Monday, March 23, 2009

Comment: Letter about illegal uranium study, comments in RED from Ms. Maute!

Delegate Marshall,

An e-mail circulated that asked for comments. Here are mine.

Re: Uranium study...

At best, we must carry the stigma of being the only state on the east coast stupid and greedy enought to entertain the idea of uranium mining and milling. At worst, we may be only state on the east coast stupid and greedy enought to mine and mill uranium. It is obvious that the study is focusing on Pittsylvania County. There is no intent, that I can see, to study or to mine and mill statewide. The state seems determined to aid and abet Virginia Uranium in assaulting an entire region of Virginia, along with its rich history and culture, for the benefit of a few. VUI advocates will do and say anything and to disturb and excavate the deposit which lies under Coles Hill.

Karen B. Maute

URANIUM MINING IN VIRGINIA
STUDY OBJECTIVES
: TO ASSESS THE SCIENTIFIC AND TECHNICAL ASPECTS OF
URANIUM MINING, MILLING AND PROCESSING IN VIRGINIA AND ASSOCIATED
ENVIRONMENTAL, HUMAN HEALTH, SAFETY AND REGULATORY ISSUES
THE STUDY WILL REVIEW:

1. URANIUM SUPPLY/DEMAND TRENDS AND PROJECTIONS These have nothing to do with the stated study objectives
a. GLOBAL, NATIONAL AND STATE Global benefit, not necessarily a benefit to either Virginia or even the US regarding energy. Irrelevant to stated objectives.
b. SHORT-TERM AND LONG-TERM TRENDS Define? Again, nothing to do with stated objectives.
c. COSTS, PRICES AND MARKETS Irrelevant to stated objectives.
#1 Is purely economics, nothing to do with science, technology or associated environmental, human health, or safety issues.
2. WORLDWIDE URANIUM DEPOSITS AND OPERATIONS What does this mean? Until defined it is irrelevant to stated objectives.
a. DEPOSIT CHARACTERISTICS AND LOCATIONS (GEOLOGY, CLIMATE,
ETC.) Of what? Until defined it is irrelevant to stated objectives.
b. OPERATION CHARACTERISTICS Of what? Until defined it is irrelevant to stated objectives.
c. COSTS AND MARKETS Of what? Until defined it is irrelevant to stated objectives.
d. BEST PRACTICES Of what? Until defined it is irrelevant to stated objectives.
e. CURRENT ISSUES AND CONCERNS Of what? Until defined it is irrelevant to stated objectives.
#2 Is extremely ill-defined and hence, irrelevant.
3.. URANIUM DEPOSITS IN VIRGINIA
a. OCCURRENCE Are they looking any further than Pittsylvania Co.?
b. GEOLOGIC, ENVIRONMENTAL, CULTURAL, CLIMATIC, AND GEOGRAPHIC SETTINGS Where?
c. PHYSICAL AND CHEMICAL CHARACTERISTICS Of what? Until defined it is irrelevant to stated objectives.
d. STATUS OF CURRENT EXPLORATION Where? Only Pittsylvania Co. is currently being explored.
e. AVAILABLE BASELINE DATA Where? Only Pittsylvania Co. is currently being explored and has any semblance of baseline data.
f. ECONOMIC FEASIBILITY Of what?
g. COMPARISON OF POTENTIAL URANIUM OPERATIONS IN VIRGINIA WITH GLOBAL DEPOSITS AND PRACTICES
I do not see any indication that anywhere other than Pittsylvania Co. are being considered. It appears that the state is partnering with VUI to undermine the health and well-being of a specific region of Virginia.
4. URANIUM MINING, MILLING AND PROCESSING TECHNOLOGIES
a. REVIEW OF CURRENT TECHNOLOGIES AND POTENTIAL NEW TECHNOLOGIES Potential new technologies will be more experimental on the population than current existing technologies.
b. APPLICATION OF TECHNOLOGIES/PRACTICES TO VIRGINIA DEPOSITS Which deposits...again, Pittsylvania County is singled out.
