08232011 URANIUM MINING PRESENTATIONTechnical Review of
“Preliminary Assessment of Potential
Impacts
of Uranium Mining in Virginia
on Drinking Water Sources”
by Michael Baker
A MORE ACCURATE LOOK AT
THE COLES HILL URANIUM PROJECT
Alan Kuhn, PhD, PE, RG, D.GE
for
Virginia Uranium Inc.
August 23, 2011
FINDINGS OF THE REVIEW OF THE BAKER STUDY
Baker study used generally accepted methods for
•
consequences of a tailing release, but the scope was limited
and did not take into account the extremely low probability of
the release of tailings.
Assumptions disregard regulatory requirements and current
•
engineering standards and best practices
Failure event was based on unrealistic assumptions about
•
location and design of tailing impoundments
Scope of the Baker Report
“…the assessment focused on the potential of a catastrophic
failure of a uranium-tailings containment structureand
subsequent discharge of uranium tailings…”(page ES-1)
Thereafter in the report, catastrophic failure was
assumed as certain.
“This report provides the results of a preliminary assessment
performed to evaluate the potential impact of..(uranium
tailings) that could be discharged…” (page 1)
BAKER
“….based on the best available information”.
(pages ES-7, 221)
Presently, uranium tailings are required to be
“
stored in specially designed waste disposal
facilities called containment cells or structures,
in compliance with Nuclear Regulatory
Commission regulations”. (page 1)
DAM REFERENCE USED BY BAKER
Rico, M. Benito, G., Diez-Herrero, A., 2008.
•
Floods from Tailing Dam Failure. Journal of
Hazardous Waste Materials 154, 79-87
None of these dams was designed and constructed
in accordance with existing regulations and
standards for uranium tailing impoundments.
NUCLEAR REGULATORY COMMISSION REFERENCES AND
STANDARDS FOR TAILINGS IMPOUNDMENTS
Uranium Mill Tailings Radiation Control Act of 1978
•
(UMTRCA)
10 CFR Part 40, Appendix A, Criteria Relating to the
•
Operation of Uranium Mills and the Disposition of Tailings
or Wastes Produced by the Extraction or Concentration of
Source Material from Ores Processed Primarily for their
Source Material Content
Regulatory Guide 3.11, Design Construction and
•
Inspection of Embankment Retention systems for Uranium
Mills
OTHER PRIMARY FEDERAL AND STATE LAWS AND REGULATIONS
AFFECTING URANIUM TAILING IMPOUNDMENTS
•40 CFR Part 192, Health and Environmental
Protection Standards for Uranium and Thorium Mill
Tailings
•40 CFR Part 264 Subpart K Surface Impoundments
•National Historic Preservation Act
•Archeological Resources Protection Act of 1979
•Endangered Species Act (ESA)
•Clean Air Act
•Clean Water Act
•Safe Drinking Water Act
•National Environmental Policy Act
•Virginia Impounding Structures Regulations (Dam
Safety) ?4VAC50-20
SOME TAILING IMPOUNDMENT DESIGN REFERENCES
Readily Accessible on the Internet
•U.S. Environmental Protection Agency, 1994. DESIGN AND EVALUATION OF TAILINGS DAMS
TECHNICAL REPORT EPA 530-R-94-038, NTIS PB94-201845
•U.S. Deptof Interior, Bureau of Reclamation, 1987. DESIGN OF SMALL DAMS, Water Resources
Technical Publication
•California Mining Association. 1991. . Sacramento, CA.
Mine Waste Management
•Doyle, F.M. (ed.). 1990. "Mining and Mineral Processing Wastes: Proceedings of the Western
Regional Symposium on Mining and Mineral Processing Wastes, Berkeley, CA, May 30 -June 1,
1990." Society for Mining, Metallurgy, and Exploration, Inc. Littleton, Colorado.
•Mittal, H.K. and N.R. Morgenstern. 1977. "Design and Performance of Tailings Dams." ASCE
Conference on Geotechnical Practice for Disposal of Solid Waste Materials.
•** Vick, S.G. 1990. Planning, Design and Analysis of Tailings Dams. BiTechPublishers Ltd.
