Subject Area: Water Resources and Environmental Sustainability

Issues and Impacts: Uranium Mining and Drinking Water Supplies in Virginia

Issues and Impacts: Uranium Mining and Drinking Water Supplies in Virginia

About the Water Research Foundation The Water Research Foundation is a member-supported, international, 501(c)3 nonprofit organization that sponsors research that enables water utilities, public health agencies, and other professionals to provide safe and affordable drinking water to consumers. WaterRF’s mission is to advance the science of water to improve the quality of life. To achieve this mission, WaterRF sponsors studies on all aspects of drinking water, including resources, treatment, and distribution. Nearly 1,000 water utilities, consulting firms, and manufacturers in North America and abroad contribute subscription payments to support WaterRF’s work. Additional funding comes from collaborative partnerships with other national and international organizations and the U.S. federal government, allowing for resources to be leveraged, expertise to be shared, and broad-based knowledge to be developed and disseminated. From its headquarters in Denver, Colorado, WaterRF’s staff directs and supports the efforts of more than 800 volunteers who serve on the board of trustees and various committees. These volunteers represent many facets of the water industry, and contribute their expertise to select and monitor research studies that benefit the entire drinking water community. Research results are disseminated through a number of channels, including reports, the Website, Webcasts, workshops, and periodicals. WaterRF serves as a cooperative program providing subscribers the opportunity to pool their resources and build upon each others’ expertise. By applying WaterRF research findings, subscribers can save substantial costs and stay on the leading edge of drinking water science and technology. Since its inception, WaterRF has supplied the water community with more than $460 million in applied research value. More information about WaterRF and how to become a subscriber is available at www.WaterRF.org.

Issues and Impacts: Uranium Mining and Drinking Water Supplies in Virginia

Prepared by: Ben Wright and Ben Stanford Hazen and Sawyer, P.C., New York, NY 10018

Sponsored by: Water Research Foundation 6666 West Quincy Ave Denver, CO 80235

Published by the

DISCLAIMER

This study was funded by the Water Research Foundation (WaterRF). WaterRF assumes no responsibility for the content of the research study reported in this publication or for the opinions or statements of fact expressed in the report. The mention of trade names for

commercial products does not represent or imply the approval or endorsement of WaterRF. This report is presented solely for informational purposes.

Copyright ©2013 by Water Research Foundation

ALL RIGHTS RESERVED.

No part of this publication may be copied, reproduced or otherwise utilized without permission.

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CONTENTS

FOREWORD ................................................................................................................................. vi 

ACKNOWLEDGMENTS ............................................................................................................ vii 

INTRODUCTION .......................................................................................................................... 1  BACKGROUND ............................................................................................................................ 2  DESCRIPTION OF PRESENTATIONS AND DISCUSSION ..................................................... 4 

National Academy of Sciences Uranium Study Overview - Scott Brooks, Oak Ridge National Laboratory ................................................................................................ 4 

Nuclear Regulatory Commission Licensing Overview - Dan Gillen, Independent Consultant ............................................................................................................... 5 

Virginia Department of Health Office of Drinking Water Perspective - John J. Aulbach II, Virginia Department of Health Office of Drinking Water ................................. 6 

Uranium Tailings Management: Risks, Regulatory Requirements and Best Management Practices –Kimberly Finke Morrison, Morrison Geotechnical Solutions, Inc. ....... 7 

Virginia Beach Modeling Study Review - Peter Pommerenk, City of Virginia Beach ...... 8 Heavy Precipitation Events: Past Trends, Causes, and Future Trends - Ken Kunkel,

National Oceanic and Atmospheric Administration and North Carolina State University ................................................................................................................ 9 

State of the Science: Water Treatment - Ben Wright, Hazen and Sawyer ....................... 10  FURTHER READING ................................................................................................................. 12 

ABBREVIATIONS .......................................................................................................................13 

APPENDIX A: MATERIALS PREPARED PRIOR TO THE FORUM ................................... A-1 APPENDIX B: WORKSHOP PRESENTATIONS.....................................................................B-1

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FOREWORD

The Water Research Foundation (WaterRF) is a nonprofit corporation that is dedicated to the implementation of a research effort to help drinking water utilities respond to regulatory requirements and address high-priority concerns of the water sector. The research agenda is developed through a process of consultation with WaterRF subscribers and other drinking water professionals. Under the umbrella of a Strategic Research Plan, the Board of Trustees and Board-appointed volunteer committees prioritize and select research projects for funding based upon current and future needs, applicability, and past work. WaterRF sponsors research projects through the Focus Area, Emerging Opportunities, and Tailored Collaboration programs, as well as various joint research efforts with organizations such as the U.S. Environmental Protection Agency and the U.S. Bureau of Reclamation.

This publication is a result of one of these sponsored studies, and it is hoped that its findings will be applied in communities throughout the world. The following report serves not only as a means of communicating the results of the water industry's centralized research program but also as a tool to enlist the further support of the nonmember utilities and individuals.

Projects are managed closely from their inception to the final report by WaterRF's staff and large cadre of volunteers who willingly contribute their time and expertise. WaterRF serves a planning and management function and awards contracts to other institutions such as water utilities, universities, and engineering firms. The funding for this research effort comes primarily from the Subscription Program, through which water utilities subscribe to the research program and make an annual payment proportionate to the volume of water they deliver and consultants and manufacturers subscribe based on their annual billings. The program offers a cost-effective and fair method for funding research in the public interest.

A broad spectrum of water supply issues is addressed by WaterRF's research agenda: resources, treatment and operations, distribution and storage, water quality and analysis, toxicology, economics, and management. The ultimate purpose of the coordinated effort is to assist water suppliers to provide the highest possible quality of water economically and reliably. The true benefits are realized when the results are implemented at the utility level. WaterRF's trustees are pleased to offer this publication as a contribution toward that end.

Roy L. Wolfe, Ph.D. Robert C. Renner, P.E. Chair, Board of Trustees Executive Director Water Research Foundation Water Research Foundation

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ACKNOWLEDGMENTS

The authors would like to express their appreciation to the Water Research Foundation and to WaterRF project manager Kim Linton for supporting this project, additionally, this project would not have been possible without the leadership and support provided by Tom Leahy and Peter Pommerenk of the City of Virginia Beach Department of Public Utilities and Kristen Lentz of the City of Norfolk Department of Utilities. Further, we are grateful to the City of Richmond Department of Public Utilities for the generous use of their training facility and assistance with workshop logistics. The authors also extend sincere and heartfelt thanks to all of the speakers who generously volunteered their time and energy to share their expertise and educate our audience.

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INTRODUCTION

As uranium spot prices increased through the early 2000s, interest in developing a known uranium deposit (Coles Hill) in southside Virginia increased, reigniting the debate over lifting a statewide moratorium on uranium mining that has been in effect since 1982. The Uranium Working Group (UWG) was established by Governor McDonnell in January 2012 to provide a scientific policy analysis to help assess whether the moratorium on uranium mining in the Commonwealth should be lifted and create a draft statutory and conceptual regulatory framework. The UWG’s report was completed on November 30, 2012 in anticipation of potential legislation to lift the moratorium on uranium mining during the 2013 General assembly session. Further a series of other reports and studies have been completed evaluating the issue from various perspectives, including a comprehensive analysis by the National Academy of Sciences, modeling studies on contamination of its water supply by the City of Virginia Beach, and a number of site-specific economic and environmental studies of the Coles Hill site.

If the Commonwealth of Virginia were to lift the moratorium on uranium mining, the development of the Coles Hill site in the Roanoke River basin would represent a wholly new potential risk to water supplies downstream. In addition to the Coles Hill site, however, the Virginia Department of Mines Minerals and Energy (DMME) has identified other formations around the state with elevated uranium content. These formations cut across all of the major river basins in Virginia. If allowed, there is a possibility that other economically viable deposits could be mined in any of these areas.

Given the uniqueness of uranium mining in Virginia, its potential impacts on drinking water supplies, and the complexity of Nuclear Regulatory Commission regulations, an educational forum was proposed in order to familiarize Virginia’s drinking water community with the current state of knowledge on this topic supported by speakers with expertise on uranium mining from other regions of the country.

This memorandum summarizes the presentations and discussions during the forum Issues and Impacts: Uranium Mining and Drinking Water Supplies held on December 11, 2012 in Richmond, Virginia. Refer to the appendix for the original invitation, agenda, background material, and speaker bios sent to invitees prior to the forum.

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BACKGROUND

Conventional uranium mining and milling consists of removing uranium ore from the ground followed by crushing and grinding the ore to produce fine particles. The fine particles are mixed with leaching agents (lixiviant) to dissolve uranium ions and separate them from the residual solids (tailings). Uranium is then recovered (stripped) from the pregnant lixiviant in the final step (precipitation) to produce yellow cake, followed by drying and packaging (Figure 1). The tailings and process wastewater are disposed of in a tailings storage facility (TSF). Typically uranium represents a small proportion of the ore rock, such that most of the mined ore is disposed of in the TSF. For example, one million pounds of 0.1% uranium ore would yield 999,000 pounds of waste tailings. The tailings and process wastewater contain residual radionuclides, heavy metals, and residual chemicals; therefore the tailings facility must be constructed to limit releases into the environment. Once the mining and milling operations are complete, the TSF is closed and must remain in perpetuity. Perpetual storage of uranium tailings is required because of the radionuclides with long half lives (Figure 2).

Figure 1. Generalized uranium mill physical layout (Source: USEIA, 2011)

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Symbol Element Radiation Half-Life

U-238 Uranium-238 alpha 4.5 billion years

Th-234 Thorium-234 beta 24.1 days

Pa-234 Protactinium-234 beta 1.17 minutes

U-234 Uranium-234 alpha 247,000 years

Th-230 Thorium-230 alpha 80,000 years

Ra-226 Radium-226 alpha 1,602 years

Rn-222 Radon-222 alpha 3.82 days

Po-218 Polonium-218 alpha 3.05 minutes

Pb-214 Lead-214 beta 27 minutes

Bi-214 Bismuth-214 beta 19.7 minutes

Po-214 Polonium-214 alpha 1 microsecond

Pb-210 Lead-210 beta 22.3 years

Bi-210 Bismuth-210 beta 5.01 days

Po-210 Polonium-210 alpha 138.4 days

Pb-206 Lead-206 none stable

Figure 2. Uranium 238 Decay Series

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DESCRIPTION OF PRESENTATIONS AND DISCUSSION

The forum opened with brief remarks by Kim Linton of the Water Research Foundation, who introduced the organizers, Hazen and Sawyer, and described WaterRF’s role in funding research of interest to the drinking water community. Tom Leahy of the City of Virginia Beach Department of Public Utilities then gave a brief presentation highlighting the need for drinking water utilities in Virginia to be aware of the risks of uranium mining in the state based on the number of drinking water supplies downstream of potential uranium mining areas. Mr. Leahy closed with a comparison of the differences in population density and hydrology between Virginia and traditional uranium mining areas in the arid western portion of the US.

National Academy of Sciences Uranium Study Overview - Scott Brooks, Oak Ridge National Laboratory

Dr. Brooks began his presentation by providing an overview of the report conducted by the National Research Council of the National Academy of Science (NAS), Uranium Mining in Virginia Scientific, Technical, Environmental, Human Health and Safety, and Regulatory Aspects of Uranium Mining and Processing in Virginia. Uranium is an important energy resource because it has an approximate heating value over 100,000 times that of coal. Price increases for uranium since 2000, which peaked in 2007, have been a major factor behind the current interest in developing uranium resources in Virginia. Because of this interest, Virginia Delegates, Virginia’s US senators, and the governor asked NAS to conduct a study to assist with the state’s decision making process. The objective for the report was to “provide independent, expert advice that can be used to inform decisions about the future of uranium mining in the Commonwealth of Virginia.” The report’s objectives did not include recommendations on whether or not to lift the moratorium nor on site-specific assessments. The NAS committee identified in its conclusions that Virginia faces steep hurdles before mining can be conducted in a way that is appropriately protective of the health and safety of workers, the public, and the environment. The committee also identified overarching best practices concepts for uranium mining in Virginia:

Planning at the outset of any project for the complete life cycle and include regular re-evaluations;

Engage and retain qualified experts; and Provide meaningful public involvement at all phases.