c. PROBLEMS AND ISSUES With exactly what?
d. AVAILABLE INFORMATION Regarding what?
e. KNOWLEDGE GAPS AND AREAS FOR RESEARCH On what will credibility of this information be based? Looks like a funding opportunity for Virginia Tech.
THE STUDY WILL ASSESS:
5. OCCUPATIONAL AND PUBLIC HEALTH AND SAFETY
a. RADIOLOGICAL HAZARDS AND RISKS What about particulate mater and heavy metals?
b. OCCUPATIONAL HEALTH AND SAFETY CONCERNS
c. CONSIDERATIONS FOR LOCAL COMMUNITIES What considerations?
d. SHORT- AND LONG-TERM CONSIDERATIONS Of what?
Pitiful criteria for assessing impact on public health.
6. SECURITY STANDARDS AND PROCEDURES
a. HAZARDOUS MATERIALS MANAGEMENT Are you drawing a distinction between radiologic material and hazardous? Define Hazardous material.
b. PERSONNEL SECURITY
c. MATERIAL CONTROL AND ACCOUNTABILITY
d. TRANSPORTATION SECURITY
e. INFORMATION SECURITY Protecting who? VUI or public health?
f. SITE SECURITY
Security will only be needed to make sure VUI doesn't sell to a terrorist country.
7. ENVIRONMENTAL CONSIDERATIONS
a. POTENTIAL IMPACTS ON AIR AND LAND Where?
b. GROUND- AND SURFACE-WATER IMPACTS AND PROTECTION Where?
c. WATER MANAGEMENT INCLUDING NET CONSUMPTION/RECYCLING Effects on local wells? There appears to be lead contamination at present from exploratory drilling. Who is investigating this? If we can't deal with water issues during exploratation, what makes you think we can deal with effects of mining, milling and waste (tailings) management?
d. WASTE MANAGEMENT INCLUDING OVERBURDEN, WASTE ROCK AND
TAILINGS To date, management of these issues have resulted in failures of one kind or another.
e. ECOSYSTEM EFFECTS
f. OTHER ENVIRONMENTAL HEALTH ISSUES Like what?
g. RISK MODELING AND IMPACTS OF SEVERE WEATHER EFFECTS OR OTHER
STOCHASTIC EVENTS
h. NOISE, AESTHETICS, TRAFFIC AND OTHER LOCAL CONSIDERATIONS
Ah, we FINALLY get to the stated objectives. They appear to be woefully inadequately addressed.
8. CLOSURE AND POST-MINING LAND USE AND MONITORING
a. MINESITE MONITORING
b. MONITORING OF TAILINGS AND OTHER WASTES
c. MONITORING OF LOCAL GROUNDWATER AND SURFACE WATERS
d. SITE RECLAMATION
e. LONG-TERM LAND USE IMPACTS AND RESTRICTIONS
f. OFFSITE ECOLOGICAL MONITORING
g. POST-CLOSURE FINANCIAL RESPONSIBILITY AND LIABILITIES
Cookie cutter crap. Damage and devastation can only be guessed. Vui may be bankrupt and the county will have yet another superfund site at taxpayers expense.
9. REGULATORY CONSIDERATIONS AND PUBLIC OUTREACH IN VIRGINIA
a. HEALTH AND SAFETY REGULATIONS Will be inadequate and unenforcable. Staff to insure compliance will be inadequate. It was, even before the downturn in the economy.
b. ENVIRONMENTAL AND MINING LAWS AND REGULATIONS Will be inadequate and unenforcable. Staff to insure compliance will be inadequate. It was, even before the downturn in the economy.
c. INSPECTION AND ENFORCEMENT Will be inadequate and unenforcable. Staff to insure compliance will be inadequate. It was, even before the downturn in the economy.
d. COMMUNITY RIGHT-TO-KNOW AND EMERGENCY PLANNING Right to know what? That Pittsylvania Co.an experiment for the state of Virginia?
a. EDUCATION AND OUTREACH Education? Outreach? To make us docile, if not willing, participants in Virginia's experiment?
10. FINDINGS AND RECOMMENDATIONS
The study is an attempt to legitimize the mining and milling of uranium in Virginia...more specifically, in Pittsylvania County.

