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Summary
I
n the 1970s and 1980s, exploration for uranium deposits in the Common-
wealth 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 indepen-
dent, 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, encom-
passing 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
1
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2 URANIUM MINING IN VIRGINIA
practices for uranium mining, processing, and reclamation that might be appli -
cable within the Commonwealth of Virginia; and the potential impact of ura-
nium 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 com -
ponent, 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 meet -
ings included time set aside for public comment. This included two evening ses -
sions 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 brief-
ings 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 head -
ings 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 assess-
ment of both the potential site and its surrounding area (including natural, histori-
cal, 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 fore-
cast, the risks and hazards associated with extreme natural events would need to
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3
SUMMARY
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 geologi-
cal and geotechnical characteristics of a uranium deposit—its mineralogy and rock
type, as well as a range of other factors. Additional factors that require consider-
ation 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 socio-
economic 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 engi-
neering planning that would include pit and rock stability considerations, as well
1 The 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.
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4 URANIUM MINING IN VIRGINIA
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 occupa -
tional 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.
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SUMMARY
• 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., floods, fire, earth -
quakes) 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 out -
lasting the current U.S. regulations for oversight of processing facility tailings.
• Radionuclides are not the only uranium mining- and processing- ssociated
a
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 antici -
pated 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.
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6 URANIUM MINING IN VIRGINIA
• A number of other exposures associated with uranium mining or pro-
cessing, 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 ura-
nium 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 poten-
tial 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 estab -
lished to provide early warning of contaminant migration, and the efforts to
mitigate and control potential impacts. If uranium mining, processing, and recla -
mation 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 facili-
ties 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 esti-
mating 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.
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7
SUMMARY
• 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 informa -
tion-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 regulat-
ing 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 experi -
ence attempting to remediate contamination due to past, inappropriate practices
at closed or abandoned sites.
• Under the current regulatory structure, opportunities for meaningful ublic
p
involvement are fragmented and limited.
BEST PRACTICES
At a high level, there are three overarching best-practice concepts, consistent
with practices that are recognized and applied by the international uranium min -
ing and processing community:
• Development of a uranium mining and processing facility has planning,
construction, production, closure, and long-term stewardship phases, and best
2 Conventional 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.
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8 URANIUM MINING IN VIRGINIA
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 exper-
tise and experience of professionals familiar with internationally accepted best
practices, to form an integrated and cross-disciplinary collaboration that encom -
passes 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 per-
mitting 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 plan-
ning for any uranium mining and processing project:
• A number of detailed specific best-practice documents (e.g., guide-
lines 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.
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SUMMARY
• 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, oper-
ational 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 establish -
ing 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.
CONCLUSION
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 ura-
nium mining, there are steep hurdles to be surmounted before mining and/or
processing could be established within a regulatory environment that is appropri -
ately protective of the health and safety of workers, the public, and the environ-
ment. 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 involve -
ment 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,
3 ALARA (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 socioeco -
nomic considerations, and in relation to utilization of nuclear energy and licensed materials in the
public interest” (10 CFR § 20.1003).
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10 URANIUM MINING IN VIRGINIA
reviewing numerous documents, and extensive deliberations, the committee is
convinced that the adoption and rigorous implementation of such practices would
be necessary if uranium mining, processing, and reclamation were to be under-
taken in the Commonwealth of Virginia.