Based on available data from the National Uranium Resource Evaluation and site specific-studies compiled by the Virginia Department of Mines Minerals and Energy, there are numerous uranium occurrences in Virginia, but only the Coles Hill deposit is potentially economically viable at present. Furthermore, based on statewide geology, it is not anticipated that the mining technique of in-situ leaching is feasible, thus conventional mining and milling would be necessary. Worldwide, uranium is not well distributed: over 90% of the uranium resources have traditionally come from eight countries. Further, there is only about 50 years of known identified uranium resources available based on current reactor technology and usage rates. Uranium prices have trended with oil prices in the past and are expected to continue to do so in the future. Economics of exploration are based on world prices and local costs. Thus, as price for the

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resource goes up, mining of resources with lower concentrations or those with higher local costs becomes more feasible. Research is being conducted into unconventional uranium resources such as seawater, fly ash, and other low concentration sources that may become more viable as uranium prices increase or technological improvements lower the cost of uranium recovery from these sources.

Dr. Brooks next transitioned into a discussion on uranium in the groundwater environment. Groundwater is an important resource in Virginia as a drinking water source for public utilities, private wells, industry, agriculture, and mining. Dr. Brooks noted that groundwater cannot be evaluated independently of surface water because they are linked and influence each other. Unfortunately ground water resources are not well understood in Virginia; more than 90% of monitoring wells are concentrated in limited areas of the state with large portions of the state lacking monitoring wells. Additionally, the areas with most of the uranium occurrences (Piedmont and Blue Ridge) host aquifers that are most susceptible to contamination from near-surface sources.

Uranium mobility in groundwater is dependent on multiple local factors, including:

Hydrogeochemical setting; Physical matrix hosting the aquifer; and Aqueous and solid phase chemistry.

After providing a brief overview of the chemical properties of uranium in the environment, Dr. Brooks presented results of a chemical model for uranium in a representative groundwater environment. The model results illustrated that both the solubility and sorption potential (two factors critical to mobility in groundwater systems) for uranium is highly dependent on pH and the concentration of carbon dioxide in the system. In a second model, Dr. Brooks demonstrated that fractured aquifer systems, similar to that of the Piedmont and Blue Ridge areas of Virginia can lead to much faster fluid flow and increased spreading of contaminants in ground water.

In summary, Dr. Brooks concluded that Virginia currently has no experience with uranium mining and only the deposit at Coles Hill is currently potentially economical; however other former lease sites have yet to be explored and the potential for other uranium mining operations in the Commonwealth cannot be eliminated pending further exploration. Because the potential for uranium migration in groundwater will depend on many factors encompassing the physical hydrology and geochemical setting of a site, the answers to many of the compelling questions regarding uranium mining and potential impacts in Virginia will come only with detailed site-specific study.

Nuclear Regulatory Commission Licensing Overview - Dan Gillen, Independent Consultant

As a retired Nuclear Regulatory Commission (NRC) employee, Mr. Gillen began his presentation by providing an overview of the mission of the NRC. NRC’s mission is to regulate the nation's civilian use of byproduct, source, and special nuclear materials to ensure protection of public health, safety, security, and the environment. The NRC does not regulate uranium mining; rather, the NRC’s responsibility covers uranium milling, which is the beginning of the nuclear fuel cycle and includes both conventional milling of uranium ore and in-situ leaching of uranium source material. States have the option of relying on the NRC for regulation and

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enforcement, or becoming agreement states with the NRC, taking over some regulatory responsibilities that can include uranium milling. Texas, Colorado, Washington, Illinois, Ohio, and Utah are the current agreement states that have authority for regulating uranium recovery.

The regulatory framework for nuclear material consists of laws, regulations, and guidance materials. The primary laws include the Atomic Energy Act of 1954, National Environmental Policy Act of 1969 (NEPA), and Uranium Mill Tailings Radiation Control Act of 1978. Other environmental laws that have some applicability include the Clean Air Act, the Resource Conservation and Recovery Act, the Clean Water Act, and the Safe Drinking Water Act. Title 10 of the Code of Federal Regulations (CFR) Parts 2, 20, 40, and 51 are generally relevant to milling of uranium ore and disposal of waste material. 10 CFR Part 40, Appendix A consists of 13 criteria for regulation of uranium recovery and its associated tailings disposal. NRC guidance documents are not requirements, but provide license applicants and licensees with information on how NRC will implement its regulations, techniques used by the NRC staff in evaluating specific problems, and data needed by the staff in its review of applications.

There are three phases to the licensing process for a mill/tailings facility, designed to cover the entire lifecycle of the site: Phase I is the license application process; Phase II is the operations phase; and Phase III is site closure and long term care. Each license application review is led by a project manager and is supported by a number of individuals with specialized expertise (e.g., health physicists, hydrogeologists, geotechnical engineers, surface water hydrologists, and financial specialists). During the operations phase of a licensed facility, the NRC staff conducts inspections and issues license amendments and renewals. During operations, facilities must, if required, have National Pollutant Discharge Elimination System (NPDES) permits and must meet federal and state discharge limits. Licensees are required to provide environmental monitoring based on NRC Regulatory Guide 4.14. Additionally, NRC specifies recordkeeping and reporting requirements as part of its oversight responsibilities. NRC regulations refer to the concept of ALARA (As Low As (is) Reasonably Achievable), in which licensees are required to use procedures and engineering controls to achieve occupational doses and doses to members of the public that are ALARA. Agreement states are required to have a regulatory program that is consistent with NRC regulations and NRC reviews the state’s regulations periodically to ensure compliance. Non-agreement states do not have a role in the licensing process beyond what is allowed for public involvement. Following closure of a uranium recovery facility with a tailings disposal area, the site is turned over to the US Department of Energy (DOE) for long-term care. DOE prepares a long term surveillance plan that is reviewed by the NRC. Licensees must provide adequate financial assurance to guarantee funds for decommissioning and long term surveillance. Mr. Gillen concluded by providing an overview of the opportunities for public involvement in the licensing process, including Freedom of Information Act requests, hearing requests, input in the environmental evaluation process per NEPA, and meetings with licensees/applicants that are open to the public.

Virginia Department of Health Office of Drinking Water Perspective - John J. Aulbach II, Virginia Department of Health Office of Drinking Water

Mr. Aulbach began his presentation with a review of the Virginia Department of Health Office of Drinking Water (ODW) mission to protect public health by ensuring all Virginians have access to safe drinking water that meets state water quality standards. ODW regulates over

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2,700 drinking water systems serving a population of over seven million people. ODW provides primary enforcement of the Federal Safe Drinking Water Act (SDWA) in Virginia, compliance oversight and technical assistance, and financial assistance to resolve public health and compliance issues. ODW’s work includes conducting inspections, reviewing plans, and issuing permits for water systems. Because the ODW has primacy in Virginia, it is responsible for ensuring compliance with regulatory rules promulgated under the SDWA, including the Radionuclide Rule. The Radionuclide Rule sets the allowable concentration in drinking water for radium, uranium, gross alpha, beta particles, and photon radioactivity, and the monitoring schedule for drinking water systems. ODW requires additional water quality monitoring for “vulnerable” drinking water systems. ODW defines vulnerable water systems as those that have either a surface water intake located within a 5-mile radius or a public water supply well located within a 1,000 foot radius of a man-made source of radiation.

Mr. Aulbach noted that the uranium standard was established to protect against kidney toxicity, rather than its radioactivity, and includes a 100 times safety factor to account for sensitive populations (i.e. newborn, elderly, immuno-compromised). The Radionuclide Rule allows for reduced monitoring, if the water quality samples are below a threshold. However, the Uranium Working Group recommended waterworks in the vicinity (possibly within 5 miles) of a uranium mine to stay on quarterly sampling for radionuclides and not allow reduced sampling. There were a number of comments, questions, and concerns voiced from the audience on this point regarding who would pay for the additional testing, which can be expensive. As the regulations currently stand, drinking water systems are responsible for paying for all testing required to maintain compliance. The ODW would work with DMME and DEQ to develop the “at risk” area for any potential increased drinking water quality monitoring based on groundwater modeling and scientific data provided through the uranium mine permit application process.

In contrast to public drinking water systems, regulations for private drinking water wells are administered by the Office of Environmental Health Services. Private wells must have an initial bacteriological test, but no radionuclide testing is required. Further, once approved, no further testing is required by the regulations. If the uranium mining moratorium is lifted a groundwater management area could be established and statues/regulations adopted to address private well water quality. However, additional concerns were raised regarding a lack of baseline radionuclide data for groundwater wells and it was noted that future monitoring campaigns to identify changes in water quality from mining and milling operations would need to address this gap.

Uranium Tailings Management: Risks, Regulatory Requirements and Best Management Practices –Kimberly Finke Morrison, Morrison Geotechnical Solutions, Inc.

Ms. Morrison opened her presentation with a description of what mine tailings are, and how they are created during the mining and milling process. A Tailings Storage Facility (TSF) is used at mills to dispose of tailings resulting from the milling of ore. The primary purpose of the TSF is to limit contamination arising from seepage, dust, erosion, and, in the case of uranium tailings, radiation. She discussed the numerous differences between TSFs and dams constructed for impounding reservoirs. One of the most important considerations is that TSFs must last in perpetuity because of the long half-life (on the order of thousands of years) of radionuclides in

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tailings. With regard to uranium tailings, an additional consideration is that the radioactive material will decay over thousands of years.

Because of improper management of tailings in the past and the potential for health and environmental exposure, the US passed the Uranium Mill Tailings Radiation Control Act (UMTRCA) in 1978. The Nuclear Regulatory Commission (NRC) or an Agreement State is responsible for source material licensing, which includes regulation of uranium mill tailings, while the USEPA is responsible for establishing public exposure standards. In 1992 the regulations were updated to include a prescriptive liner system for facilities used for the disposal of uranium tailings, and establishment of the “prime option” of fully below grade disposal. Facilities can potentially be constructed below grade in areas with high water tables, though this would add additional engineering and construction challenges. Tailings are generally saturated during the operational phase of the TSF and a water cover is maintained over the tailings in order to limit radon release to the atmosphere.

Prescriptive regulations are indicative of a high level of control over uranium mill tailings. Ms. Morrison described the design of the prescribed uranium tailings liner system from 40 CFR 264.221 and contrasted it with other types of liners commonly used in the mining industry. Ms. Morrison then provided an overview of the Piñon Ridge Project in Colorado, which is the first new uranium mill proposed for construction in the US in nearly 30 years. The description included tailings cell design, liner design, and the decommissioning process. Despite the fact that the “prime option” for TSFs is fully below-grade construction, the Piñon Ridge TSFs were designed to be constructed mostly below grade due to shallow bedrock across the site. Ms. Morrison also provided brief overviews of current licensing and construction activities for the White Mesa Mill in Utah, the Sheep Mountain Project in Wyoming, and Crescent Junction in Utah. Ms. Morrison indicated that failures of TSFs storing uranium tailings have not been documented in the US since implementation of modern regulations; however, she acknowledged that tailings facilities in other parts of the world without stringent regulations do still occur periodically. In conclusion, Ms. Morrison indicated that with mounting public concern for public health and the environment, it is more important than ever to design and construct potentially hazardous facilities in a manner which minimizes present and future adverse impacts. Current regulations are stringent but are also flexible to allow for site-specific optimization.

Virginia Beach Modeling Study Review - Peter Pommerenk, City of Virginia Beach Dr. Pommerenk introduced his presentation by reviewing the locations of known

occurrences of uranium in Virginia, and the municipalities that are downstream of the Coles Hill deposit. The City of Virginia Beach diverts a portion of the flow into Lake Gaston for drinking water for Virginia Beach and other Hampton Roads municipalities. Because mining of the Coles Hill deposit will result in millions of pounds of tailings, there is a risk that any tailings storage facility could fail, contaminating Lake Gaston with radioactive tailings. Hydrology, particularly extreme rainfall, has been a causative factor in most tailings impoundment failures in the past. Virginia is relatively hydrologically active compared to arid western states where uranium mining currently takes place. Virginia has seen two near probable maximum precipitation (PMP) events in the past 50 years, both of which resulted in severe debris flows. Dr. Pommerenk highlighted the fact that the near PMP events in Virginia were nearly as high as the record precipitation events worldwide.

