In the 1970s and 1980s, exploration for uranium deposits in the Commonwealth of Virginia identified a number of areas containing potential ore deposits, and several large tracts of land in the Commonwealth were leased for exploration. A particularly rich deposit of uranium—the Coles Hill uranium deposit—was discovered in 1978 in Pittsylvania County, south central Virginia, and more detailed geological exploration of this deposit was undertaken in the 1980s. In 1982, the Commonwealth of Virginia enacted a statewide moratorium on uranium mining, although approval for restricted uranium exploration in the state was granted in 2007.
In 2009, the National Research Council was commissioned to prepare a report describing the scientific, technical, environmental, human health and safety, and regulatory aspects of uranium mining and processing as they relate to the Commonwealth of Virginia, with the ultimate objective of providing independent, expert advice to help inform decisions about uranium mining and processing in Virginia. The impetus for this study came from the Virginia legislature, in the form of a request from the Virginia Coal and Energy Commission. Additional letters supporting this request were received from U.S. Senators Mark Warner and Jim Webb and from Governor Kaine. The study was funded under a contract with the Virginia Center for Coal and Energy Research at Virginia Polytechnic Institute and State University (Virginia Tech); funding for the study was provided to Virginia Tech by Virginia Uranium, Inc.
The formal task statement for the study committee was wide-ranging, encompassing the physical and social context in which uranium mining and processing might occur; the occurrences and exploration status of uranium in Virginia and the global and national uranium markets; the primary technical options and best
practices for uranium mining, processing, and reclamation that might be applicable within the Commonwealth of Virginia; and the potential impact of uranium mining, processing, and reclamation operations on occupational and public health, safety, and the environment. A review of the state and federal regulatory framework for uranium mining, processing, and reclamation was also identified as part of the committee’s charge. The task statement required scientific and technical analysis, and although the social context is included as a required component, consideration of the potential socioeconomic impacts of uranium mining and processing was outside the committee’s purview. The task statement for the committee specifically noted that the study should not make recommendations about whether or not uranium mining should be permitted, and would not include site-specific assessments.
The committee met seven times over 11 months, and all but one of the meetings included time set aside for public comment. This included two evening sessions organized as “town hall”-style meetings, to receive community input and commentary. In addition, the committee traveled to northeastern Saskatchewan, Canada, for site visits to two uranium mines and associated processing facilities. This challenging schedule was designed to allow the committee to receive briefings regarding the scientific and technical aspects of its charge; to receive input from individuals and community organizations; to deliberate on its findings; and to write its report. The committee’s deliberations resulted in a series of findings and key concepts covering the broad range of its task statement, together with some overarching as well as specific best practices related to uranium mining, processing, reclamation, and long-term stewardship. These findings and key concepts are summarized as bullet points under a series of specific topic headings below. Note that the description of potential impacts of uranium mining, processing, and reclamation operations on occupational and public health, safety, and the environment are presented separately from the section on the range of best practices that could be applied to mitigate some of these adverse impacts.
VIRGINIA PHYSICAL AND SOCIAL CONTEXT
• Virginia has a diverse natural and cultural heritage, and a detailed assessment of both the potential site and its surrounding area (including natural, historical, and social characteristics) would be needed if uranium mining and processing were to be undertaken. Virginia’s natural resources include a wide range of plants, animals, and ecosystems, a large number of which are currently under significant stress.
• The demographic makeup of the state varies greatly, both among and within its physiographic provinces.
• Virginia is subject to extreme natural events, including relatively large precipitation events and earthquakes. Although very difficult to accurately forecast, the risks and hazards associated with extreme natural events would need to
be taken into account when evaluating any particular site’s suitability for uranium mining and processing operations.
URANIUM OCCURRENCES, RESOURCES, AND MARKETS
• 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.
• In 2008, uranium was produced in 20 countries; however, more than 92 percent of the world’s uranium production came from only eight countries (Kazakhstan, Canada, Australia, Namibia, Niger, Russia, Uzbekistan, and the United States).
• 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, 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.
MINING, PROCESSING, AND RECLAMATION
• The choice of mining methods and processing parameters for uranium recovery depends on multiple factors that are primarily associated with the geological and geotechnical characteristics of a uranium deposit—its mineralogy and rock type, as well as a range of other factors. Additional factors that require consideration are the location and depth of the deposit, whether the location is in a positive or negative water balance situation, as well as a range of environmental and socioeconomic factors. Consequently, a final design would require extensive site-specific analysis, and accordingly it is not possible at this stage to predict what specific type of uranium mining or processing might apply to ore deposits in Virginia.1
• Uranium recovery from ores is primarily a hydrometallurgical process using chemical processes with industrial chemicals, with a lesser dependence on physical processes such as crushing and grinding.