SOCIO-ECONOMIC IMPACTS OF URANIUM MINING IN VIRGINIA
STUDY OBJECTIVES: TO ADDRESS SITE- AND REGION-SPECIFIC SOCIAL, ECONOMIC AND
ENVIRONMENTAL IMPACTS AND SUSTAINABILITY FACTORS SUCH AS QUALITY OF LIFE,
INFRASTRUCTURE, LOCAL ECONOMIC OPPORTUNITIES AND PROPERTY AND REAL ESTATE
VALUES.
It appears that site and region specific means HERE. ..Coles Hill in Southside Virginia.
STUDY COMPONENTS:
1. SOCIAL IMPACTS
a. AESTHETICS AND OVERALL QUALITY OF LIFE ISSUES Where?
b. AVAILABILITY OF AND IMPACTS ON SOCIAL INFRASTRUCTURE
(POLICE, FIRE, ROADS, SCHOOLS, ETC.) Where?
c. EFFECTS ON LOCAL POPULATION AND COMMERCIAL ACTIVITY Where?
d. EFFECTS ON INTERNAL AND EXTERNAL IMAGE OF THE REGION Where? What region?
e. MARKETABILITY OF THE REGION FOR OTHER INDUSTRY AND
POPULATION Where? What region?
f. FEAR OF POTENTIAL HEALTH AND ENVIRONMENTAL EFFECTS Where? The facts give rise to fear. VUI, and now YOU are asked, "Show us 5 places where Uranium has been safely mined in a place similar to Virginia w/regard to climate, population, rainfall, topography, watersheds, hydrology etc.
g. SHORT- VS. LONG-TERM EFFECTS AND COMMUNITY SUSTAINABILITY These cannot be determined.
h. EDUCATATIONAL OPPORTUNITIES What the heck does that mean?
Again, Southside Virginia is the focus.
2. ECONOMIC IMPACTS
a. JOB CREATION AND LOCAL INCOME EFFECTS
b. INFRASTRUCTURE DEVELOPMENT For the uranium industry? Infrastructure for other development can not be ascertaianed since the industry may negate future economic development in other sectors.
c. EFFECTS OF CHANGES IN INCOME AND LOCAL ECONOMIC
ACTIVITY
d. TAX REVENUES OVER LIFE OF MINE AND BEYOND For whom?
e. IMPACTS ON GOVERNMENT EXPENDITURES Local and state?
f. OVERALL ECONOMIC DEVELOPMENT EFFECTS, PARALLEL AND
SUPPORT BUSINESSES ETC. for the uranium industry? Looks as though econimic diversity has been abandoned.
g. PROPERTY VALUES VS. DISTANCE FROM MINE OR PROCESSING FACILITY Nice to finally see concern for citizens and their property values. The whole region will suffer. Those of us who have bought our homes and looked at them as a safe environment and a good investment will be disappointed on both counts.
h. IMPACTS ON REAL ESTATE VALUES IN THE AREA AND ON You can bet that Coles Hill will not be on the Virginia Garden Club Tour in the future.
LOCAL COMMUNITIES Again, the whole region will suffer. Those of us who have bought our homes and looked at them as a safe environment and a good investment will be disappointed on both counts.
i. LONG-TERM ECONOMIC SUSTAINABILITY
3. ENVIRONMENTAL IMPACTS
a. INTEGRATION WITH THE TECHNICAL STUDY (I.E., NRC) What technical study?
b. ENVIRONMENTAL IMPACTS ON SOCIAL AND ECONOMIC
FACTORS What does this mean?
c. MONITORING DURING OPERATIONS/CLOSURE Taxpayer money...forever. That's if things go well, which historically, they don't.
4. FINDINGS AND RECOMMENDATIONS
The study is pro-uranium mining and milling and it's findings will reflect such.

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