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In order to understand the potential impacts to Lake Gaston from a potential tailings failure, Virginia Beach conducted a modeling study to analyze the concentrations of radium, uranium, and total alpha emitters (radium and thorium) over time in Lake Gaston from a representative tailings failure. Multiple modeling runs were conducted varying both the solubilities of the contaminants and the hydrology of the system for wet years and dry years. The findings from the modeling study indicated that radium concentrations from the representative event would result in the water supply exceeding the maximum contaminant level (MCL) for approximately 20 to 80 days during the wet hydrology scenario but would exceed the radium MCL for radium for approximately 250 to 500 days during the dry hydrology scenario. Further, tailings would remain in the river system and become resuspended periodically over time following high flow events. If such an event occurred, the only acceptable course of action for Virginia Beach would be to shut down its diversion from Lake Gaston until concentrations subsided below the MCL. In closing, Dr. Pommerenk indicated that the prospect of losing access to a critical water supply for the region for potentially as long as sixteen months is unacceptable to the City of Virginia Beach.

Heavy Precipitation Events: Past Trends, Causes, and Future Trends - Ken Kunkel, National Oceanic and Atmospheric Administration and North Carolina State University

Dr. Kunkel introduced his presentation by providing historical statistics of each region of the country showing decadal changes in average precipitation, which he then contrasted with historical statistics for extreme precipitation. The values for average precipitation varied (i.e. higher or lower) from region to region, while the extreme precipitation values generally showed an upward trend in all regions of the continental US. Dr. Kunkel indicated for his presentation he would be using the 48-hour, 5-year recurrence interval storm as the definition of an extreme precipitation event. However, he noted that the definition of extreme event was immaterial, because regardless of how an extreme was defined, similar patterns of increased occurrence were identified.

Dr. Kunkel then described his research looking at the causes of the observed increases in extreme precipitation, primarily:

Have there been changes to the meteorological phenomena producing heavy precipitation; or

Are the recent increases a result of increases in atmospheric water vapor concentrations?

Looking at the specific meteorological types that produce rainfall events across the US, and focusing on the types that most affect eastern US hydrology (e.g., frontal activity and tropical cyclones), there has been a statistically significant increase this century in the occurrence of extreme events caused by fronts. Further, with respect to tropical cyclones, in the last decade there has been an increase in extreme rainfall caused by landfalling tropical cyclones. Analyzing atmospheric water vapor, there has been a significant positive trend throughout most of the US. Additionally, temperature trends also show a generally positive trend in each region of the US.

Using global circulation models, future projections for atmospheric water vapor and upward motion in the atmosphere (both of which are components of storm activity) can be projected. Model outputs predict that upward motion in the atmosphere will show little change, while the percentage of water vapor increases noticeably and in proportion to what would be expected

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from increases in global surface temperatures. Thus, while the prediction is still uncertain, it appears likely that the probability of extreme precipitation events in VA will increase in the future. In conclusion, Dr. Kunkel indicated that confidence in future increases in atmospheric water vapor is high because there is a good understanding of the physical mechanism. While model projections also show an increase in maximum precipitation, our understanding of quantitative changes in the number and characteristics of future fronts and tropical cyclones is not as high.

State of the Science: Water Treatment - Ben Wright, Hazen and Sawyer Mr. Wright began his presentation by reviewing the potential pathways by which wastes

could travel into drinking water supplies, which predominantly consists of chronic releases (e.g., regulated releases, leaching of wastewater into the groundwater, etc.) that occur over a long period of time and acute releases that might be associated with a tailings or wastewater impoundment failure. The solubility and sorption potential of uranium and other contaminants will depend on the local conditions present in the environment as described previously by Dr. Brooks. Regulated releases must comply with the numeric standards in 40 CFR 440, which only apply to uranium, radium, zinc, chemical oxygen demand, pH, and total suspended solids. (Table 1). Comparing the maximum concentrations from 40 CFR 440 for mine releases with the MCLs for drinking water, the radium discharge limit is two times larger than the radium MCL, while the uranium release concentration is approximately 66 times larger than the uranium MCL. Therefore, if the maximum concentration is released from the mine area, there needs to be 66 times more water in the river to provide adequate dilution to meet the uranium MCL, assuming no specialized treatment at the drinking water utility to remove uranium.

Table 1. Uranium Mining Release Concentrations per 40 CFR 440 and USEPA MCL/MCLG

Effluent characteristic Maximum value for any

1 day Average Daily value for

30 consecutive days MCLG MCL

COD (mg/L) 200 100 NA NA

Zn (mg/L) 1.0 0.5 5 5

Ra 226 (dissolved) (pCi/L) 10.0 3.0 zero NA

Ra 226 (total) (pCi/L) 30.0 10.0 5 5

U (mg/L) 4.0 2.0 Zero 0.03

pH 6 to 9 6 to 9 6.5 to 8.5 6.5 to 8.5

TSS (mg/L) 30.0 20.0 NA NA

From a uranium treatment perspective precipitation by lime softening is the most common method of removing uranium from process water and is capable of removing upwards of 90%. Enhanced coagulation, ion exchange, and reverse osmosis are other common technologies, though more expensive and typically used in conjunction with lime softening to achieve greater removal. Precipitation is also the common treatment method for other contaminants typical to uranium mine/mill wastewater: treatment with barium chloride for

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radium precipitation (though radium is also removed with lime softening) and treatment with ferric chloride for arsenic.

Since radionuclides can be removed by common treatment processes employed at drinking water treatment plants, increased background concentrations of radionuclides in source waters could result in the concentration of these constituents in drinking water treatment plant residuals or filter media. If radionuclides are concentrated above threshold levels established by state and federal regulations, the waste could be considered either a technologically enhanced naturally occurring radioactive material (TENORM) or a low level radioactive waste (LLRW). Regulated radioactive wastes are more expensive to dispose of than typical solid wastes. The experience of a drinking water utility in Glendale, CA, whose spent ion exchange resin had high concentrations of naturally occurring uranium, illustrates that costs for uranium-contaminated residuals can be on the order of 40 times higher than typical disposal options. Mr. Wright noted that with respect to uranium mine and mill discharges the UWG report indicated that the current federal standards were outdated and that Virginia needed to develop its own technologically based standards. It was also noted that developing discharge standards implies developing Total Maximum Daily Load values for receiving waters. Because there are suitable treatment technologies available to remove radiological contaminants from mine discharges, the costs should not be borne by the drinking water utilities for treatment of water quality degradation resulting from a uranium mine or mill facility.

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FURTHER READING Association of California Water Agencies. 2012. Hexavalent Chromium Treatment Residuals Management. Prepared by Malcolm Pirnie, a Division of Arcadis. Accessed at http://www.acwa.com/sites/default/files/news/water-quality/2012/04/acwa-cr6-report-final-appendices-032712_1.pdf City of Virginia Beach. 2011. Virginia Beach Uranium Mining Impact Study. Prepared by Michael Baker Corporation. Accessed at http://www.vbgov.com/government/departments/public-utilities/Pages/Uranium-Mining.aspx Committee on Uranium Mining in Virginia, Committee on Earth Resources, National Research Council. 2012. Uranium Mining in Virginia: Scientific, Technical, Environmental, Human Health and Safety, and Regulatory Aspects of Uranium Mining and Processing in Virginia. Washington, DC: The National Academies Press. Accessed at http://www.nap.edu/catalog.php?record_id=13266 Kunkel, K.E. et al., 2012 (In Review). Monitoring and Understanding Changes in Extreme Storm Statistics: State of Knowledge. Bulletin of the American Meteorological Society. IAEA (International Atomic Energy Agency). 2004. Treatment of Liquid Effluent from Uranium Mines and Mills. IAEA-TECDOC-1419. International Atomic Energy Agency, Vienna, Austria. Accessed at http://www-pub.iaea.org/mtcd/publications/pdf/te_1419_web.pdf Nuclear Regulatory Commission. NRC Regulatory Guides - Environmental and Siting (Division 4). Accessed at http://www.nrc.gov/reading-rm/doc-collections/reg-guides/environmental-siting/rg/ US Environmental Protection Agency. 2001. Radionuclides Rule: A Quick Reference Guide. Washington, DC. Accessed at http://water.epa.gov/lawsregs/rulesregs/sdwa/radionuclides/upload/2009_04_16_radionuclides_qrg_radionuclides.pdf Virginia Department of Mines, Minerals, and Energy; Virginia Department of Environmental Quality; and Virginia Department of Health. 2012. Commonwealth of Virginia 2012 Uranium Working Group Report. Richmond, Virginia. Accessed at http://www.governor.virginia.gov/utility/docs/UWG%20Report%20-%20FINAL%2030Nov2012.pdf

13

ABBREVIATIONS

ALARA – As Low As Reasonable Achievable CFR – Code of Federal Regulations DEQ – Department of Environmental Quality DMME - Department of Mines Minerals and Energy EIA – Energy Information Administration LLRW - Low Level Radioactive Waste MCL – Maximum Contaminant Level NAS – National Academy of Science NEPA – National Environmental Policy Act NRC – Nuclear Regulatory Commission ODW – Office of Drinking Water TENORM - Technologically Enhanced Naturally Occurring Radioactive Material TSF – Tailings Storage Facility UMTRCA - Uranium Mill Tailings Radiation Control Act USEPA – US Environmental Protection Agency USDOE – US Department of Energy UWG – Uranium Working Group

A-1

APPENDIX A

This section includes the following materials prepared prior to the forum:

Invitation Agenda Background Information Speaker bios

DON’T MISS THIS EVENT! Issues and Impacts:  

Uranium Mining and Drinking Water Supplies 

The City of Virginia Beach, City of Norfolk, and the Water Research Foundation 

are  supporting  an  educational  forum  to  provide  an  opportunity  for  water 

utilities to discuss the potential risk and issues that can be identified regarding 

uranium mining  in  the  state.  The  overarching  objective  of  this  educational 

forum is to provide information to utilities in order to assist their evaluation of 

the potential risks to their water supplies from uranium mining.  

 

Objectives of the educational forum include: 

Provide legal / regulatory background  

Provide information on Virginia’s geology as it relates to potential uranium 

deposits 

Educate attendees on current uranium mining techniques 

Discuss regional climate and hydrology as it relates to uranium 

development  

Provide an overview of the existing study completed for the Roanoke River 

Watershed 

Date: Tuesday, December 11th 

Time: 8:30 AM ‐  4:00 PM  

City of Richmond, WWTP 1400 Brander Street  Richmond, VA 23224 

*Breakfast and Lunch will be provided 

RSVP by Friday, November 30th (Seating is Limited): Ben Wright, PE | bwright@hazenandsawyer.com  

Complementar

y 

Education

al  

Forum… 

Earn 4 PDH

s! 

Issues and Impacts:  Uranium Mining and Drinking Water Supplies 

 AGENDA 

8:30  Breakfast & Coffee (provided) 

9:00  Introductory Remarks Kim Linton (Water Research Foundation) Tom Leahy (City of Virginia Beach) 

9:30  National Academy of Sciences Uranium Study Overview Scott Brooks (Oak Ridge National Lab) 

10:15  Break 

10:30  Nuclear Regulatory Commission Licensing Overview Dan Gillen (Independent Consultant) 

11:00  VDH ODW Perspective John J. Aulbach II (Virginia Dept. of Health Office of Drinking Water) 

11:30  Lunch (provided) 

12:30  Tailings Impoundments Risks and Best Management Practices Kimberly Morrison (Morrison Geotechnical Solutions, Inc.) 

