soil cover on the development rock areas is expected to provide for compliance with this proposed reclamation standard at the Daneros Mine. A post-reclamation gamma survey and assessment of compliance with the voluntary reclamation standard will be conducted after mining and reclamation are complete. This rock management plan will mitigate adverse effects that could be caused by the Daneros Mine development rock piles and provide for reclamation success after mining is completed.
If a radiological regulatory standard for reclamation of uranium mines is implemented by DOGM prior to final reclamation of the Daneros mines, Energy Fuels will work with DOGM to evaluate if it can be applied to future Daneros reclamation efforts without excessive cost or major changes to our reclamation plans.”
“4.9 Post-Closure Management
After reclamation is completed, post-closure monitoring and maintenance is anticipated to take 3 to 5 years. Success and progress of revegetation efforts are dependent on seasonal growth patterns, precipitation, and weather patterns. Additional erosion control measures and seeding may be required during the post-closure period to meet BLM and UDOGM reclamation standards.
Revegetation success will be measured in accordance with UAC Rule R647-4-111 such that revegetation has achieved 70 percent of the pre-mining vegetative ground cover. In addition, the vegetation must survive three growing seasons following the last seeding. Revegetation will also be considered accomplished if the BLM and UDOGM determine that the site is stable and revegetation work has been satisfactorily completed within practical limits. This provision of the rules is especially applicable to mine sites such as the Daneros Mine where historic mining activities have decreased the amount of salvageable topsoil. A vegetation survey was conducted for the purpose of establishing pre-mining vegetative ground cover as discussed in Section 8.4 and detailed in Attachment F.”
[WHAT’S 70% REVEGETATION OF 4 TO 30%? HOW LONG WILL THAT HOLD BACK EROSION IN THIS SLOPED CANYON ENVIRONMENT? 3 TO 5 YRS? How much is left when it becomes “Within practical limits? ]
From p.8-8 of the EF POO:
“This survey identified 36 vegetative species including grasses, forbs and cacti with vegetative cover ranging from 4 to 30 percent in seven point-intercept method vegetation survey transects. The average vegetative cover within the seven transects was 16 percent. The project area is not heavily infested by noxious weeds and saltcedar (tamarisk) was the only species noted within the plant survey area (within 200 feet surrounding project features). Other invasive species noted in the area included Russian thistle, saltlover (halogeton), and cheatgrass“.
From EF POO p. 5-5: “The air volume of the mine exhausts and the measured radon concentrations within the exhausts are utilized by Energy Fuels to derive an annual radon emission rate estimate. The annualized emission rate data, the physical parameters of the mine exhaust, and the location of the nearest resident are entered into EPA’s computer model (Comply-R) or an equivalent EPA approved model. The model output is compared against the 10 mrem/yr incremental dose limit for the general public (i.e., the nearest residents) to determine if the mine is in compliance or whether there is a need for further radon control. Although the 10 mrem/yr standard is very low (typical annual radiation doses received from natural background sources for people living in this part of Utah are in excess of 400 mrem/yr), exceedance of the standard is very unlikely given the mine’s remote location and the lack of nearby residents.” [MISLEADING-DISTORTION. In the EA, the BLM claims that “Radon and airborne particulates (Inhalation)” are 230 mrem for the national average and 260 mrem for that area of Utah. Thus, the correct comparison appears to be 260 mrem. They (BLM-DOE) claim 30 mrem for food ingestion. And, a total of 310 mrem and 430 mrem respectively, i.e. 3.1 mSv and 4.3 mSv. Compare to worldwide average annual dose of 2 mSv, of which 1.1 is inhaled radon and ingested radionuclides. How much of the much higher US average is from ingestion of natural potassium 40 and how much is from mining, nuclear reactors, and weapons testing and radioactive waste contaminating food, water, air, land? The amount of natural potassium, a very tiny fraction of which is radioactive, should be the same for all people in the world, suggesting that the higher amounts are from uranium mining; fallout from weapons testing, nuclear reactors, nuclear fuel production, and nuclear waste, all of which legally and sometimes illegally discharge radioactive materials to the environment. Furthermore, “… when radon gas migrates through the atmosphere, the solid radon progeny are deposited on the soil and water below, entering into the food chain and hence the bodies of birds, animals, fish and insects.” http://www.ccnr.org/radon_chart.html Radon becomes radioactive lead with a half-life of decades. The mine is less than 10 miles from a Natural Bridges National Park-Monument.
