The Wyoming Mining Association (WMA) is an industry association representing mining companies, contractors, vendors, suppliers and consultants in the State of Wyoming. Among its mining industry members are uranium recovery licensees, including conventional and in-situ uranium recovery operators, several companies planning new uranium recovery operations and several companies conducting final reclamation/groundwater restoration operations. Wyoming accounts for between 30 and 40 percent of the total uranium concentrate production in the United States.
In their recent ProPublica article, “The Cold War Legacy Lurking in U.S. Groundwater” (December 3, 2022), the authors mislead readers with a broad misrepresentation of the American uranium recovery industry and effects of uranium exposure. The article is filled with errors, misrepresentations and blatant falsehoods regarding uranium and the American uranium recovery industry, some egregious. WMA seeks to correct these and give ProPublica readers actual facts backed by scientific studies rather than unfounded provocative speculation.
One of the more striking stories told in the article discusses an event involving livestock deaths. “Such was the case near Griffin, North Dakota, where six cows and 2500 sheep died in 1973; their bodies emitted a blue glow in the morning light”, and that “Thousands of sheep turned blue and died after foraging on land tainted by processing sites in North Dakota.” The implication of “a blue glow” is that, in some fashion, radioactive material was involved in the deaths of these animals. It is not possible at a uranium recovery facility to concentrate radioactive elements to the extent that exposure or ingestion would result in a blue glow being emitted from an animal carcass. This is a blatant falsehood. And while the authors initially imply that uranium was the likely cause of those animals’ deaths, the article later states, “The flock is believed to have been poisoned by land contaminated with high levels of molybdenum.” If the cause of death was believed to be molybdenum poisoning, the article should have stated that outright and not engaged in deliberate exaggeration.
To better understand how the molybdenum poisoning of the animals most likely occurred, it is helpful to think first about how minerals are distributed in the ground by nature. Very few potential mining sites for ores have sharply limited ore bodies. This happens in nature because the deposition of materials in the ground most often shows a great deal of blending of the ore materials with the adjacent rock material at the edges of the deposits. It is rare that geologists find nearly pure concentrations of some element or compound in the deposit. This means that while contamination of land by mining can occur, it is far more common for areas that the public may think contaminated (by mining activities) to actually contain natural deposits which possess elevated levels of minerals in both the ground and the groundwater in an area. It is indeed common for minerals to occur in elevated concentrations in the areas surrounding a location where commercially economic deposits of the mineral occur. Oftentimes it is the size or scale of a deposit, and not the mineral concentration itself, that precludes the deposit from being economic to recover.
Uranium and cancer
The article repeatedly attempts to link uranium to cancer. “And cancer wards across the West swelled with sick uranium workers.” A 2004 study from the National Institute of Occupational Safety and Health (NIOSH) of uranium mill workers and subsequent report entitled “Mortality among a cohort of uranium mill workers: an update” states that, “Mortality from all causes was less than expected, which is largely accounted for by fewer deaths from heart disease than expected. Mortality from all malignant neoplasms (cancers) was also less than expected. Cancer rates among uranium mill workers were less than expected, not more.
The article continues by stating: “Reports by government agencies found high concentrations of cancer near a mill in Utah and elevated cancer risks from mill waste in New Mexico that can persist until cleanup is complete. Residents near those sites and others have seen so many cases of cancer and thyroid disease that they believe the mills and waste piles are to blame, although epidemiological studies to prove such a link have rarely been done.” In fact, epidemiological studies have been done and prove the opposite.
Multiple peer reviewed papers by Dr. John Boice, et. al. of Vanderbilt University on cancers as related to uranium mining conclude that cancers that might possibly be increased following high exposures to uranium and its decay products, (i.e., cancers of the lung, bone, kidney and liver) were not elevated, nor was leukemia, a sensitive indicator of excessive exposure to external gamma radiation. Boyce’s research shows there is no evidence that of an increased risk of miners dying of cancer or other diseases because of environmental exposures associated with uranium and vanadium milling and mining activities.
