ENFORCE31823 - Laserfiche WebLink

Home Browse Search

Cotter's modeling, which the GeoScience Services' February 7, 2006, letter described as based on the assumed "transport of the uranium as a complex carbonate species (i.e. UOZCO3)." The same deficiencies exists for the other additional contaminants that may be released from the ore and/or waste rock material. This includes toxic or acidic releases to surface and/or groundwater, and also releases to air via blowing dust resulting in public or mine worker exposure. The record similazly lacks basis as to releases from air sources. Although not as mobile as uranium in groundwater, the high radium content of the ores in the Uravan azea pose a serious health threat that has received no analysis by the Division. Radium- 226 activity documented by EPA at most mine sites is particulazly high in the ores stockpiles and forms the key metric for human health risks. While high uranium concentrations may be -and often are -measured in wastes, uranium mining TENORM is generally characterized by its more hazazdous decay products. In particulaz, the concentration of radium-226 is a key metric for purposes of classifying waste materials. Radium is the radionuclide of interest at uranium TENORM sites for two reasons: its decay products give off strong gamma radiation that is easy to measure, and it has the most significance for human health risks due to radon generation. Exh. 5 at 3-21 . Although radium poses serious health threats, the March 2006 analysis does not consider adverse effects from radium in the ore stockpiles. Under the MLRA, the proper place for the analysis of the unique factors posed by uranium mines - and the measures necessary to address and treat the toxic and acid-forming materials - is the Environmental Protection Plan ("EPP") that is required by the DMO designation. Not only is a non-DMO status unsupported by facts the mine file, providing SM-18 with anon-DMO determination or a DMO exemption would short-circuit the statutory process meant identify and address these problems. Some examples of wastewater strategies that could be considered for inclusion in the EPP are discussed by EPA and include: The objective of preventive strategies is to avoid generation of acidic wastewaters and contaminated water from closed or abandoned mines and to reduce the amount of contamination needing remediation. The planning of mine closure activities generally gives priority to preventive strategies whenever possible. Following aze some of the preventive strategies and goals that may be applicable: Underground Mines • Avoid mixing good and poor wafer quality in actively managed mines. • Allow flooding of decommissioned mines to reduce the atmospheric oxygen available and the mobilization of contaminants if there is no connection from the mine to surface or groundwater.