The following has been presented to the Uranium Mining Subcommittee by the Dan River Basin Ass'n Mining Task Force. It suggests several specific, line-by-line changes to the study's Statement of Task. The suggestions are excellent.
We appreciate DRBA's sharing this with us so that we could share it with you.
To: Uranium Mining Subcommittee
By: Katie Whitehead, Chair, Dan River Basin Association Mining Task Force
Wayne Kirkpatrick, President, Dan River Basin Association
Re: Uranium Mining in Virginia – Statement of Task
From the point of view of the National Academy of Sciences, the Statement of Task should
1) state what the National Research Council thinks the study sponsor wants
2) summarize what the National Research Council can realistically offer to do
From the point of view of the Uranium Mining Subcommittee, the Statement of Task can and should
1) accurately represent what the subcommittee wants in a study
2) clarify for the subcommittee and interested citizens what the study will and will not do
The draft before you today is not a “final recommendation” from the National Academy of Sciences. It is a draft document that attempts to summarize what you want. It is the National Research Council’s first take and comes with the question, implied if not stated, Is this what you want?
It would not be disrespectful to request changes.
The National Research Council is a contractor responding to a client request. You are the client. They have responded to the draft document that you sent them.
The subcommittee asked the National Research Council to “assess the scientific and technical aspects of uranium mining, milling and processing in Virginia and associated environmental, human health, safety and regulatory issues.”
The subcommittee did not ask the National Research Council to “determine whether uranium can be mined safely in Virginia .”
The study will not “determine” what Virginia should do. You and other citizens and legislators will decide public policy. Science will not discover the answer; you, our elected representatives, will choose.
The idea that some of the best scientific experts in the world will determine what we should do appeals to many citizens and appears to let legislators off the hook – as though the study will decide. Let us be clear: the study will not decide anything.
The Dan River Basin Association would like to recommend changes that clarify what the study will and will not do.
Included here are 8-10 very specific suggestions.
The Dan River Basin Association would also like to state for the record that we do not think that the study you have asked for is the study people expect. People want answers to their questions:
Is uranium mining safe? Safe or not, is it a good idea? Can uranium mining sustain our communities and quality of life?
People have been led to believe the study will answer these questions and save us from public policy driven by political influence. The study will not decide for us. When the time comes, legislators and citizens will still have to choose.
To clarify what the study will and will not do, please incorporate these changes:
Task 2:
· For clarity, include additional examples of deposit characteristics that parallel the list in Task 3.
· Explicitly state that task 2 includes comparisons between sites worldwide and Virginia .
Task 3:
· Explicitly list “demographics.”
· Clarify use of the term “uranium resources” to avoid possible confusion with the legal and financial use of the term to mean indicated and measured resources.
Tasks 4, 5, 7, 8, 9, 10:
· Explicitly list “ore storage” and “long-term tailings management.”
Tasks 5:
· Include “local” government and the “potential for government responsibility and financial liability.”
Task 7:
· Explicitly include chemical and radiological health effects and available epidemiologic and animal research.
Task 8:
· Clarify that water and waste management and severe weather events are relevant.
Task 10:
· Explicitly include “whether exploratory drilling can compromise baseline data.”
Task 11:
· Omit task 11 because it appears to anticipate that uranium mining will be permitted. It does not make sense to perform this task unless Virginia chooses to change its current policy regarding uranium mining.
Concluding sentence:
~~~~~~~~~~~~~~~~~~~~~
Statement of Task
Uranium mining in the Commonwealth of Virginia has been prohibited since 1982 by a state moratorium, although approval for restricted uranium exploration in the state was granted in 2007. A National Research Council study will examine the scientific, technical, environmental, human health and safety, and regulatory aspects of uranium mining, milling, and processing as they relate to the Commonwealth of Virginia. In particular, the study will:
1) Review global and national uranium market trends.
2) Identify and briefly describe the main types of uranium deposits worldwide including, for example, geologic characteristics, environmental, geographic, climatic, demographic, and cultural settings; mining operations, and best practices; and health, safety, and environmental records. Consider whether any site or sites might serve as an example of what citizens could reasonably expect in Virginia if uranium mining were permitted.
3) Review the geologic, environmental, geographic, climatic, demographic, and cultural settings and exploration status of uranium resources in the Commonwealth of Virginia . The term “uranium resources,” as used here, is a general term that does not in any way limit the review to a specific site or type of deposit.
4) Review the primary technical options and best practices approaches for uranium mining, ore storage, milling, processing, and reclamation that might be applicable within the Commonwealth of Virginia , including discussion of improvements made since 1980 in the design, construction, and monitoring of tailings impoundments (“cells”).
5) Review the local, state and federal regulatory framework and potential for government responsibility and financial liability for uranium mining, ore storage, milling, processing, and reclamation, and long-term tailings management.
6) Review federal requirements for secure handling of uranium materials, including personnel, transportation, site security, and material control and accountability.
7) Assess the potential short- and long-term occupational and public health and safety considerations from uranium mining, ore storage, milling, processing, and reclamation, and long-term tailings management, including the potential human health effects from exposure to “daughter” products of radioactive decay of uranium. Include an assessment of epidemiologic research and animal studies regarding the chemical and radiological health effects of long-term exposure to low-level radiation and low-dose heavy metals, such as might be experienced living near uranium mines, mills, and tailings.
8) Identify the issues that may need to be considered regarding effects upon the quality and quantity of groundwater and surface water, and the quality of soil and air from uranium mining, ore storage, milling, processing, and reclamation, and long-term tailings management, such as water and waste management, severe weather effects and other stochastic events. As relevant, water and waste management and severe weather effects or other stochastic events may also be considered.
9) Assess the potential ecosystem issues for uranium mining, ore storage, milling, processing, and reclamation, and long-term tailings management.
10) Identify baseline data and approaches necessary to monitor environmental and human impacts associated with uranium mining, ore storage, milling, processing, and reclamation, and long-term tailings management, and assess whether exploratory drilling can compromise baseline data.
11) Briefly characterize a potential public education and outreach program in the Commonwealth of Virginia for a uranium mining operation (for example, health and safety issues, inspection and enforcement, community right-to-know, emergency planning).
By addressing these questions, 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 or make a policy decision as to whether uranium can be mined safely; nor will the study include site-specific assessments.
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