The article states that, “Tom Hanrahan grew up near uranium mills in Colorado and New Mexico and watched three of his three brothers contract cancer. He believes his siblings were “casualties” of the war effort.” Uranium mills process uranium ore and generally produce a uranium oxide product called yellowcake or in some cases a uranium/ammonia product called ammonium diuranate, sometimes called greencake. In either case the uranium component is natural uranium and the actual cause of the cancers is therefore not likely to be directly or indirectly associated with the uranium mills. Indeed, natural uranium that was processed in the uranium mills is not a listed carcinogen.
The U.S. Department of Health and Human Services, Agency for Toxic Substances and Disease Registry publishes a comprehensive document called the “Toxicological Profile for Uranium.” This 526 page resource is easily available and is an excellent source for well documented studies, as are a large number of Toxicological Profiles for other substances. Toxicological Profiles provide a thorough review of a substance for which public or scientific concern exists that the public and/or the American work force might be exposed to potentially (but not necessarily) dangerous chemicals.
While the Toxicological Profile for Uranium is mostly highly technical, the Center for Disease Control (CDC) has written a clear, readable discussion for ordinary people of the known toxicity of uranium. The document states that, “Neither the National Toxicology Program (NTP), International Agency for Research for Cancer (IARC), nor the EPA have classified natural uranium or depleted uranium with respect to carcinogenicity.” What this means is that there is no risk of cancer death by exposure to natural or depleted uranium.
While uranium does have a small level of chemical toxicity to the kidneys, which presents as mildly increased protein in the urine, secretion into the urine of the protein stops after the source of uranium (which can be from private wells that penetrate an undetected natural mineral deposit) is removed. This may involve switching to a public water supply which is monitored for potential contaminants.
The Toxicological Profile for Uranium categorically states that, “No health effects, other than kidney damage, have been consistently found in humans after inhaling or ingesting uranium compounds or in soldiers with uranium metal fragments in their bodies.” It further states that, “Neither the National Toxicology Program (NTP), International Agency for Research on Cancer (IARC), nor the EPA have classified natural uranium or depleted uranium with respect to carcinogenicity.” Natural uranium that was processed in uranium mills is not a listed carcinogen.
The ProPublica article states, “When a uranium mill shuts down, here is what’s supposed to happen: The company demolishes the buildings, decontaminates the surrounding soil and water, and encases the waste to stop it from leaking cancer-causing pollution. Leaking of “cancer-causing pollution” implies that a contaminant, most likely uranium (it is a uranium mill after all) in a liquid (water) can cause cancer. The most severe case of internal uranium exposure occurs when uranium is embedded inside an individual’s body and cannot be removed. This has indeed occurred in other contexts and therefore, the actual effects can be known.
The U.S. Department of Veterans’ Affairs published a paper entitled the “U.S. Department of Veterans’ Affairs Depleted Uranium Exposed Cohort At 25 Years: Longitudinal Surveillance Results” that discussed the medical monitoring of a cohort of veterans that had uranium metal embedded in their bodies that could not be surgically removed. This is a worst case for uranium exposure for a human being.
The paper concluded that “Now, more than 25 years since first exposure to DU, an aging cohort of military veterans continues to show no U-related health effects in known target organs of U toxicity. The results of an extensive health assessment have also shown no other clinically significant health effects as a function of U burden.”
Risks from the nuclear fuel cycle, including in-situ uranium recovery, are in general very low. This issue is discussed in the paper entitled Five-Hundred Life-Saving Interventions and Their Cost-Effectiveness. This paper evaluates various risks including risks from radiation in terms of the cost of the intervention in terms of dollars per year of life saved. The costs of interventions related to the nuclear fuel cycle are among the highest cost (lowest risk) interventions described in the paper. The following two (2) interventions pertain to Nuclear Regulatory Commission (NRC) licensed facilities and uranium fuel cycle facilities that include uranium recovery facilities:
881 Radionuclide emission control at NRC-licensed and non-DOD facilitates – $2,600,000,000
881 Radionuclide emission control at uranium fuel cycle facilities – $34,000,000,000
The costs of interventions in these areas exceed $1 billion per year of life saved.
