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Home My WebLink About 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 ?