1:00  Virginia Beach Modeling Study Review Tom Leahy (City of Virginia Beach) 

1:30  Break 

2:00  Hydrology and Climate Change Dr. Ken Kunkel  (NOAA) 

2:30  State of the Science: Water Treatment Ben Wright (Hazen and Sawyer) 

3:00  Wrap‐up discussion Dr. Ben Stanford (Hazen and Sawyer) 

4:00  Adjourn 

Issues and Impacts:  Uranium Mining and Drinking Water Supplies 

  In 2007, a Canadian mining company proposed to exploit a large uranium ore deposit  at Coles Hill  in Pittsylvania County upstream of Kerr Reservoir  and Lake  Gaston.    The  uranium  industry  is  now  lobbying  to  lift  the  state‐wide moratorium  on  uranium  mining  in  Virginia,  potentially  during  the  next  state General Assembly. However, other  formations have been  identified around  the state with elevated uranium content. These formations cut across all of the major river basins in Virginia. Global economic drivers are expected to continue to push the price of uranium ore higher,  if  the  legislature  rescinds  the uranium mining moratorium state‐wide,  it will  likely result  in  further exploration and potentially new economically  viable discoveries.  Therefore,  lifting  the moratorium has  the potential to affect Virginia water utilities.    Over the lifetime of a typical mine, tens of millions of cubic yards of sand‐like residue (tailings) from the uranium milling and extraction process that retains more  than  80%  of  the  original  radioactivity,  are  produced  and  stored permanently on‐site. Given the wet climate and the propensity of near probable maximum precipitation (PMP) storms in the area, and the fact that hydrology has been  a major  causative  factor  in  past  failures,  there  is  a  potential  risk  to  any water utility downstream of these facilities.        The  City  of  Virginia  Beach,  City  of  Norfolk,  and  the  Water  Research Foundation are  supporting an educational  forum  to provide an opportunity  for water  utilities  to  discuss  the  potential  risk  and  issues  that  can  be  identified regarding  uranium  mining  in  the  state.  The  overarching  objective  of  this educational  forum  is  to  provide  information  to  utilities  in  order  to  assist  their evaluation of the potential risks to their water supplies from uranium mining.     Objectives of the educational forum include:  Provide legal / regulatory background   Provide  information on Virginia’s  geology  as  it  relates  to potential uranium 

deposits  Educate attendees on current uranium mining techniques  Discuss regional climate and hydrology as it relates to uranium development   Provide an overview of the existing study completed for the Roanoke River 

Watershed  Identify the potential water quality impacts due to tailings dam failures 

caused by extreme weather  

 EDUCATIONAL FORUM BACKGROUND 

Issues and Impacts:  Uranium Mining and Drinking Water Supplies 

Scott C. Brooks, PhD Oak Ridge National Laboratory Scott C. Brooks is Senior Scientist in the Environmental Sciences Division of Oak Ridge National Laboratory. Dr. Brooks’ research focuses on the interplay between geochemistry, microbiology, and hydrology, and how this interplay influences the fate, transformation, and movement of chemicals in groundwater and soil. He has conducted numerous laboratory and field experiments studying these processes, with a focus on heavy metals and radionuclides, at spatial scales ranging from the molecular to kilometer. He has Ph.D. and M.S. degrees in Environmental Sciences from the University of Virginia. Daniel M. Gillen Independent Consultant Mr. Gillen holds a Masters Degree in Geotechnical Engineering. He has 39 years of experience, including a 31-year career with the Nuclear Regulatory Commission. His NRC work included geotechnical design review of nuclear power plants, uranium recovery facilities, and mill tailings impoundments; project management of nuclear facility license applications and decommissioning actions; policy review as technical assistant to the Chairman of the Nuclear Regulatory Commission; and oversight as a Senior Executive Service Manager of several nuclear program areas including Uranium Recovery Facilities, Fuel Cycle Facilities, and Reactor and Material Site Decommissioning. A major part of his NRC career was in managing the uranium recovery program. After NRC retirement, his recent international work has included preparation of IAEA guidance documents, development and conduct of several NRC-sponsored workshops for developing nations on uranium recovery regulation, and participation in IAEA-sponsored workshops on uranium recovery activities. Kenneth Kunkel, PhD NOAA National Climatic Data Center Kenneth E. Kunkel is Lead Scientist for Assessments with the NOAA Cooperative Institute for Climate and Satellites at the National Climatic Data Center in Asheville, NC and Research Professor in the Department of Marine, Earth, and Atmospheric Sciences of North Carolina State University. He holds a B.S. degree in physics from Southern Illinois University and M.S. and Ph.D. degrees in meteorology from the University of Wisconsin-Madison. His recent research has focused on climate variability, extremes, and change. A particular focus of his research has been on assessing historical trends in extreme weather and climate extremes, particularly extreme precipitation. He is currently providing technical support for the development of the 2013 National Climate Assessment report. Tom Leahy, PE City of Virginia Beach Department of Public Utilities Mr. Leahy is the Director of City of Virginia Beach Department of Public Utilities, which provides water and sewer service for more than 425,000 people. He oversees an organization with over 400 employees, an operating budget of over $100 million per year, and a capital improvement program of $30 million per year. Before assuming the role of the Director, Mr. Leahy was the Water Resources Manager for Public Utilities during which time he was Project Manager for the $150 million pipeline project to transfer 60 million gallons of water per day from Lake Gaston to southeast Virginia.

Continued... 

SPEAKER BIOS 

Issues and Impacts:  Uranium Mining and Drinking Water Supplies 

Kimberly Morrison, PE, RG Morrison Geotechnical Solutions Kimberly Morrison, PE, RG is the President of Morrison Geotechnical Solutions, located in Lakewood, Colorado. She has fifteen years of consulting experience on a variety of geotechnical, civil, environmental and construction projects, specializing in the geotechnical and environmental design of mine waste facilities for clients worldwide. Ms. Morrison served as the project manager and lead designer of geotechnical and hydrogeological components for Energy Fuels’ proposed Piñon Ridge uranium mill in Colorado, which is the first new conventional uranium mill being proposed for construction in the US in about 30 years. She has design and licensing experience on various other uranium mining, milling and ISR projects in Utah, Wyoming, Colorado, Australia, Canada, and Kazakhstan. Currently, Ms. Morrison is working with Energy Fuels on design components for their proposed Sheep Mountain Project, which is the first uranium heap leach pad proposed in the United States in recent history. Ben Stanford, PhD Hazen and Sawyer Ben Stanford is the Director of Applied Research at Hazen and Sawyer in New York City. Dr. Stanford joined Hazen and Sawyer in 2009 from the Southern Nevada Water Authority in Las Vegas, NV, where he worked with Shane Snyder on a variety of drinking water, wastewater, and reuse projects. Dr. Stanford's current work ranges from understanding the impacts of climate change on water quality to investigating advanced treatment technologies for water treatment and water reuse, among others. Ben Wright, PE Hazen and Sawyer Mr. Wright has performed modeling and analysis for water resources management and water supply infrastructure projects for utilities in Virginia, New York, Florida, and California over the past twelve years. His work often combines science and engineering with regulatory and policy issues related to protecting water resources. Currently, Mr. Wright is involved with a number of projects addressing utility risk and vulnerabilities from extreme weather, climate change, and energy exploration.

SPEAKER BIOS 

A-2

APPENDIX B WORKSHOP PRESENTATIONS

B-1

Water Research FoundationWater Research Foundation

Uranium MiningUranium Mining

Drinking Water SuppliesDrinking Water Supplies

December 11, 2012December 11, 2012

Google Lights Reflect Population Density

Uranium Mining in Virginia Scientific, Technical, Environmental,

Human Health and Safety, and Regulatory Aspects of Uranium

Mining and Processing in Virginia

Scott C. Brooks Oak Ridge National Lab

brookssc@ornl.gov

Impacts and Issues: Uranium Mining and Drinking Water Supplies Water Research Foundation Workshop

11 December 2012

http://www.nap.edu/catalog.php?record_id=13266

Outline • Overview of the NAS study

– http://www.nap.edu/catalog.php?record_id=13266

• U sources in Virginia

– Present/ future

– Conventional/ unconventional

• U in water

– Implications for movement in groundwater environment

• Not addressing – mitigation and remediation

Committee Members • PAUL A. LOCKE, Chair, Johns Hopkins Bloomberg School of Public Health,

Baltimore, Maryland

• CORBY G. ANDERSON, Colorado School of Mines, Golden

• LAWRENCE W. BARNTHOUSE, LWB Environmental Services, Inc., Hamilton, Ohio

• PAUL D. BLANC, University of California, San Francisco

• SCOTT C. BROOKS, Oak Ridge National Laboratory, Tennessee

• PATRICIA A. BUFFLER, IOM, University of California, Berkeley

• MICHEL CUNEY, Nancy Universite, Centre National de la Recherche Scientifique, Vandoeuvre, France

• PETER L. deFUR, Environmental Stewardship Concepts, Henrico, Virginia

• MARY R. ENGLISH, University of Tennessee, Knoxville

• KEITH N. ESHLEMAN, University of Maryland Center for Environmental Sciences, Frostburg

• R. WILLIAM FIELD, College of Public Health, University of Iowa, Iowa City

• JILL LIPOTI, New Jersey Department of Environmental Protection, Trenton

• HENRY A. SCHNELL, AREVA NC (retired), British Columbia, Canada

• JEFFREY J. WONG, California Environmental Protection Agency, Sacramento

http://www.nap.edu/catalog.php?record_id=13266

NRC Staff

• DAVID A. FEARY, Study Director

• DEBORAH GLICKSON, Senior Program Officer

• STEPHANIE JOHNSON, Senior Program Officer

• SOLMAZ SPENCE, Communications Officer

• NICHOLAS D. ROGERS, Financial and Research Associate

• PENELOPE GIBBS, Senior Program Associate

• COURTNEY R. GIBBS, Program Associate

• JASON R. ORTEGO, Research Associate

http://www.nap.edu/catalog.php?record_id=13266

Approximate Heating Values

Btu Btu Relative to Western coal

1lb. 3.2% enriched uranium 1,250,000,000 113,636

1 lb. U3O8 180,000,000 16,364

1 barrel No. 2 fuel oil 5,750,000 523

1 lb. No. 2 fuel oil 19,500 1.77

1 lb. Bunker C oil 18,500 1.68

1 lb. Eastern US bituminous coal 13,000 1.18

1 lb. Western US subbituminous coal 11,000 1 http://www.uranium.info/unit_conversion_table.php

How did we get here? • 1978 Coles Hill U deposit discovered, Pittsylvania County

– exploration – Marline U Corp. early 1980’s

• 1982 Commonwealth of Virginia - U mining moratorium

– Leasing rights returned to landowner

– Exploration is allowed with permit

• 2007 – Virginia Uranium, Inc. formed by Coles and Bowen families

• 2008 General Assembly – discussions of creating Virginia Uranium Mining Commission – advisory to executive branch

• Nov 2008 – Virginia Coal and Energy Commission (Kilgore, Chair; legislative branch) created Uranium Mining Subcommission

Figure 3.22 – Inflation adjusted spot price of U and oil, 1974-2011 Current spot

price ~$42

1978

1982

2007

Initiating the study • Aug 2009 - Letter from Delegate Terry Kilgore (R), on

behalf of the Virginia Coal and Energy Commission

• Supporting letters from

– US Senator Mark Warner (D), Sept 2009

– US Senator Jim Webb (D), Oct 2009

– Governor Timothy Kaine (D), Nov 2009

Statement of Task (in a nutshell)

• Scientific, Technical, Environmental, Human Health and Safety, and Regulatory Aspects

• “…the study will provide independent, expert advice that can be used to inform decisions about the future of uranium mining in the Commonwealth of Virginia; however, the study will not make recommendations about whether or not uranium mining should be permitted nor will the study include site-specific assessments.”

Report Timeline

JOBS FOR VIRGINIA

10/26/10 12/1/11

Washington D.C.*

Danville, VA*,†

Richmond, VA*,†

Va Beach†

Fairfax†, Charlottesville†,

Richmond†

Danville†

Presentation to VA - CEC

Report delivered to Commonwealth

Irvine, CA

Saskatoon, Canada*

Boulder, CO*

Washington D.C. *

5/31/12

Gov. McDonnell U Working Group

DMME VDEQ VDH

* = public comment † = town hall

Report Structure

Nontechnical Summary

1. Introduction

2. Virginia Physical and Social Context

3. Uranium Occurrences, Resources, and Markets

4. Uranium Mining, Processing, and Reclamation

5. Potential Human Health Effects of Uranium Mining, Processing, and Reclamation

6. Potential Environmental Effects of Uranium Mining, Processing, and Reclamation

7. Regulation and Oversight of Uranium Mining, Processing, Reclamation, and Long-term Stewardship

8. Best Practices

Each chapter begins with a summary of key points…

… and ends with findings and key concepts

Overarching Best Practices Concepts

• Plan at the outset of any U mining project the complete life cycle – mining, processing, reclamation – and include regular re-evaluations

• Engage and retain qualified experts

• Provide meaningful public involvement at all phases

“If the Commonwealth of Virginia removes the moratorium on uranium mining, there are steep hurdles to be surmounted…”

(p. 27, NRC report)

Virginia’s Physiographic Provinces

Ch. 3: URANIUM OCCURRENCES, RESOURCES, AND MARKETS: KEY POINTS

• Of the localities in Virginia where existing exploration data indicate that there are significant uranium occurrences, predominantly in the Blue Ridge and Piedmont geological terrains, only the deposits at Coles Hill in Pittsylvania County appear to be potentially economically viable at present.

