To: Northern Arizona Proposed Withdrawal Project
ATTN: Scott Florence
Bureau of Land Managment

From: Nancy Freeman
Groundwater Awareness League, Inc.
P. O. Box 934
Green Valley, AZ 85622

Date: April 4, 2011

To assist in viewing tables this report can be viewed on website link:
www.mining-law-reform.info/GrandCanyon.htm

Dear Friends,

First, I want to commend you on the fine job you have done in collecting data and information to support a proposal to withdraw the Grand Canyon region from uranium mining in its entirely as laid out in Proposal B. My comments cannot begin to measure to the copious work you have done. However, I live in an area where uranium was mined and yellow cake was processed for approximately 20 years, from 1964 to 1983, at the Anaconda Twin Buttes facility in Sahuarita, Arizona.

At the present time, radionuclides are in the groundwater and seeping toward our public water supplies in Sahuarita and Green Valley. In fact, they are present at the mid-way point between the mine property and the town. Further, there are also numerous toxic chemicals in the soil and groundwater on the mine premises. The levels were deemed high enough that in 2008, EPA was considering it for the CERCLA list. However, the mining company wanted to complete a Voluntary Program, under the oversight of ADEQ, so that clean-up and data collection is in progress.

So in major part, I am furnishing you real-time, down-to-earth facts and figures that I have collected over the past eight years in an effort to obtain clean water in my community. Further, I would hope that no one will have to spend eight years of their life taking on a challenge to have clean water to drink.

General Environment

So most of my comments will be regarding the local situation, but, first, with the “a picture is worth a thousand words” framework, let’s take a look at the reality of what is being considered for our public lands in a region of recreation and wildlife:

Ambrosia Lake Mill, New Mexico

Since the Grand Canyon is a special place designated for human recreation and wildlife habitat, it needs to maintain a healthy environment to be accessible to the public. The citizens of the United States are the owner of the property. BLM and the Forest Service provide stewardship of those lands for the public. Therefore, the dividing up and fencing of the property would be contrary to the goals of the public trust. All mining, including uranium mining, requires fences, barriers and toxic chemical warnings. I do not feel that these barriers are appropriate for special public places, such as the Grand Canyon. The following two examples are from the Mt. Taylor uranium mine near Grants, New Mexico.

Environmental Contamination

The U. S. Environmental Agency (EPA) has published a recent (2008) report that uranium mining renders the region unfit for human—and therefore wildlife—use, even for recreational use.

Most abandoned uranium mines are likely to have elevated radium and uranium concentrations, and possibly elevated levels of other contaminants such as arsenic. An analysis of the location of uranium mine records indicates that many are on federal lands, so a primary exposure scenario pertains to short-term recreational activities, including short-term occupation.

Source: Technical Report on Technologically Enhanced Naturally Occurring Radioactive Materials from Uranium Mining, Volume 2: Investigation of Potential Health, Geographic, And Environmental Issues of Abandoned Uranium Mines
U.S. Environmental Protection Agency; Office of Radiation and Indoor Air
Radiation Protection Division (6608J)
1200 Pennsylvania Avenue; Washington , DC 20460
202-564-4355
www.epa.gov/radiation/docs/tenorm/402-r-08-005-volii/402-r-08-005-v2.pdf
Page 7-1

This entire report contains data of the contamination of the environment, including water, and the health risks caused by uranium mining. The information it contains should be given priority when considering where to place a uranium mine. As shown in the following map furnished by EPA, there are many sites for uranium, so it is not necessary to destroy a special place for the sake of uranium.

Specific contaminants: Dust

As is well known, dust has been an issue at the Grand Canyon, causing limited visibility. To allay the effects, the Navajo Generating plant was required to install more efficient burners at a cost of $47 million and catalectic reduction units are now being installed at a cost of $400 million.

Dust from mining operations is an on-going concern for the health of the environment. The principal cause of dust complaints is dust from the tailings impoundments. In the mining region where I live, dust from the impoundments is a continual problem. Scott Porter, Pima County DEQ, stated in a recent public meeting that the department receives approximately 50 complaints a year, usually when the wind reaches 25 mph.