• Mine design—whether open pit or underground—requires detailed engineering planning that would include pit and rock stability considerations, as well
1The report notes that in situ leaching/in situ recovery (ISL/ISR) mining methods are unlikely to be applicable in Virginia because of the geological characteristics of known uranium occurrences.
as ventilation design to account for the presence of radon and other respiratory hazards.
• With the ore grades expected in Virginia, many of the technical aspects of mining for uranium would be essentially the same as those applying to other hard-rock mining operations. However, uranium mining and processing add another dimension of risk because of the potential for exposure to elevated concentrations of radionuclides.
• A complete life-cycle analysis is an essential component of planning for the exploitation of a uranium deposit—from exploration, through engineering and design, to startup, operations, reclamation, and finally to decommissioning leading to final closure and postclosure monitoring.
POTENTIAL HEALTH EFFECTS
• Uranium mining and processing are associated with a wide range of potential adverse human health risks. Some of these risks arise out of aspects of uranium mining and processing specific to that enterprise, whereas other risks apply to the mining sector generally, and still others are linked more broadly to large-scale industrial or construction activities. These health risks typically are most relevant to individuals occupationally exposed in this industry, but certain exposures and their associated risks can extend via environmental pathways to the general population.
• Protracted exposure to radon decay products generally represents the greatest radiation-related health risk from uranium-related mining and processing operations. Radon’s alpha-emitting radioactive decay products are strongly and causally linked to lung cancer in humans. Indeed, the populations in which this has been most clearly established are uranium miners that were occupationally exposed to radon.
• In 1987, the National Institute for Occupational Safety and Health (NIOSH) recognized that current occupational standards for radon exposure in the United States do not provide adequate protection for workers at risk of lung cancer from protracted radon decay exposure, recommending that the occupational exposure limit for radon decay products should be reduced substantially. To date, this recommendation by NIOSH has not been incorporated into an enforceable standard by the U.S. Department of Labor’s Mine Safety and Health Administration or the Occupational Safety and Health Administration.
• Radon and its alpha-emitting radioactive decay products are generally the most important, but are not the sole radionuclides of health concern associated with uranium mining and processing. Workers are also at risk from exposure to other radionuclides, including uranium itself, which undergo radioactive decay by alpha, beta, or gamma emission. In particular, radium-226 and its decay products (e.g., bismuth-214 and lead-214) present alpha and gamma radiation hazards to uranium miners and processors.
• Radiation exposures to the general population resulting from off-site releases of radionuclides (e.g., airborne radon decay products, airborne thorium-230 (230Th) or radium-226 (226Ra) particles, 226Ra in water supplies) present some risk. The potential for adverse health effects increases if there are uncontrolled releases as a result of extreme events (e.g., foods, fire, earthquakes) or human error. The potential for adverse health effects related to releases of radionuclides is directly related to the population density near the mine or processing facility.
• Internal exposure to radioactive materials during uranium mining and processing can take place through inhalation, ingestion, or through a cut in the skin. External radiation exposure (e.g., exposure to beta, gamma, and to a lesser extent, alpha radiation) can also present a health risk.
• Because 230Th and 226Ra are present in mine tailings, these radionuclides and their decay products can—if not controlled adequately—contaminate the local environment under certain conditions, in particular by seeping into water sources and thereby increasing radionuclide concentrations. This, in turn, can lead to a risk of cancer from drinking water (e.g., cancer of the bone) that is higher than the risk of cancer that would have existed had there been no radionuclide release from tailings.
• A large proportion of the epidemiological studies performed in the United States, exploring adverse health effects from potential off-site radionuclide releases from uranium mining and processing facilities, have lacked the ability to evaluate causal relationships (e.g., to test study hypotheses) because of their ecological study design.
• The decay products of uranium (e.g., 230Th, 226Ra) provide a constant source of radiation in uranium tailings for thousands of years, substantially outlasting the current U.S. regulations for oversight of processing facility tailings.
• Radionuclides are not the only uranium mining- and processing-associated occupational exposures with potential adverse human health effects; two other notable inhalation risks are posed by silica dust and diesel exhaust. Neither of these is specific to uranium mining, but both have been prevalent historically in the uranium mining and processing industry. Of particular importance is the body of evidence from occupational studies showing that both silica and diesel exhaust exposure increase the risk of lung cancer, the main risk also associated with radon decay product exposure. To the extent that cigarette smoking poses further risk in absolute terms, there is potential for increased disease, including combined effects that are more than just additive.