• Because of their geological characteristics, none of the known uranium occurrences in Virginia would be suitable for the in situ leaching/in situ recovery (ISL/ISR) uranium mining/processing technique.

Ch. 3: URANIUM OCCURRENCES, RESOURCES, AND MARKETS: KEY POINTS

• In 2008, uranium was produced in 20 countries; however, more than 92 percent of the world’s uranium production came from only eight countries.

• In general, uranium price trends since the early 1980s have closely tracked oil price trends. The Chernobyl (Ukraine) nuclear accident in 1986 did not have a significant impact on uranium prices, and it is too early to know the long-term uranium demand and price effects of the Fukushima (Japan) accident.

• Existing known identified resources of uranium worldwide, based on present-day reactor technologies and assuming that the resources are developed, are sufficient to last for more than 50 years at today’s rate of usage.

Very high-grade ore (Canada) - 20% U 200,000 ppm U

High-grade ore - 2% U, 20,000 ppm U

Low-grade ore - 0.1% U, 1,000 ppm U

Very low-grade ore* (Namibia) - 0.01% U 100 ppm U

Granite 3-5 ppm U

Sedimentary rock 2-3 ppm U

Earth's continental crust (av) 2.8 ppm U

Seawater 0.003 ppm U

Uranium Sources

Coles Hill avg grade 0.1% U3O8 = 850 ppm U

Oceans hold ~4 billion tons U (2011 worldwide production 50,000 tons)

Credit: Oak Ridge National Lab

New sorbent extracts 3× more U from seawater -C&E News 9/3/12

http://www.world-nuclear.org/info/inf75.html

Concentration not only factor dictating what is “economically recoverable”

National Uranium Resource Evaluation (NURE), 1973 – 1984

• Aeroradiometric map of Virginia

• Equivalent U (eU) in top few centimeters rock or soil

• U concentration in stream sediment

Lassetter, 2010

National Uranium Resource Evaluation (NURE), 1973 – 1984

http://energy.cr.usgs.gov/radon/DDS-9.html

Potential implications for other states in the southeast

Coles Hill

Uranium Occurrences in Virginia

Roanoke

Richmond

Charlottesville

Coles Hill

• Fig. 3.3. modified, from Lassetter (2010) – based on geologic terrains, presence of U-bearing minerals, elevated natural radioactivity, geochemical data

“occurrence” = area naturally elevated in U but may not represent an ore deposit

Uranium Occurrences in Virginia

• Fig. 3.3. modified, from Lassetter (2010) – based on geologic terrains, presence of U-bearing minerals, elevated natural radioactivity, geochemical data

Roanoke

Richmond

Charlottesville

Coles Hill

The Coles Hill Deposit

• Contains significant U resources

– Although the ore grade is low, comparable to other deposits worldwide being mined

• Uraninite (UO2) and coffinite (USiO4) dominant ore minerals

– Easily leached but hosted in rock that is hard to crush

– 1-9 wt% P2O5

• No genetic model developed for this deposit

– Unknown likelihood of other similar occurrences in state

Former Uranium Mining Leases in Piedmont

Map provided by The Piedmont Environmental Council

Unconventional U Sources in VA • Pennsylvanian coal fly ash

– Extract U from coal ash produced at power plants

• Byproduct of mining

– Granitic hydrothermal deposits mined for Th

– Phosphate rock / phosphoric acid (e.g., Florida)

– Heavy mineral sands: Driving interest (in decreasing order) is Ti, Zr, REE, Th

• 2003 – Virginia was the 2nd leading producer of Ti and Zr from heavy mineral sands in the US

– Future economic pressures in REE production?

– Between 1880 and 1918 virtually all Th production in US from heavy mineral sands in Piedmont region of NC and SC

USGS Fact sheet FS-163-97

Virginia Groundwater use 2003-2007

• Groundwater is an important resource in Virginia

• Constituted 22% freshwater use 2008

Source: VA DEQ 2010

Groundwater = water beneath the land surface that completely fills the fractures and cracks in rocks, and openings between mineral grains. This water is the source of water that supplies wells, springs, and seeps.

• For purposes of discussion it is convenient to address surface water and groundwater as if they are separate compartments. In reality surface water and groundwater are part of a single resource.

• Water moves in both directions between the visible surface water and the unseen groundwater – Studying these interactions is difficult and remains an active area of

research

• It has become clear that changes to the quantity and quality of one will affect the same parameters in the other

• Less important whether it is surface water or groundwater that is initially impacted because their interaction can result in both being impacted

Groundwater versus Surface Water

Statewide, 22% of Virginians use privately owned domestic wells for drinking water

Proportion of Virginia population served by domestic wells in 2005 High proportions in southside VA, Piedmont, Blue Ridge

USGS, 2005. Estimated Use of Water in the United States, County-Level Data for 2005. Available at http://water.usgs.gov/watuse/data/2005/index.html

381 of 411 water level monitoring wells are located in the Coastal Plain and northern

Shenandoah Valley (Valley and Ridge) Piedmont, Blue Ridge, Valley and Ridge, Appalachian Plateau covered by only 30 wells

Source: USGS “Virginia’s Ground-Water Resources, Monitoring Network, and Studies, 2008”

Limited well-construction data in Piedmont Few comprehensive investigations

Source: VA DEQ

Southern Piedmont and portions of Blue Ridge under-represented relative to the rest of the state

Coles Hill

Areas with most U occurrences (Piedmont and Blue Ridge) also host aquifers most susceptible to contamination from

near-surface sources

Nelms et al. 2003. USGS WRIR 03-4278

Virginia’s Regional Aquifer Susceptibility

• 1930 - Last comprehensive analysis of springs in Virginia

• Huge gap in information about spring water quality and occurrence in the state

– efforts for improvement in the past 6 years

• VaDEQ’s Groundwater Characterization Program (GWCP) is updating and modernizing the spring database

– historical datasets

– more recent field measurements

– establishing data sharing agreements with the USGS and sister state agencies

Source: STATUS OF VIRGINIA’S WATER RESOURCES

http://www.deq.state.va.us/export/sites/default/watersupplyplanning/documents/pdf/Oct2008_AWRR_FINAL.pdf

Springs in Virginia

Uranium Mobility in Groundwater

• Depends on the hydrogeochemical setting

• Physical matrix hosting the aquifer

– Fracture flow versus porous granular media

– Significant matrix storage/ multidomain flow?

• Aqueous and solid phase chemistry

– Oxidizing or reducing?

– Inorganic carbon content?

– pH?

– Aquifer minerals?

Some Chemical Properties of U • Redox sensitive element

– Environmentally relevant oxidation states +6 (uranyl, U(VI)) and +4 (uranous, U(IV))

– U higher solublility at acidic and basic pH

– U(VI) higher solubility, more mobile in groundwater

– U(IV) sparingly soluble, much less mobile, most U deposits U(IV) minerals (uraninite, coffinite, pitchblende)

• U(VI) minerals most often products of U(IV) mineral weathering

• U hydrolyzes readily, forms strong aqueous complexes with carbonate and phosphate influencing fate and transport, e.g.

Slide removed for copyright purposes. Original Slide was titled “IllustrativeOriginal Slide was titled  Illustrative 

simulations that follow assume median concentration of major groundwater j gconstituents” and was Table 8.8 from 

Langmuir, D., 1997. Aqueous Environmental Geochemistry. Upper Saddle River, NJ: 

Prentice Hall

2 3 4 5 6 7 8 9 10 11–17

–16

–15

–14

–13

–12

–11

–10

pH

log

a U++

++

25°C

Uraninite [UO2]

U(SO4)20

U(OH)22+

U(OH)3+ U(OH)4

0

U(CO3)44-

U(IV) solubility log(PCO2) = -3.5

Soddyite [(UO2)2SiO4•2H2O]

Ca2UO2(CO3)3(aq)

UO22+

UO2OH+

UO2CO30

U(VI) solubility log(PCO2) = -3.5

U(VI) versus U(IV) Solubility as f(pH)

0 2 4 6 8 10 12 14

–.5

0

.5

1

pH

Eh

(vol

ts)

25°C

U(CO3)56-

Ca2UO2(CO3)3(aq)

UO22+

U(SO4)2(aq)

UO2+

U(OH4)0 U(OH3)+

U(OH2)2+

UO2OH+

UO2CO30

Ca2UO2(CO3)3(aq)

UO22+

U(SO4)2(aq)

UO2OH+ Soddyite [(UO2)2SiO4•2H2O]

Haiweeite [Ca(UO2)2(Si2O5)3•5H2O]

U(CO3)56-

Uraninite [UO2]

log(PCO2) = -3.5 log(PCO2) = -3.5

Eh-pH Relationships U-O2-H2O-CO2 System

U Sorption onto Mineral Surfaces • Sorption f(aqueous chemistry, sorbent surface chemistry)

pH4 5 6 7 8 9

Frac

tion

U s

orbe

d

0.0

0.2

0.4

0.6

0.8

1.0log(PCO2) = -3.5

log(PCO2) = -2

log(PCO2) = -1

UO22+

UO2OH+

CaUO2(CO3)32-

Ca2UO2(CO3)30

UO2(CO3)34-

U Equilibrium Aqueous Speciation No sorption, log(PCO2) = -3.5

(UO2)2CO3(OH)3-

UO2CO30

Fraction U sorbed variable log(PCO2)

U Transport: Impact of Aqueous Chemistry

• pH 6

• 10 y U source to gw

• U retardation and tailing inversely related to inorganic C

•••

Dx = 1 m

n = 100 q = 0.3 = 20 cm Fe(OH)3 = 0.1% vol

*NOTE: Assumes isotropic, homogeneous media, equilibrium chemistry

Time (years)0 50 100 150 200

Rel

ativ

e C

once

ntra

tion

(C/C

0)

0.001

0.01

0.1

1U log(PCO2) = -3.5

U log(PCO2) = -2

U log(PCO2) = -1

Bromide

Concentration History 100m Downgradient

U Transport: Impact of Preferential Flow

• pH 6

• 10 y U source to gw

• Fracture flow leads to faster transport

• Matrix diffusion creates extended tailing

• Piedmont and Blue Ridge aquifer system hosted by fractured igneous and metamorphic rock

*NOTE: Assumes equilibrium chemistry

•••

Dx = 0.17 m

n = 600 q = 0.3 = 20 cm Fe(OH)3 = 0.1% vol

Fractures 10% volume

30 cm apart Matrix diffusion

Time (years)0 20 40 60 80 100 120 140

Rel

ativ

e C

once

ntra

tion

(C/C

0)

0.001

0.01

0.1

1U log(PCO2) = -2

Bromide

U log(PCO2) = -2 Fracture flow

Bromide Fracture flow

62 years

Concentration History 100m Downgradient

Summary

• Virginia has no experience with U mining – Virginia has a U mining moratorium in place

• Uranium in Virginia

– Only the deposits at Coles Hill in Pittsylvania County appear to be potentially economically viable at present

– Other U occurrences exist around the state

– Most former leases were not explored

– Unconventional sources should be kept in mind

• Groundwater and surface water should be considered together

Summary

• Groundwater is an important resource in Virginia

• Groundwater resources are not well understood across most of the state

• The potential for U migration in groundwater depends on many factors encompassing the physical hydrology and geochemical setting

• Answers to many of the compelling questions regarding U mining and potential impacts will come only with detailed site-specific study

Nuclear Regulatory Commission Licensing of

Uranium Recovery Facilities

Daniel M. Gillen; Independent Consultant

Content

• NRC Role • Regulatory Framework • Licensing Process • Other Licensing Information

• NRC Mission: To regulate the nation's civilian use of byproduct, source, and special nuclear materials to ensure adequate protection of public health and safety, to promote the common defense and security, and to protect the environment.