These risks are also discussed in the SENES Consultants, Limited document entitled “A Citizen’s Guide to Uranium Mining” which states that, “Possible health effects in populations living close to uranium mines and mills also have been well studied. No additional effects have been observed when compared to the health status of similar populations not living nearby a uranium mine or mill.”
A paper entitled “Grand Rounds: Nephrotoxicity in a Young Child Exposed to Uranium from Contaminated Well Water” from the journal Environmental Health Perspectives discusses the case of a three year old girl exposed to uranium that occurred naturally in the water from her family’s water well. Three months after ceasing consumption of the water from the well, the child’s urine beta‐2‐microglobulin excretion rate had dropped to slightly above the upper range of normal at 52 micrograms beta‐2‐microglobulin per millimole creatinine and the child showed no lasting ill effects. This paper again shows the low risk posed by uranium to human beings.
The paper entitled “Acute Chemical Toxicity of Uranium” by Ronald L. Kathren and Richard K. Burklin makes the following conclusions regarding uranium toxicity: “However, there has never been a death attributable to uranium poisoning in humans, and humans seem to be less sensitive to both acute and chronic toxic effects of uranium than other mammalian species studied. Highly relevant data on uranium toxicity in humans are available from the experience of persons administered large doses of uranium for therapy of diabetes and from acute accidental inhalation intakes.” It further states that, “It is highly significant to note that there have been no reports of deaths in humans following acute or chronic intakes of uranium by whatever route of entry during mankind’s more than two centuries of experience with uranium (ATSDR 1999), and humans as a species seem to have a lower order of sensitivity to the toxic effects of uranium than the other mammalian species that have been studied. Since at least the late nineteenth century until after the discovery of insulin by Canadians Frederick Banting and Charles Best and their coworkers in 1921–1922, uranium was used therapeutically in the treatment of diabetes mellitus. This paper also highlights the low risks posed by uranium to human beings.
PUBLIC HEALTH ASSESSMENT Monticello Mill Tailings Site (MMTS) and Monticello Vicinity Properties (MVP) Monticello, San Juan County, Utah
The ProPublica article links to a document entitled “PUBLIC HEALTH ASSESSMENT Monticello Mill Tailings Site (MMTS) and Monticello Vicinity Properties (MVP) Monticello, San Juan County, Utah” as prepared by the Utah Department of Health. Regarding this document, article states, “Reports by government agencies found high concentrations of cancer near a mill in Utah…” In stating this, the authors fail to provide full context in that the assessment actually concludes that, “Following thorough review of the environmental pathway exposure data, the EEP finds that one intermittent surface seep (seep 6) requires continued investigation to adequately determine the potential health effects (if any) of this seep. The EEP further finds that the remediation efforts and institutional controls in place at the MMTS and MVP have effectively addressed all other pathways of contaminant exposure and that contaminants that were associated with the former mill site are not expected to harm people’s health.”
The assessment also discusses the cancer issue stating that, “the EEP conducted a review of cancer-related mortality data in San Juan County from 1974 through 2006 using additional data available since the original PHA (Public Health Assessment) This report found increasing mortality over time due to lung and breast cancers; however, the development of these cancers is not known to be directly related to exposures to the types of contaminants found at the mill or surrounding site.” The authors’ apparent “cherry picking” of information in the assessment to support their claims seems contrary to ProPublica’s Code of Ethics guidelines to present facts accurately and fairly.
Relocation of uranium mill tailings
The ProPublica article supports the relocation of uranium mill tailings in the discussion of the Lakeview Mining Company site in Southern Oregon. The article states that, “There’s no way in hell we’re going to leave this stuff here,” Dixon, the nuclear cleanup specialist, remembered thinking. He represented the state of Oregon at the former mill, which was one of the first sites to relocate its waste to a specially engineered disposal cell.”
The removal and relocations of uranium mill tailings are often more hazardous that leaving them in place. For example, the Vitro Site materials in Salt Lake City, Utah was moved to Clive, Utah and tailings in Grand Junction and Durango, Colorado were moved out of their urban settings as well. Actions like these should be risk based and cost effective. The decision to move the Atlas Mill tailings away from the Colorado River and Moab, Utah to Crescent Junction was not risk-based or cost informed, but rather political. The relocation started in 2008 and is on-going with a probable completion date of 2030. The cost exceeded one billion dollars long ago. This project expended dollars, energy, and time while exposing workers and the public to risks, specifically those related to the excavation and transportation of the material.