• Although uranium mining-specific injury data for the United States were not available for review, work-related physical trauma risk (including electrical injury) is particularly high in the mining sector overall and this could be anticipated to also apply to uranium mining. In addition, hearing loss has been a major problem in the mining sector generally, and based on limited data from overseas studies, may also be a problem for uranium mining.
• A number of other exposures associated with uranium mining or processing, including waste management, also could carry the potential for adverse human health effects, although in many cases the detailed studies that might better elucidate such risks are not available.
• Assessing the potential risks of multiple combined exposures from uranium mining and processing activities is not possible in practical terms, even though the example of multiple potential lung carcinogen exposures in uranium mining and processing underscores that this is more than a theoretical concern.
POTENTIAL ENVIRONMENTAL EFFECTS
• Uranium mining, processing, and reclamation in Virginia have the potential to affect surface water quality and quantity, groundwater quality and quantity, soils, air quality, and biota. The impacts of these activities in Virginia would depend on site-specific conditions, the rigor of the monitoring program established to provide early warning of contaminant migration, and the efforts to mitigate and control potential impacts. If uranium mining, processing, and reclamation are designed, constructed, operated, and monitored according to modern international best practices, near- to moderate-term environmental effects specific to uranium mining and processing should be substantially reduced.
• Tailings disposal sites represent potential sources of contamination for thousands of years, and the long-term risks remain poorly defined. Although significant improvements have been made in recent years to tailings management engineering and designs to isolate mine waste from the environment, limited data exist to confirm the long-term effectiveness of uranium tailings management facilities that have been designed and constructed according to modern best practices.
• Significant potential environmental risks are associated with extreme natural events and failures in management practices. Extreme natural events (e.g., hurricanes, earthquakes, intense rainfall events, drought) have the potential to lead to the release of contaminants if facilities are not designed and constructed to withstand such an event, or fail to perform as designed.
• Models and comprehensive site characterization are important for estimating the potential environmental effects associated with a specific uranium mine and processing facility. A thorough site characterization, supplemented by air quality and hydrological modeling, is essential for estimating the potential environmental impacts of uranium mining and processing under site-specific conditions and mitigation practices.
REGULATION AND OVERSIGHT
• The activities involved in uranium mining, processing, reclamation, and long-term stewardship are subject to a variety of federal and state laws that are the responsibility of numerous federal and state agencies.
• Because the Commonwealth of Virginia enacted a moratorium on uranium mining in 1982, the state has essentially no experience regulating uranium mining and there is no existing regulatory infrastructure specifically for uranium mining. The state does have programs that regulate hard-rock mining and coal mining.
• There is no federal law that specifically applies to uranium mining on non-federally owned lands; state laws and regulations have jurisdiction over these mining activities. Federal and state worker protection laws, and federal and state environmental laws, variously apply to occupational safety and health, and air, water, and land pollution resulting from mining activities.
• At present, there are gaps in legal and regulatory coverage for activities involved in uranium mining, processing, reclamation, and long-term stewardship. Some of these gaps have resulted from the moratorium on uranium mining that Virginia has in place; others are gaps in current laws or regulations, or in the way that they are applied. Although there are several options for addressing these gaps, the committee notes that Canada and the state of Colorado have enacted laws and promulgated regulations based on best practices that require modern mining and processing methods, and empower regulatory agencies with strong information-gathering, enforcement, and inspection authorities. In addition, best practice would be for state agencies, with public stakeholder involvement, to encourage the owner/operator of a facility to go beyond the regulations to adopt international industry standards if they are more rigorous than the existing regulations.
• The U.S. federal government has only limited recent experience regulating conventional2 uranium processing and reclamation of uranium mining and processing facilities. Because almost all uranium mining and processing to date has taken place in parts of the United States that have a negative water balance, federal agencies have limited experience applying laws and regulations in positive water balance situations. The U.S. federal government has considerable experience attempting to remediate contamination due to past, inappropriate practices at closed or abandoned sites.
• Under the current regulatory structure, opportunities for meaningful public involvement are fragmented and limited.