• The NRC's regulatory mission covers three main areas: – Reactors - Commercial and research – Materials - Uses of nuclear materials in medical, industrial, and

academic settings and facilities that produce nuclear fuel – Waste - Transportation, storage, and disposal of nuclear materials

and waste, and decommissioning of nuclear facilities from service

What is Uranium Recovery? • The beginning of the

nuclear fuel cycle • Extracting (or mining)

natural uranium ore and concentrating (or milling) that ore.

• Mills produce U3O8 or "yellowcake”

• Uranium recovery operations also generate waste, called byproduct materials, which contain low levels of radioactivity.

NRC Uranium Recovery Program

• NRC does not regulate uranium mining; Only milling

• Currently, NRC regulates uranium recovery operations in Wyoming, New Mexico, and Nebraska

• NRC does not directly regulate active uranium recovery operations in Texas, Colorado, and Utah (Agreement States)

The Regulatory Framework

Laws

Regulations (CFR)

NRC Guidance

Three Levels of the Regulatory Framework

Level 1 - U.S. Laws Affecting Uranium

Recovery

• Atomic Energy Act of 1954 • National Environmental

Policy Act of 1969 • Uranium Mill Tailings

Radiation Control Act of 1978

• Other UR-Related Environmental Laws – Clean Air Act – Resource Conservation

and Recovery Act – Clean Water Act – Safe Drinking Water Act

Level 2: NRC Regulations Part

2 • General

rules of practice for licensing

Part 20

• Radiation protection

Part 40

• Licensing source and byproduct material

Part 51

• Protection of the environment

10 CFR Part 40, Appendix A (13 Criteria)

General site and design criteria for tailings disposal

Ground-water protection requirements, including liner requirements

Requirements for preoperational and operational monitoring programs

Requirements for air emission controls

Financial assurance requirements

Closure requirements: tailings cover, radon, stability, soil cleanup, long-term surveillance

Level 3 - NRC Guidance • Not requirements, just acceptable approach • Regulatory Guides - Guidance to licensees and

applicants on: – how NRC will implement its regulations – techniques used by the NRC staff in evaluating specific

problems – data needed by the staff in its review of applications

• NUREG-Series Publications – Guidance on regulatory decisions, results of research, results of investigations

• Additional guidance provided in inspection manual chapters, generic communications, and staff technical positions.

Key Guidance for Uranium Recovery • Regulatory Guide 3.5: Standard Format and

Content of License Applications for Uranium Mills • NUREG-1748: Environmental Review Guidance for

Licensing Actions Associated with NMSS Programs Applications

• Regulatory Guide 3.11: Design, Construction, and Inspection of Embankment Retention Systems at Uranium Recovery Facilities

• Regulatory Guide 4.14: Radiological Effluent and Environmental Monitoring at Uranium Mills

• Regulatory Guide 8.31: Information Relevant to Ensuring that Occupational Radiation Exposures at Uranium Recovery Facilities Will Be as Low as Is Reasonably Achievable

Operations

• NUREG-1620: Standard Review Plan for the Review of a Reclamation Plan for Mill Tailings Sites under Title II of the Uranium Mill Tailings Radiation Control Act of 1978

• NUREG-1623: Design of Erosion Protection for Long-Term Stabilization

Closure

The Licensing Process

Licensing Process Phases Phase I: License

Application Phase II: Facility

Operation

Phase III: Closure, License termination,

Long Term Care

Project Manager

Technical Reviewers

Environmental Reviewers

1-2 years Decades, with renewal every 10 years

Project Manager

Technical Reviewers

Environmental Reviewers

Inspectors

Applicant Licensee Licensee/DOE

Project Manager

Technical Reviewers

Environmental Reviewers

Inspectors

Up to several years for decom; Long-term care is open ended

NRC issues license

NRC performs full Technical and Environmental Review

NRC performs Acceptance Review

Applicant submits Technical and Environmental Report

NRC and applicant hold pre-application discussions

Applicant conducts site selection and characterization

Phase I: Application

Yes

Yes

Technical Review Team • The team is led by the

Project Manager

• Includes various technical specialists dictated by the type of license application

– Health Physicists

– Hydro-geologists

– Geotechnical Engineers

– Surface water hydrology and erosion experts

– Financial Specialists

Phase II: Operations

Licensee performs baseline

monitoring and constructs facility

NRC conducts construction

inspection and oversight

NRC issues license

amendment to operate

Licensee operates facility

NRC inspects and renews/amends

license Licensee decision

to close facility

ALARA Principle

• ALARA = As Low As (is) Reasonably Achievable

• Licensees must use procedures and engineering controls to achieve occupational doses and doses to members of the public that are ALARA.

ALARA continued • Licensees should set ALARA goals for effluents.

Most licensees can achieve goals of 10 to 20% of NRC requirements in 10 CFR Part 20.

• Licensees must perform surveys and monitoring to demonstrate compliance with dose limits. This includes monitoring and surveys necessary to determine whether radiation levels and effluents meet the licensee's established ALARA goals.

Liquid Waste Discharge

• NRC has established levels of radionuclides that licensees can release into unrestricted areas of the environment (10 CFR Part 20.1302(b)(2)(i) and Appendix B, Table 2).

• Some States have set conservative limits of 10% of the NRC values.

• The Clean Water Act requires NPDES Permits with stringent limitations to ensure State standards are met.

Environmental Monitoring • Areas of NRC review

– Types (radon, air particulates, biota, soils, direct radiation, water), and locations of monitoring

– Frequency of sampling – Action levels and corrective

action • Basis for review

– Regulatory Guide 4.14 on environmental monitoring programs

– 10 CFR Part 20 on doses to the public, and reporting data to NRC

Recordkeeping Records need to be kept related to:

– Implementation of the radiation protection program – Radiation surveys and instrument calibration – Occupational doses and planned special exposures – Doses to members of the public – Waste disposal – Receipt and transfer of source or byproduct material – Spills – As built drawings – Environmental monitoring (biota, air, groundwater,

surface water)

Reporting

Reports need to be sent to NRC on: – Theft or loss of material – Incidents where doses are exceeded – Exposures, radiation levels, and

concentrations of radioactive material exceeding the constraints or limits

– Unplanned contamination events – Results of effluent monitoring

Inspection and Enforcement • NRC inspectors must pass qualification • Inspection Manual Chapter 2801 addresses how uranium mill

inspected • Frequency generally 1/yr, but depends on operating history • May be announced or unannounced • Team: Lead inspector (HP); hydro-geologist, geotechnical engineer

as needed • Inspect records, interview staff, perform confirmatory surveys,

observe activities • Enforcement action may follow: NOV’s, Civil Penalties, Orders

Phase III: Closure Licensee submits Decommissioning

Plan

DP Review and Approval

(amendment)

Perform Decommissioning

Decommissioning Inspection

Submit Completion

Report and LTSP Review CR and

LTSP

Terminate License and Accept LTSP

DOE Long-Term Care

DOE Long-Term Care

For closed sites with reclaimed tailings wastes remaining, DOE is the long-term custodian

DOE licensed for long-term care under general licenses in NRC regulations (10CFR Part 40)

Specific Long-Term Surveillance Plans provide details of DOE care – DOE prepares – NRC reviews and accepts

DOE conducts annual inspections and some periodic monitoring

Additional Uranium Recovery Licensing Information

Uranium Recovery Site Types • Title I Tailings Sites – old, unlicensed,

abandoned mill tailings sites identified and cleaned up by DOE with NRC concurrence in accordance with Title I of UMTRCA

• Title II Sites – NRC or Agreement State licensed sites

• Conventional Mills - uranium recovery sites using conventional ore milling processes

• In Situ Recovery Facilities – uranium recovery through fluid injection into ore body, pumping of resulting uranium–bearing solution, and separation of the uranium in a processing facility

Characteristics of a Conventional Mill

Recovery Method Physical and chemical process to extract uranium from mined ore.

Siting Generally located near ore body; Ore trucked to mill.

Surface Features Ore storage, mill building, process tanks, tailings impoundments

Size Impoundments limited to 40 acres, but multiple impoundments can total hundreds of acres.

Wastes Mill tailings; contaminated equipment

Decommissioning Demolition of mill; cleanup of any contaminate soils; final cover over tailings; monitoring

End State Transfer to DOE for long-term care under NRC license; annual inspection

Conventional Mill Process • Ore delivered to mill • Ore crushed and ground

(water added) • Ore slurry leached by acid

or alkaline process • Solids (tailings) filtered out

and sent to impoundments • Uranium stripped from the

solution in the extraction circuit

• Yellowcake produced by precipitation and drying

Tailings: Design and Operation • NRC requirements - 10 CFR Part 40 Appendix A; Criteria

1, 3, 5A, and 8A – For selection of disposal sites, primary emphasis must be on

isolation of tailings or wastes – Disposal fully below grade; or at least minimize the size of

retention structures by excavation to the maximum extent – Disposal cells must have liners to prevent migration of

wastes out of the impoundment – Impoundment must be designed, constructed, maintained,

and operated to prevent overtopping or massive failure of dikes

– Daily inspections must be conducted • Additional EPA requirements (double liner systems,

40-acre size limitation)

Tailings: Long-Term Disposal • NRC requirements - 10 CFR Part 40 Appendix A; Criteria

4, 6, and 6A – Embankment and cover slopes must be relatively flat

after final stabilization to minimize erosion potential and to provide long-term stability

– A full self-sustaining vegetative cover must be established or rock cover employed to reduce wind and water erosion to negligible levels

– Rock must be dense, sound, and resistant to abrasion – Must place an earthen cover over tailings at the end of

milling operations and provide control of radiological hazards to (i) be effective for 1,000 years, to the extent reasonably achievable, and, in any case, for at least 200 years, and (ii) limit releases of radon to less than 20 (pCi/m2s)

Canonsburg, PA before

Canonsburg after

Tuba City, Arizona

Ambrosia Lake, New Mexico

Financial Assurance

• Licensees must provide: – Certification of

financial assurance to guarantee that funds will be available for decommissioning

– Breakdown of estimated costs for site closure

– Commitments for annual update and updates for any planned expansions or operational changes

Public Involvement

NRC Public Website Freedom of Information Act

requests Hearing requests; Petitions to

intervene – Opportunities for hearings on licensing

actions published in FR and on NRC website

– Individuals, citizen groups, private businesses, and governmental bodies have received hearing status

Input in the environmental evaluation process (scoping and comment)

Meetings with licensees/applicants open to public

Summary

The Regulatory Framework includes Laws, Regulations, and Guidance

Licensing a Uranium Recovery Facility can be looked at as having 3 main phases; Application, Operation, Closure

The application process includes hearing opportunities, technical and environmental review, public involvement

Summary continued Key regulatory aspects of operations include: Keeping doses ALARA Limiting discharges by NPDES permits Requiring collection of and reporting environmental

monitoring data and other site records Controlling tailings wastes Performing inspections

The closure process includes: Mill demolition Cleanup of any site contamination Stabilization and closure of tailings DOE long-term control under NRC license

QUESTIONS?

Uranium Tailings Management: Risks, Regulatory Requirements and Best

Management Practices

Kimberly Finke Morrison, P.E., R.G.

Morrison Geotechnical Solutions, Inc.

“Issues and Impacts: Uranium Mining and Drinking Water Supplies”

Richmond, Virginia 11 December 2012

Uranium Tailings Management

…a waste product of the mining process

Tailings are…

Mine/Pit

Waste Dump

Process Plant

Water

Concentrate Tailings

Ore

Waste Rock

$$$

TSF

Tailings Storage Facility (TSF)

• A Tailings Storage Facility (TSF), not a “Tailings

Dam”… ▫ A conventional dam is designed to store only water and has a

finite life

• Why are TSFs needed?

▫ Legislation requires them! ▫ Because mining processes produce fines wastes that need to be

contained ▫ To limit contamination arising from seepage, dust, erosion and

radiation

Golder Associates

Conventional Dams vs. TSFs

Constructed in single stage

Steady state achieved early

Owner focused on dam operation & surveillance

Owner has substantial resources available

Viewed as an asset

In-house expertise

Finite operating life

Construction ongoing

Steady state only at closure

Owner not focused on dams, focused on mining

Constraints imposed by mining economics

Not an asset

Reliance on consultants

Have to last “forever”

Conventional Dams Tailings Facilities

What is Special about TSFs?