What of animals? Well, they are supposed to go someplace for a couple of decades and return to an even more radioactive environment, it seems!
Says Energy Fuels:
“4.4 Wildlife Habitat Rehabilitation Land uses prior to proposed mine disturbance included uranium mining, recreation, livestock grazing, and wildlife habitat. The post-mining land will be returned to recreation and wildlife land uses on a natural landscape. Seed mix(es) have been designed to reflect the species composition observed within the project area and surrounding landscape, as well as those not observed, but typically associated with the landscape, soil type, elevation, and precipitation of the resource management area“. p. 4-4 EF POO, Plan of Operations Modification UTU-74631 June 2016 Danero s Mine San Juan County, Utah
Energy Fuels’ research, as reported, suggests that a few inches of soil might bring the radiation exposure down (assuming their assumptions are correct), but it is still works out to be around 195 mrem per year (1.9 mSv) above background. The 2011 FONSI said to keep dumping dirt until they arrived at the 0.1 mrem, but there will be erosion. With floodwaters barreling through the canyon, the erosion may occur quickly. The most common isotopes of radium are Ra-226 and Ra-228. Ra-226 is part of the uranium decay series. Ra-228 and Ra-224 are part of the thorium decay series. All isotopes of radium are radioactive. Radium decays to produce radon gas. Ra-226 has a half life of 1600 years; Ra-228 of 5.75 years.
“Evaluation of the Radiological Characteristics of Uranium Mine Waste Rock“, 2014
According to Spycher et. al. (2015), “The worldwide annual dose of 2 mSv represents total background radiation and includes inhaled radon gas and ingested radionuclides. The appropriate comparison is with cosmic and terrestrial gamma radiation, which together contribute an annual average of 0.9 mSv worldwide (UNSCEAR 2000).” “Response to “Comment on ‘Background Ionizing Radiation and the Risk of Childhood Cancer: A Census-Based Nationwide Cohort Study’” http://dx.doi.org/10.1289/ehp.1510111R Refers to http://dx.doi.org/10.1289/ehp.1408548 volume 123 | number 8 | August 2015 • Environmental Health Perspectives Ben D. Spycher, Martin Röösli, Matthias Egger,and Claudia E. Kuehni.
According to the EA: “184.108.40.206 Post-Closure Management After reclamation is completed, post-closure monitoring and maintenance would be anticipated to require 3 to 5 years. Success and progress of revegetation efforts would be dependent on seasonal growth patterns, precipitation, and weather patterns. Additional erosion control measures and seeding may be required during the post-closure period to meet the BLM and UDOGM reclamation standards. Revegetation success would be measured in accordance with UAC Rule R647-4-111 such that revegetation has achieved 70 percent of the pre-mining vegetative ground cover. In addition, the vegetation must survive three growing seasons following the last seeding. Revegetation would also be considered complete if the BLM and UDOGM determine that the site is stable and revegetation work has been satisfactorily completed within practical limits. ” p. 30
United States Department of the Interior Bureau of Land Management, “Environmental Assessment Daneros Mine Plan Modification”, May 2016 BLM EA: http://web.archive.org/web/20160731024049/https://eplanning.blm.gov/epl-front-office/projects/nepa/54345/73737/82821/Daneros_EA_06.09.2016.pdf
From Energy Fuels POO:
“Section 4 Reclamation Plan“, pp. 4-7
“No federal or State of Utah radiological standards exist for reclamation of the DRAs at uranium mine sites. The Nuclear Regulatory Commission (NRC) has specifically excluded natural ores from regulation under the Atomic Energy Act (Section 6.2 of the Atomic Energy Act (42 U.S.C. 2092), and as set forth in 10 CFR 40.13(b)). However, despite the absence of federal or state standards, Energy Fuels proposes to voluntarily reclaim the DRAs to a standard dose of 100 millirem/year (mrem/yr) or less above background to a person camping on or near a DRA for 14 days for its mines in Utah.” 2013 and 2016 version appear the same: “Plan of Operations Modification UTU-74631 June 2016 Danero s Mine San Juan County”
From the EA, public exposure as high as 10 mrem per hour, 6 ft away! “Radiological impacts to the public would also occur as a result of exposure to low levels of radiation near the haul trucks transporting ore to the White Mesa Mill. Regulatory limits (49 CFR 173.441 and 10 CFR 71.47) were established to protect the public and limit exposure to 10 mrem/hr at 6 feet from the sides of the haul trucks (see MPOM Attachment N). The U.S. Department of Transportation (USDOT) also requires that ore shipments be covered, placarded, and monitored for gamma radioactivity levels at specified distances from the trailer.” p. 95 http://web.archive.org/web/20160731024049/https://eplanning.blm.gov/epl-front-office/projects/nepa/54345/73737/82821/Daneros_EA_06.09.2016.pdf (Beware not to camp or stay in a hotel near one of the trucks.)