At a high level, there are three overarching best-practice concepts, consistent with practices that are recognized and applied by the international uranium mining and processing community:
• Development of a uranium mining and processing facility has planning, construction, production, closure, and long-term stewardship phases, and best
2Conventional mining and processing includes surface or open-pit mining, or some combination of the two, and their associated processing plants, but excludes ISL/ISR uranium recovery.
practice requires a complete life-cycle approach during the project planning phase. Planning should take into account all aspects of the process—including the eventual closure, site remediation and reclamation, and return of the affected area to as close to natural condition as possible—prior to initiation of a project. Good operating practice is for site and waste remediation to be carried out on a continual basis during ore recovery, thereby reducing the time and costs for final decommissioning, remediation, and reclamation. Regular and structured risk analyses, hazard analyses, and operations analyses should take place within a structured change management system, and the results of all such assessments should be openly available and communicated to the public.
• Development of a mining and/or processing project should use the expertise and experience of professionals familiar with internationally accepted best practices, to form an integrated and cross-disciplinary collaboration that encompasses all components of the project, including legal, environmental, health, monitoring, safety, and engineering elements.
• Meaningful and timely public participation should occur throughout the life cycle of a project, beginning at the earliest stages of project planning. This requires creating an environment in which the public is both informed about, and can comment upon, any decisions made that could affect their community. Notice should be given to interested parties in a timely manner so that their participation in the regulatory decision-making process can be maximized. All stages of permitting should be transparent, with independent advisory reviews. One important contribution to transparency is the development of a comprehensive Environmental Impact Statement for any proposed uranium mining and processing facility.
At a more specific level, this report contains best-practice guidelines that encompass a diverse range of issues that would need to be addressed during planning for any uranium mining and processing project:
• A number of detailed specific best-practice documents (e.g., guidelines produced by the World Nuclear Association, International Atomic Energy Agency, and International Radiation Protection Association) exist that describe accepted international best practices for uranium mining and processing projects. Although these documents are by their nature generic, they provide a basis from which specific requirements for any uranium mining and processing projects in Virginia could be developed.
• Some of the worker and public health risks could be mitigated or better controlled if uranium mining, processing, and reclamation are all conducted according to best practices, which at a minimum for workers would include the use of personal dosimetry—including for radon decay products—and a national radiation dose registry for radiation- and radon-related hazards. NIOSH-recommended exposure limits for radon, diesel gas and particulates, occupational noise, and silica hazards represent minimal best practices for worker protection.
• A well-designed and executed monitoring plan, available to the public, is essential for gauging performance, determining and demonstrating compliance, triggering corrective actions, fostering transparency, and enhancing site-specific understanding. The monitoring strategy, encompassing baseline monitoring, operational monitoring, and decommissioning and postclosure monitoring, should be subject to annual updates and independent reviews to incorporate new knowledge or enhanced understanding gained from analysis of the monitoring data.
• Because the impacts of uranium mining and processing projects are, by their nature, localized, modern best practice is for project implementation and operations, whenever possible, to provide benefits and opportunities to the local region and local communities.
• Regulatory programs are inherently reactive, and as a result the standards contained in regulatory programs represent only a starting point for establishing a protective and proactive program for protecting worker and public health, environmental resources, and ecosystems. The concept of ALARA3 (as low as is reasonably achievable) is one way of enhancing regulatory standards.
The committee’s charge was to provide information and advice to the Virginia legislature as it weighs the factors involved in deciding whether to allow uranium mining. This report describes a range of potential issues that could arise if the moratorium on uranium mining were to be lifted, as well as providing information about best practices—applicable over the full uranium extraction life cycle—that are available to mitigate these potential issues.
If the Commonwealth of Virginia rescinds the existing moratorium on uranium mining, there are steep hurdles to be surmounted before mining and/or processing could be established within a regulatory environment that is appropriately protective of the health and safety of workers, the public, and the environment. There is only limited experience with modern underground and open-pit uranium mining and processing practices in the wider United States, and no such experience in Virginia. At the same time, there exist internationally accepted best practices, founded on principles of openness, transparency, and public involvement in oversight and decision making, that could provide a starting point for the Commonwealth of Virginia were it to decide that the moratorium should be lifted. After extensive scientific and technical briefings, substantial public input,
3ALARA (an acronym for “as low as is reasonably achievable”) is defined as “means making every reasonable effort to maintain exposures to radiation as far below the dose limits … as is practical consistent with the purpose for which the licensed activity is undertaken, taking into account the state of technology, the economics of improvements in relation to state of technology, the economics of improvements in relation to benefits to the public health and safety, and other societal and socioeconomic considerations, and in relation to utilization of nuclear energy and licensed materials in the public interest” (10 CFR § 20.1003).