THEY NEED TO LAST IN PERPETUITY

perpetuity = a long time

These are not equivalent propositions

This is the only one of the seven wonders of the ancient world still standing…..

This will require a much higher degree of stewardship than the Great Pyramid.

Uranium Tailings Management

Uranium Tailings – What’s are the risks?

• Contain over a dozen radioactive nuclides, emitting gamma radiation

• Radium decays to produce radon, a radioactive gas

• Radium in the tailings will not decay entirely for thousands of years

• Children’s sand boxes (e.g., uranium tailings)

• Construction material for roadways and foundations (houses, buildings)

Risks Caused by Unauthorized Removal

and Use of Tailings

Uranium Tailings Management

Regulation of Mine Tailings – Why? • To PREVENT:

▫ Death or injury to the general public

▫ Death or injury to employees

▫ Liability to the public (costs)

▫ Short term (acute) environmental impacts

▫ Damage to public infrastructure

▫ Long term (chronic) environmental impacts

▫ Perceived political risk

Uranium Tailings – Regulatory Definition

• Atomic Energy Act (1954) section 11e.(2) byproduct material

• “Tailings or wastes produced by the extraction or concentration of uranium or thorium from any ore processed primarily for its source material content”

U.S. Regulation of Uranium Tailings • 1978 – Uranium Mill

Tailings Radiation Control Act (UMTRCA)

▫ UMTRCA Title I program – remedial action at abandoned mill tailings sites

▫ UMTRCA Title II program – uranium mill sites

U.S. Regulation of Uranium Tailings • US Nuclear Regulatory Commission (NRC) responsible for

licensing (or Agreement State)

▫ NRC regulations: 10 CFR Part 40 (notably Appendix A)

• EPA responsible for establishing public exposure standards

▫ EPA regulations: 40 CFR 192

Recent Regulatory Changes

• In 1992, dramatic changes were made to the regulatory environment in the U.S. for permitting of uranium facilities

▫ Prescriptive liner system

▫ Promote fully below-grade tailings disposal

• Regulations recently being implemented after long recession

▫ Piñon Ridge Mill, Colorado

▫ Tailings Cell 4A at White Mesa Mill, Utah

▫ Sheep Mountain Project, Wyoming

▫ Crescent Junction, Utah

Key Regulatory Requirements • Appendix A to 10 CFR 40:

▫ Criterion 3 - “The ‘prime option’ for disposal of tailings is placement below grade, either in mines or specially excavated pits.”

▫ Criterion 5 - Incorporates the basic groundwater protection standards imposed by the EPA in 40 CFR Part 192 and 264 Prescriptive liner system

Need to consider: (i) installation of bottom liners (e.g., test compatibility of clay); (ii) maximize recycle and water conservation; (iii) dewatering of tailings (e.g., underdrains); (iv) neutralization

▫ Criterion 6 – Closure cover design: (i) to be effective for 1ooo years, to the extent reasonably achievable,

and in any case for at least 200 years

(ii) limit releases of radon-222 from uranium byproduct to an average release rate of 20 pCi/m2s (max.)

Regulation of Uranium Tailings

• Trust x Control = Constant (k) (reference Hugh Jones)

Legislation Community Requirements

Total Prohibition Maximum Control

Prescriptive Regulations High Control

Code of Practice General Control

Specific Guidelines General Trust

Generic Guidelines High Trust

No Regulation or Guidelines

Maximum Trust

Prescriptive Liner System • Prescriptive Liner System for

Containment of Uranium Tailings (40 CFR 264.221)

Primary geomembrane

Leak detection layer (drainage gravel or geosynthetic)

Secondary geomembrane

3 feet of 10-7 cm/sec clay

Types of Liners

No Liner

Clay Liner

Single Composite Liner

Double Composite Liner

q = 1.1x10-4 m3/s

q = 1.1x10-6 m3/s

q = 1.6x10-10 m3/s

100 times better

than clay alone

Nearly 7,000 times

better than SCL

Nearly 700,000 times

better than clay alone

Note: Compares liners with 3 ft of clay (1x10-7 cm/s)

Uranium Tailings Management

Piñon Ridge Project - Colorado • First new uranium mill proposed for construction in the US in

nearly 30 years

• Strategically located in the Uravan Mineral Belt District of Western Colorado

• Project includes design and licensing of uranium and vanadium processing facilities

Piñon Ridge Project

• Design milling capacity of 500 tpd, with potential expansion to 1000 tpd

• Mill life up to 40 years

• Major project components:

▫ Process plant

▫ Tailings cells

▫ Evaporation ponds

▫ Ore stockpile pads

• Licensing through CDPHE (Agreement State)

• Three tailings cells, constructed in phases

▫ Each cell with capacity for 13.4 years at 500 tpd operations

▫ Mostly below-grade disposal, with excess cut to be used for closure cover construction

▫ 3H:1V internal slopes with intermediate benches

▫ 10H:1V external slopes (5H:1V between cells) to achieve closure requirements

Tailings Cell Design

Tailings Cell Cross-Section

• Tailings cells designed with maximum surface area of 30 acres, with up to two cells active at any given time ▫ Tailings Cell A designed as a split cell for contingency purposes

▫ Tailings Cells B and C are designed as single cells with option for split cell construction

• Designed Liner System (top to bottom): ▫ 60 mil HDPE primary

geomembrane

Conductive geomembrane

Light-reflective (white) coating

▫ Underdrain system

▫ Leak collection system layer with geonet (on base) and drainage geocomposite (on slopes)

▫ 60 mil HDPE secondary geomembrane

▫ Geosynthetic clay liner (GCL)

Lower permeability than 3 ft of clay

Increased GCL overlaps

Tailings Cell Liner System Design

Decommissioning Process • A decommissioning and reclamation plan is required for the

entire site, as part of the permitting process ▫ The regulatory agency must approve the estimated costs for the closure,

assuming that a third party might be required to do the work

▫ A financial surety is required by Owner to assure that funds will be available to reclaim the site, if the Owner is unable to complete this task

▫ The cost estimate and surety must also include the funds necessary for the long-term monitoring of the decommissioned site to protect public health and safety

• After satisfactory completion of the closure objectives, the title to the encapsulated uranium tailings will pass to the U.S. or to the State of Colorado, at the option of the state which is responsible for the long-term care

Tailings Closure Considerations • Minimize post-closure maintenance

• Perimeter external berm side slopes designed at 10H:1V to consider closure

• Cover materials will be placed over tailings in each cell as deposition is complete

• Tailings will be dewatered (as feasible) prior to placement of closure cover materials

Tailing cell dike

Radon Barrier

Interim cover

Tailings

Erosion/ET Cover

Proposed Closure Cover Design

• Design objectives: ▫ Designed to provide containment

of byproduct for 1000 years

▫ Limit radon flux from cover surface to <20 pCi/m2 s

• Cover design: ▫ Evapotranspiration (ET) cover,

or “water balance” cover was selected

Licensing Status… • Piñon Ridge mill license application issued on 18 November 2009

• CDPHE issued completeness determination on 18 December 2009

• First public hearing: 21 January 2010 in Nucla, Colorado

• Second public hearing: 17 February 2010 in Montrose, Colorado

• Within 90 days of first public meeting: Montrose County Commissioners’ comments on ER must be received by CDPHE

▫ 19 April 2010 – Montrose County Commissioners’ comments on ER were received by CDPHE. CDPHE has 270 days to determine whether license is rejected, issued as requested, or issued with conditions

▫ Established deadline of 17 January 2011 for CDPHE’s decision (decision made on 6 January 2011)

• CDPHE issued the radioactive materials license on 7 March 2011

• However....

Licensing Status • Sheep Mountain Alliance in cooperation with Towns of

Telluride and Ophir sued CDPHE over Colorado Administrative Procedures Act: ▫ “Procedures under state law include an opportunity for the

public to participate in a public hearing which includes an opportunity for cross-examination”

▫ Obligated CDPHE to provide an adjudicatory hearing as part of the Application, but CDPHE contended that only the Applicant (i.e., Energy Fuels) can request the hearing

▫ Court ruling: License invalidated

CDPHE ordered to convene hearing within 75 days of 5 July 2012

• Adjudicatory hearings held early November 2012 • CDPHE has 270 days from 5 July 2012 to approve, approve

with conditions, or deny the Application

Uranium Tailings Management

White Mesa Mill - Utah

• Only fully-licensed and operating conventional uranium mill in the US

• Licensed capacity of 2,000 tpd

• Tailings disposal:

▫ Tailings Cells 1, 2 and 3 constructed in 1980 with engineered membrane liner

▫ Tailings Cell 4A constructed in 1990, required re-lining in late 2000s

Sheep Mountain Project - Wyoming • Major project components:

▫ Open pit

▫ Underground mining

▫ Process plant

▫ Heap leach facility

▫ Process ponds

• Pursuing licensing through NRC

▫ Draft Technical Report (TR) and Environmental Report (ER) issued in 2011

▫ Plan to issue Final TR and ER in 2013

Re-Location of Moab Impoundment • Contains 16 Mt of tailings,

current under control of the U.S. Department of Energy (DOE)

• Tailings stored in unlined facility adjacent to the Colorado River

• Atlas Uranium Mill was closed in 1984

• Pollutants from the tailings is leaching into the river

• U.S. DOE announced in 2005 plans to re-locate the tailings

Crescent Junction - Utah • New uranium tailings disposal facility

designed to store tailings re-located from the Moab Tailings Impoundment

▫ 2400-ft thick Mancos Shale extends below site, negating need for liner installation

▫ Estimated aboveground height ~20 ft

▫ Cover design ~8 ft thick multi-layer with rock cap

Uranium Tailings Management

Conclusions • More stringent regulations governing uranium licensing

in the U.S. came into effect in 1992

• In general, the regulations provide minimum requirements, many of which are often flexible to allow for site-specific optimization

• With mounting public concern for the environment, it is more important than ever to design and construct potentially hazardous facilities in a manner which minimizes present and future adverse impacts

Impacts of a Potential Uranium Mill Tailings

Release on Downstream Drinking Water Sources

Issues and Impacts:

Uranium Mining and Drinking Water Supplies

11 December 2012

Peter Pommerenk, Ph.D., P.E.

Department of Public Utilities

City of Virginia Beach

Uranium Occurrences in Virginia

Source: NAS - Uranium Mining in Virginia: Scientific, Technical, Environmental,

Human Health and Safety, and Regulatory Aspects of Uranium Mining and

Processing in Virginia

Coles Hill Uranium Deposit

[

[

Coles Hill

Lake Gaston Intake

Crewe

Oxford

Roxboro

Danville

Henderson

Altavista

Farmville

South Hill

Chase City

Blackstone

Yanceyville

South Boston

Roanoke Rapids

To

Virginia

Beach

Slid d f i hSlide removed for copyright purposes. Original Slide was titled “Coles Hill Uranium 

Deposit and is available at http://www.theenergyreport.com/cs/new/dp gy pownload/co_file/3457/VUICorporatePresent

ationNov2012.pdfationNov2012.pdf

Uranium Mining & Milling

63 million pounds

of yellowcake

60 billion pounds of waste tailings

(22 million cubic yards) containing

radioactive and toxic chemicals

Concerns about Uranium Mining at

Coles Hill

• Proposed mining location is upstream of Lake

Gaston, a water source for Virginia Beach

• Refining activities will yield large amounts of

radioactive and toxic waste material (tailings)

that have to be stored on-site

• A catastrophic failure of a tailings confinement

cell can result in contamination of the City of

Virginia Beach’s water supply

Causes of Tailing Cell Failures

Annual Average Rainfall in the U.S.

Legend

Annual Average Precipitation

inches

Less than 5

5 to 10

10 to 15

15 to 20

20 to 25

25 to 30

30 to 35

35 to 40

40 to 50

50 to 60

60 to 70

70 to 80

80 to 100

100 to 140

140 to 180

More than 180Data source: ftp://prism.oregonstate.edu//pub/prism/us/grids/ppt/Normals/

Extreme Rainfall in Virginia

Unusual Rainfall in Virginia

Source: http://www.dcr.virginia.gov/documents/dscambell.pdf

What if?

• If a catastrophe were to happen:

– Will the concentrations of toxic and radioactive

pollutants increase above the standards?

– How long will the impact last?