The miner has done a Gamma survey but what about alpha and beta for inhalation ingestion?
“… when radon gas migrates through the atmosphere, the solid radon progeny are deposited on the soil and water below, entering into the food chain and hence the bodies of birds, animals, fish and insects.” http://www.ccnr.org/radon_chart.html
“* 222Rn, 3.8 days, alpha decaying to…
* 218Po, 3.10 minutes, alpha decaying to…
* 214Pb, 26.8 minutes, beta decaying to…
* 214Bi, 19.9 minutes, beta decaying to…
* 214Po, 0.1643 ms, alpha decaying to…
* 210Pb, which has a much longer half-life of 22.3 years, beta decaying to…
* 210Bi, 5.013 days, beta decaying to…
* 210Po, 138.376 days, alpha decaying to…
* 206Pb, stable.”
From the EPA:
“Radium (chemical symbol Ra) is a naturally occurring radioactive metal. Radium is a radionuclide formed by the decay of uranium and thorium in the environment. The most common isotopesof radium are Ra-226 and Ra-228. Ra-226 is part of the uranium decay series. Ra-228 and Ra-224 are part of the thorium decay series. All isotopes of radium are radioactive. Radium decays to produce radon gas.
Ra-226: 1,600 years | Ra-228: 5.75 years
half life: Ra-224: 3.66 days | Ra-226: 1,600 years | Ra-228: 5.75 years
In the natural environment, radium occurs at trace levels in virtually all rock, soil, water, plants and animals. Trace levels can also be found in the air.
In areas where radium concentrations in rocks and soils are higher, the ground water also typically has relatively higher radium content.
Milling of uranium concentrates radium in the tailings. Uranium mining also results in higher levels of radium in nearby water. Radium may concentrate in fish and other aquatic animals. Plants and vegetation may take up radium from the soil.
Chronic exposure to high levels of radium can result in an increased incidence of bone, liver or breast cancer.
decay chainThe series of decays or transformations that radionuclides go through before reaching a stable form. For example, the decay chain that begins with Uranium-238 culminates in Lead-206, after forming intermediates such as Uranium-234, Thorium-230, Radium-226, and Radon-222. Also called the “decay series.” https://www.epa.gov/radiation/radionuclide-basics-radium
Compliance and Monitoring Requirements Daneros Mine Plan of Operations
A gamma survey by a certified Radiation Safety Officer shall be conducted on the waste rock dump after application of cover material and prior to seeding. The survey report shall be submitted to BLM. If the gamma radiation dose, assuming a 14-day exposure period, is found to exceed 0.1 mrem/yr over background, then UEC shall apply additional cover material to meet this standard….”
2009 EA, apparently for the smaller uranium mine:
As a rule of thumb, 1 roentgen is approximately 10 mSv.
Background gamma radiation in the Daneros Mine area is approximately 5 microroentgen (µR/hr). (See p. 3-20, Energy Fuels POO_
which is 0.438 mSv; 43.8 mrem
Rem stands for Roentgen Equivalent Man, and for x-rays and gamma a roentgen should be approximately a rem. 100 mrem is 1 mSv. 1 rem is 10 mSv. For other types of radiation, such as alpha, beta and neutrons there would need to be a weighting factor.
“Evaluation of the Radiological Characteristics of Uranium Mine Waste Rock“, 2014
2013 POO seems identical, or almost identical, to the 2016 one: http://web.archive.org/web/20160731011742/http://www.blm.gov/style/medialib/blm/ut/monticello_fo/Minerals/Daneros_Plan_Modification.Par.36950.File.dat/Daneros%20Plan%20of%20Operations_201312.pdf
IF ENERGY FUEL’S PLAN OF OPERATION IS POO, WHAT DOES BLM STAND FOR? BUREAU OF LIQUIFIED MANURE? Nope, can’t be. Liquified manure has uses such as fertilizer and biofuel.
“BLM set to approve expansion of inactive uranium mine in Utah“, By BRIAN MAFFLY, The Salt Lake Tribune , First Published Jul 29 2016 06:30PM, Last Updated Jul 29 2016 09:46 pm