•Fredland, J.W. 2008, Developments in the Safety and Security of Mining Industry Dams, Mine
Safety and Health Administration, Tailings and Mine Waste `08 Conference
•US Army Corps of Engineers, 2004 . General Design and Construction Considerations for Earth
and Rock-Fill Dams, EM 1110-2-2300
•Canadian Geotechnical Society. 1989. "Geotechnical Aspects of Tailings Disposal and Acid Mine
Drainage." Proceedings of a conference held May 26, 1989, Vancouver, British Columbia
•Allan Breitenbach, 2010, OVERVIEW OF TAILINGS DISPOSAL & DAM CONSTRUCTION
PRACTICES IN THE 21ST CENTURY, Tailings & Mine Waste Conference 2010, Vail, Colorado
USA
**Baker made reference to VICK’s first edition (1983) but used it only for tailings grain size
characterization, not as a design reference.
“…for the purposes of this study, a horizontal bottom which provided
uniform depth over the entire reservoir is assumed to obtain the
maximum volume impounded by the dams with different heights”.
(Baker study, page 86)
A tailing impoundment with a 40-acre horizontal bottom would have
vertical sides.
Physically impossible to construct
•
Would not be permitted
•
40-acre
surface area
Horizontal 40-acre
bottom
ACTUAL TAILING IMPOUNDMENT WILL HAVE
SLOPED SIDES
40 acre surface area
Because impoundment sides
must be slopes, actual tailing
volumes would be 9% to 55%
less than assumed in the Baker
model.
Ref: 10 CFR 40 App. A, Criteria 3, 5; 40 CFR 192 Subparts D, E; 40 CFR
264.221
DESIGN FEATURES OF A TAILING IMPOUNDMENT
MAXIMUM WATER SURFACE
FREEBOARD
DAM
Tailings
Erosion Protection
Excavated Cell
E
Liner
CELL BELOW GROUND
SURFACE AS MUCH AS
MINIMUM REQUIRED FREEBOARD WILL
POSSIBLE
PROVIDE SPACE FOR:
Storage of Probable Maximum Precipitation
+ wave run-up height
UNREALISTIC LOCATIONS
ASSUMED IN THE BAKER STUDY
Near the Roanoke River
•
too far from the mine
–
no property position there
–
Adjacent to the Banister River -would violate
•
Federal regulations for
flood plain
–
wetlands
–
The Banister River Model
Coles
Hill
Banister
River
Kerr
Reservoir
THE ASSUMED LOCATION OF THE TAILING
IMPOUNDMENT IS NOT POSSIBLE
•Distance from Mine/ Mill Location
•PMF floodplain
•Wetlands
Baker Study Assumed
Dam Location Here
(Fig. 5-47)
Ref: 10 CFR 40 App. A, Criteria 1,4
MAXIMUM POSSIBLE
HEIGHT AT THIS
LOCATION IS 53 FT.
BAKER STUDY POSTULATED
DAM HEIGHTS OF
16, 49, 98AND 164FT.
TAILINGS LOCATED IN AREAS ABOVE FLOOD PLAINS
NO TAILINGS IN THIS AREA
PROBABLE MAXIMUM FLOOD LEVEL
GROUND WATER TABLE
THE COLES HILL URANIUM PROJECT LIFE CYCLE
MILL
MINE
TAILING
DECLINE
CELL
MINE
If approved by the NRC, tailings will
be placed both in the mine space
as backfill and in impoundments
SUMMARY
•THE BAKER STUDY USED UNREALISTIC ASSUMPTIONS ABOUT THE
DESIGN, LOCATION, AND REGULATORY REQUIREMENTS FOR THE
TAILINGS IMPOUNDMENT AT COLES HILL.
•ALTHOUGH THE COLES HILL TAILING IMPOUNDMENT DESIGN HAS
NOT YET STARTED, AN EXTENSIVE AMOUNT OF DESIGN
INFORMATION ALREADY EXISTS TO SUPPORT BETTER ASSUMPTIONS
THAN THOSE MADE BY BAKER.
•EXISTING REGULATIONS AND BEST CURRENT PRACTICE REQUIRE
DESIGN OF IMPOUNDMENTS THAT PROVIDE PROTECTION AGAINST
THE “CATASTROPHIC FAILURE” POSTULATED BY BAKER, MAKING ITS
PROBABILITY “EFFECTIVELY ZERO”.
•BECAUSE THE BAKER STUDY DOES NOT ADDRESS EITHER
PROBABILITY OF TAILING RELEASE OR MONITORING AND
TREATMENT OF WATER IN THE MUNICIPAL WATER SYSTEM, IT HAS
CAUSED UNJUSTIFIED ALARM, HOWEVER UNINTENTIONAL
QUESTIONS ?