River/Reservoir Models

• CCHE1D (Banister, Roanoke River)

– General-purpose one-dimensional model, simulation of

long-term erosion and deposition processes in dendritic

channel networks.

– Calculates unsteady flows solving the Saint-Venant

equations.

• CCHE2D (Kerr Reservoir, Lake Gaston)

– Two-dimensional depth-averaged hydrodynamic model

– Sediment model is capable of simulating non-equilibrium

non-uniform sediment transport including suspended load,

bed load, and total load

Lake Gaston 2-D Mesh

Contaminant Fate and Transport

• Assumed linear equilibrium partition

– Highly soluble contaminants tend to remain dissolved in the water and are transported

in overall proportion with the water, (low Kd)

– Weakly soluble contaminants tend to remain associated with particles and are

transported in overall proportion with the sediment (suspended or bed) (high Kd)

Contaminants Included in the Model

Contaminant Drinking Water

Standard

Radium 226/228 5 pCi/L Ra Only

Alpha Particles 15 pCi/L Ra + Th

Uranium 30 μg/L

Tailings Release Scenarios

• Release of 720,000 yd3 of tailings into Banister River

– Estimate based on recent mining proposal and historical tailings dam failure data

• Tailings release followed by either

– Wet period (Sep 1996 – Aug 1998)

– Dry period (Jun 2001 – May 2003)

• No water withdrawal from Lake Gaston pump station

Study Scenarios

Radionuclide Solubility

Hydrology

Tailings Release to Banister

River

Wet

High

Low

Dry

High

Low

Impact to Kerr Lake

(Wet Year – High Solubility - Radium)

Clarksville

Impact to Kerr Lake

(Dry Year – High Solubility - Radium)

Clarksville

Days

Rad

ium

Co

ncen

trati

on

, p

Ci/L

0 100 200 300 400 500 600 700

0.01

0.1

1

10

100

1000Dry Year

Wet YearRadium MCL

Impacts to Kerr LakeWater Column Radium Concentration at the Clarksville Water Intake

Days

Rad

ium

Co

ncen

trati

on

, p

Ci/L

0 100 200 300 400 500 600 700

0.01

0.1

1

10

100

1000Dry Year

Wet YearRadium MCL

Impacts to Kerr LakeWater Column Radium Concentration near the Henderson, NC Water Intake

Impact to Lake Gaston

(Wet Year – High Solubility - Radium)

VB Intake

Impact to Lake Gaston

(Dry Year – High Solubility - Radium)

VB Intake

Days

Rad

ium

Co

ncen

trati

on

, p

Ci/L

0 100 200 300 400 500 600 700

0.01

0.1

1

10

100

1000Dry Year

Wet YearRadium MCL

Impacts to Lake GastonWater Column Radium Concentration in the Main Channel near Pea Hill Creek

Days

Rad

ium

Co

ncen

trati

on

, p

Ci/L

0 100 200 300 400 500 600 700

0.01

0.1

1

10

100

1000Dry Year

Wet YearRadium MCL

Impacts to Banister RiverWater Column Radium Concentration at the Town of Halifax, VA

Fate of the TailingsTotal Radioactivity (Ra + Th) in the Sediments 2 Years After Tailings Discharge

Fate of the Tailings

Water Body Fraction of Contaminants Remaining in

Sediments 2 years After Tailings Release

Radium Thorium Uranium

Banister River 54% - 83% 77% - 84% 67% - 78%

Kerr Lake 0.1% - 3.4% 2.3% - 4.2% 0.4% - 3.3%

Lake Gaston 0.03% - 0.4% 0.2% - 0.5% 0.1% - 0.6%

General Conclusions

• Impacts are dependent on stream flows and they are most significant upstream and in the main channels of the reservoirs

• Any credible scenario will likely result in contaminant concentrations above the SDWA levels.

• Contaminant concentrations would subside in the water column of the reservoirs within 2 years, but they will be will likely remain elevated for several years in Banister River.

• Most of the contaminated particulate matter will remain in the Banister River bed sediments for the foreseeable future.

• The contaminated sediments can be re-mobilized during flood events and flushed downstream

Lake Gaston near Pea Hill Creek

• Radioactivity (Ra & Th) would remain above the MCL for up to 10 months during dry years

• Radium Levels would remain above the MCL for up to 16 months during dry years

• Uranium would be elevated but not exceed the MCL

• If the pump station remained offline, no contamination would migrate into Pea Hill Creek

• However, the inability to withdraw water from Lake Gaston for up to 1.5 years would result in severe water shortages for the Cities of Virginia Beach, Chesapeake and Norfolk

Questions?

1

Kenneth E. Kunkel NOAA Cooperative Institute for Climate and Satellites

National Climatic Data Center and

Department of Marine, Earth, and Atmospheric Sciences North Carolina State University

2

• Trends in Mean Precipitation

• Trends in Extreme Precipitation

• Meteorological Causes of Extreme Precip Trends

• Possible Role of Water Vapor

• Climate Model Simulations of Future

3

• Results shown at national and even global scales

• Exhibits the extent to which results are coherent on large spatial scales

• Drill down to Virginia

4

5 5

6 6

7

8

• Many studies have found an upward trend in various measures of heavy precipitation events in the U.S.

9

• 48-hr, 5-yr storms

• Trends in number of such storms

10

Long-term Precipitation Stations

11 11

12

0.0

0.5

1.0

1.5

2.0

2.5

3.0

3.5

Nu

mb

er

of

sto

rms

Pe

r Y

ea

r

Decade

48-hr, 5-yr Storms in Virginia

13

14

• Have there been changes over time in the frequency, intensity, and other characteristics of the meteorological phenomena producing heavy precipitation?

• Are the recent increases primarily a result of increases in atmospheric water vapor concentrations?

15

• Extratropical Cyclones Frontal (at least ~300 km away from center of surface or

upper low)

ETC (near surface or upper low center)

• Tropical Cyclones

• Mesoscale Convective Systems

• Air Mass Convection

• North American Monsoon

• Upslope

16

17

0.00

0.05

0.10

0.15

0.20

0.25

1900 1910 1920 1930 1940 1950 1960 1970 1980 1990 2000 2010

Nu

mb

er

of

Eve

nts

/Sta

tio

n/y

r

Year

ETC Frontal Tropical

18

0.00

0.01

0.02

0.03

0.04

0.05

1900 1910 1920 1930 1940 1950 1960 1970 1980 1990 2000 2010

Nu

mb

er

of

Eve

nts

/Sta

tio

n/y

r

Year

Monsoon Air Mass MCC Upslope

19

• Fraction of all events caused by tropical storms or hurricances

20

Percent of extreme events caused by Tropical Cyclones

21

Heavy Event Frequency vs. Landfalling Hurricane Number

22

23

Adapted from Kunkel, K.E. et al., 2012 (In Review). Monitoring and Understanding Changes in Extreme Storm Statistics: State of Knowledge. BAMS.

Difference between 1990-2009 minus 1971-1989 for daily, 1-in-5-year extreme events

23

24

25 25

26

27

• Computer programs which represent the physical equations governing motion in the atmosphere

• Extension of weather forecast models

• We analyzed newest set of models being used for the upcoming 5th Assessment Report of the Intergovernmental Panel on Climate Change (IPCC)

• I will show results for the end of the 21st Century under a high CO2 emissions scenario

28

• Atmospheric Water Vapor

• Upward motion of atmosphere

29

30

31

32

33

• We have observed increases in the frequency of occurrence of extreme precipitation events in the eastern U.S. and Virginia

• Climate models show large future increases in atmospheric water vapor and the magnitude of the largest precipitation events

34

• Our confidence in future increases in atmospheric water vapor is high because we have a good physical understanding of the mechanism Imbalance in radiative energy budget Excess energy deposited in ocean surface waters Increase in water vapor concentrations near surface

• Our understanding of future changes (if any) in the number and characteristics of fronts and tropical cyclones is less

35

• Support for portions of this study was provided by the NOAA Climate Program Office, Climate Observations and Monitoring Program

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State of the Science: Water Treatment

Ben Wright, PE

December 11, 2012

Issues and Impacts: Uranium Mining

and Drinking Water Supplies

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Pathways – both acute and chronic

Mining Operations

Solid Waste

•Tailing PilesMilling

Aqueous Waste

•Tailing Ponds

Aqueous Discharge

•Solids

•Heavy Metals

•Radiologicals

•Δ pH

•Nitrogen •Other Chemicals

(Lixiviant, etc.)

Surface Water Ground Water

Uncaptured Runoff Captured Runoff SpillsTreatment

Mechanism

•Stormwater

•Pond Failure•Catastrophic Event

Discharge Affected by:

•Inefficient Design

•Overflow•Process Upset

Possible Processes

� Ion Exchange/ Adsorption

�Bioremediation�FeCl

�BaCl2

Mechanism

•Stormwater

•Pond Failure•Catastrophic Event

Mechanism

•Stormwater

•Air Deposition

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Uranium: Complex Aqueous Chemistry

� Uranium moves between soluble and insoluble

states based on environmental characteristics

� pH

� presence of organic matter

� oxidation-reduction potential

� complexing agent concentrations (carbonate, fluoride,

sulfate, phosphate, and dissolved carbon)

� aluminum- and iron-oxide mineral concentrations

� uranium concentrations

� presence of sorbing materials

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Common Treatment Methods for Uranium Wastewater

� Uranium can be removed from solution through

precipitation, co-precipitation, and adsorption

using the following treatments

� Lime Softening

� Enhanced Coagulation/Filtration

� Ion Exchange

� Reverse Osmosis

� Permeable Reactive Barriers

� Bioremediation

� Activated Alumina Adsorption

� Electrodialysis

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Uranium Mining and Milling Discharge Limits

Effluent characteristic Maximum value for any

1 day

Average Daily value for

30 consecutive days MCLG MCL

COD (mg/L) 200 100 NA NA

Zn (mg/L) 1.0 0.5 5 5

Ra 226 (dissolved) (pCi/L) 10.0 3.0 zero NA

Ra 226 (total) (pCi/L) 30.0 10.0 5 5

U (mg/L) 4.0 2.0 Zero 0.03

pH 6 to 9 6 to 9 6.5 to 8.5 6.5 to 8.5

TSS (mg/L) 30.0 20.0 NA NA

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Comparing Discharge Standards with Drinking Water MCLs

0

1

10

100

1,000

10,000

Ura

niu

m M

ine

an

d M

ill D

isch

arg

e R

ate

(M

GD

) a

t co

nce

ntr

ati

on

s

pe

r 4

0 C

FR

44

0 (

2 m

g/L

fo

r U

an

d 5

pC

i/L

for

Ra

22

6)

River Flow (MGD) assumed Background Concentration Equals Detection Limit (0.0005 mg/L

for U and 0.15 pCi/L for Ra 226)

Radium 226 Uranium

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Drinking Water Treatment Considerations – chronic impacts

� Chronic discharges may increase the background concentration of radionuclides

� Unless the discharge is very large relative to streamflowthere is little risk of exceeding MCLs

� However, there is the distinct risk of creating TENORN or LLRW in residuals that is regulated and extremely difficult to dispose of

� Cost of resin disposal increased from $2,000 to over $80,000 for

disposal of ~200 cubic feet of resin for Glendale Water and

Power

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Virginia Definition of TENORM 12VAC5-481-10

� "Technologically Enhanced Naturally Occurring Radioactive Material (TENORM)" means . . . Naturally occurring radionuclides whose concentrations are increased by or as a result of past or present human practices. TENORM does not include background radiation or the natural radioactivity of rocks or soils. TENORM does not include uranium or thorium in "source material" as defined in the AEA and NRC regulations.

� Source material is defined by NRC as having 0.05% by weight of Uranium or Thorium

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Drinking Water Treatment Considerations – acute impacts

� Major acute event would be the failure of storage or treatment facility that released large volumes contaminated wastes into the water supply

� Effective treatment could be implemented in emergency situations, but at great expense

� Taking supply offline until the plume passes

� Long term chronic issues may result from uranium deposited with sediment in rivers or lakes.

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Critical Uncertainties

�Drinking water utility risk exposure will be related to the following uncertainties:

� Discharge rates and concentrations

� Drainage plans / design storm

� Proximity to surface water

� Landslide potential

� Structural design

� Below- vs. above-grade construction

� Quality control during construction

� Structural inspections and maintenance

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�Questions?