 

ASARCO Mission Mine Impoundment, Sahuarita , AZ

Source: Scott Porter
Air Quality Compliance Division
Pima County Department of Environmental Quality
Tucson, Arizona
520/243-7383

In comparing the wind rates in Grand Canyon and Tucson International Airport, it is noted that they are very similar. Therefore, it could be surmised that there would be a similar scenario on any mining site at the Grand Canyon.

Climate Historical Summaries
http://www.wrcc.dri.edu/Climsum.html
________________________________________
Climatological Data Summaries (LCD)
(Temperature, Sunshine, Sky Cover, Station Pressure, Humidity, Precipitation and Wind.)
Summaries based on unedited daily ASOS data.

Grand Canyon Wind:
WIND-MPH-Avg. |        Jan    Feb    Mar    Apr    May    Jun    Jul    Aug    Sep    Oct     Nov    Dec | Year 1996-2008
|
Daily Avg Wind Speed|   6.0     6.5    6.5      7.9     7.3     7.4     5.2    4.7     5.7     5.9      5.5     5.8  | 6.2
Daily Avg Max 2-Min   16.8   18.4   19.5   22.7   22.3   22.9   19.7   18.6   19.6   18.4   17.3   16.7  | 19.4
Daily Avg Peak Gust |   21.3   23.7   25.4   29.7   29.6   30.7   26.2   24.4   25.9   24.2   22.0   21.6  | 25.4
| |
Maximum Daily Avg |   19.4   21.5   19.6   22.2   23.4   19.1   12.5   12.2   19.6   21.8   18.5    23.5  | 23.5

Max. 2-Minute Avg |    44      46      41      45       41      44      35      33      37      46      40       44    | 46

http://www.wrcc.dri.edu/summary/gcn.az.html

Tucson Airport Wind:
WIND-MPH-Avg. |      Jan    Feb    Mar    Apr    May    Jun     Jul      Aug    Sep    Oct    Nov  Dec  | Year 1996-2008
| |
Daily Avg Wind Speed|  6.6    7.0     7.5      8.0     7.8      7.8    7.4     7.0       7.3     7.3      6.8     6.5  |  7.3
Daily Avg Max 2-Min |16.6   17.4   18.5   19.8   19.3    20.3   22.4    21.2    18.9   17.9     16.6   17.0 | 18.8
Daily Avg Peak Gust |  21.4   22.4   23.8   25.7   25.1    26.5   28.3    27.1    24.1   23.2     21.6   21.9 | 24.3
| |
Maximum Daily Avg |   22.5   18.5   20.9  17.2   17.4    15.5   13.4    22.4   17.3    22.9     20.2   19.1 | 22.9
| |
Max. 2-Minute Avg|      36      37      40      39      35      48      55       48      44       38        35       36  | 55

http://www.wrcc.dri.edu/summary/tus.az.html

There are other sources of dust, particularly the crushing areas, dirt roads, that would also be augmented by wind speed.

Crushing operations, Morenci , AZ

Road dust at ASARCO Ray Mine, AZ

It is important to recognize that the Arizona Department of Environmental Quality is a regulatory agency that accesses fines for non-compliance to the air quality permits. The permits effectively set levels that the company is allowed to pollute. ADEQ can not and does not stop air quality problems. Do we want more dust in the Grand Canyon region? More importantly, do we want dust that is laced with uranium and its components in the Grand Canyon region?

Water

The major contaminant in this mining region has been the water. Even though uranium was mined in this region, there is no requirements from EPA or ADEQ that water monitoring near the mines or in the impoundments for uranium and its components. The very little data available, I obtained from the local mining company, but they were very clear: “we do not have to test for uranium and radioactive components.”

The following link gives tables for the few monitor wells that were tested:
www.savethesantacruzaquifer.info/Radionuclides.htm

At the two monitor wells near the mill area, the levels of gross alpha averaged from 50 to 150 pc/l and from 600 to 1,000 in the second one. The levels in the wells off site are within the allowable rates, but they are moving toward Green Valley and Sahuarita.