Tailings removal (extraction) and relocation (transportation and material moving) operations create risks for workers involved in those activities. The United States Department of Labor (USDOL) Occupational Safety and Health Administration (OSHA) states:
“4,764 workers died on the job in 2020 (3.4 per 100,000 full-time equivalent workers). Workers in transportation and material moving occupations and construction and extraction occupations accounted for nearly half of all fatal occupational injuries (47.4 percent), representing 1,282 and 976 workplace deaths, respectively.” Source: Commonly Used Statistics – https://www.osha.gov/data/commonstats
These excavation and relocation projects expose workers to risks that are not justified by the lower risks posed by properly reclaiming and leaving the materials in place.
Alternate Concentration Limits (ACLs)
The ProPublica article refers to Alternate Concentration Limits (ACLs) calling them “exemptions.” “Often, companies or agencies tasked with cleanup are unable to meet water quality standards, so they request exemptions to bypass them. The NRC or state agencies almost always approve these requests, allowing contaminants like uranium and selenium to be left in the groundwater.”
ACLs are not exemptions to the law or to regulations. They are an integral part of the regulatory process. They are codified in 10 CFR Part 40 Appendix A Criterion 5(B) which states, “Alternate concentration limits that present no significant hazard may be proposed by licensees for Commission consideration. Licensees must provide the basis for any proposed limits including consideration of practicable corrective actions, that limits are as low as reasonably achievable, and information on the factors the Commission must consider. The Commission will establish a site-specific alternate concentration limit for a hazardous constituent as provided in paragraph 5B(5) of this criterion if it finds that the proposed limit is as low as reasonably achievable, after considering practicable corrective actions, and that the constituent will not pose a substantial present or potential hazard to human health or the environment as long as the alternate concentration limit is not exceeded.”
The provision for ACLs recognizes that there should be a risk-informed cost-benefit analysis performed for all sites, particularly for legacy sites that are the focus of this article. In addition, reclaimed Title II sites that contain reclaimed tailings impoundments and associated groundwater plumes must be maintained and monitored in perpetuity by a government body which in all cases to date has been the Department of Energy. 10 CFR Part 40 Appendix A requires that the company (site licensee) pre-fund this perpetual care. Claims that mining companies are somehow not meeting their obligations are false.
Background concentrations of natural uranium natural, uranium decay products and related elements in ground water
Uranium is ubiquitous in nature as are other elements associated with it including selenium, vanadium, molybdenum, bismuth and arsenic. Background concentrations of uranium and the elements associated with it can vary widely.
The uranium recovery industry has through its exploration activities identified areas of groundwater unfit for use in the United States either because the natural uranium exceeds the Agency’s drinking water standard of 30 micrograms per liter, the combined Radium-226/228 standard of 5.0 pCi/l or because the radon of the water is sufficiently elevated that use of such water in a household would release significant amounts of radon into the home’s interior.
An example of such an area identified by uranium exploration activities is documented in: Geology of the Lost Creek schroeckingerite deposits, Sweetwater County, Wyoming, USGS Bulletin 1087-J By: Douglas M. Sheridan, Charles Henry Maxwell, and John T. Collier. This document identified shallow groundwater containing naturally occurring uranium at concentrations up to 46 milligrams per liter. Wells in the Great Divide Basin in Sweetwater County, Wyoming (a known uraniferous area) are known to contain dissolved uranium in excess of public water supply standards. Two (2) are listed in Water Resources of Sweetwater County, Wyoming Scientific Investigations Report 2004-5214 By Jon P. Mason and Kirk A. Miller (a U.S. Geological Survey report – on pages 124 and 159 as follows:
The first listed well is in Holocene alluvium while the second is in the Battle Spring Formation. These two (2) wells either approach or exceed 0.25 parts per million uranium.
Background concentrations of natural uranium natural uranium decay products and related elements in soils
As alluded to earlier, uranium and its decay products are ubiquitous in soils around uranium deposits as are other elements associated with it including selenium, vanadium, molybdenum, bismuth and arsenic. Just because uranium, its decay products or other associated elements are present in elevated concentrations around a uranium recovery site does not mean that are necessarily anthropogenic contamination. They may well be part of natural background. For example, the previously referenced report also provides trench sampling data showing elevated naturally occurring concentrations of uranium in the area. This is but one such example of elevated concentrations of uranium that are naturally occurring.
Naturally occurring concentrations of uranium, uranium decay products and associated elements should not be confused with anthropogenic contamination.
Uranium recovery’s impact on groundwater
The low risk to groundwater is well documented by the NRC itself in its report entitled “DATA ON GROUNDWATER IMPACTS AT THE EXISTING ISR FACILITIES – NRC-075.” The report states that, “Based on a review of historical licensing documentation, data from the regional monitoring at all existing ISR facilities indicate that no impacts attributable to an ISR facility were observed at the regional monitoring locations. In addition, the staff is unaware of any situation indicating that: (1) the quality of groundwater at a nearby water supply well has been degraded; (2) the use of a water supply well has been discontinued; or, (3) a well has been relocated because of environmental impacts attributed to an ISR facility.
This document was prepared because the Commission directed the NRC staff to provide it with the data it had in hand that assessed environmental impacts to the groundwater from previously licensed ISR facilities. The Staff Requirements Memorandum (SRM) was issued following a December 11, 2008, NRC briefing on the status of uranium recovery facilities during which the staff briefed the Commissioners on the status of uranium recovery applications, ISR facilities generic environmental impact statement (GEIS), rulemaking for groundwater protection at ISR facilities, and Native American outreach.
The state of Texas reached a similar conclusion when the Texas Commission on Environmental Quality, which has regulated in-situ uranium recovery for over three decades, noted in May 24, 2012, comments to the Nuclear Regulatory Commission that, “there has not been one instance of documented off-site pollution of a USDW from in situ uranium mining activities.” Additionally, the Texas Railroad Commission, which has regulated Texas uranium exploration projects for over four decades, also noted in an April 6, 2015, letter to the Environmental Protection Agency that, “we are not aware of a single example of groundwater contamination from in situ uranium recovery operations.” Both documents discuss the lack of harm to groundwater from uranium in-situ mining.
“NUREG-1910 – Generic Environmental Impact Statement for In-Situ Leach Uranium Milling Facilities” confirms the low risk involved in in-situ uranium recovery facilities. This document indicates the majority of potential impacts are “small,” and explains that all groundwater in an ISR uranium recovery zone is exempted from consideration as a source of drinking water by the EPA because it is unsuitable for human consumption as a drinking water source both before and after uranium recovery operations occur. The document describes the groundwater restoration that is required to protect adjacent non-exempt waters and explains that in ISR mining, non-toxic leaching agents, such as oxygen with sodium carbonate, are injected through wells into the ore body to dissolve the uranium.
Regarding the use of passive restoration (natural flushing), a paper entitled “Determination of Contaminant Levels and Remediation Efficacy In Groundwater at a Former In-Situ Recovery Uranium Mine” by Thomas Borch, Nicholas Roche and Thomas E. Johnson of Colorado State University concludes that, “The very low concentrations of target species (U, Ra) at the two monitoring wells indicate that natural attenuation is likely to play a major role at immobilizing residual (after remediation) concentrations of U(VI) species thus preventing them from moving outside the mined area. There is a potential for natural attenuation in this system, since the conditions were originally reduced (low redox potential) especially if sulfate reducing conditions can be re-established. Undisturbed soil outside the mining area is also conducive to precipitation, complexation and immobilization of uranium due to the existing reducing conditions.”
Conclusions
The “legacy” sites described by the authors are no different than any other industrial operations from 50 or 100 years ago. As we have gained experience, particularly with radioactive and chemical substances, we have significantly improved health and environmental protections. The author’s assumption that that all of the health issues are due to one bad actor (uranium) is neither true nor scientific. Current operating and regulatory standards for uranium recovery in the United States recognize a wide range of hazards and are designed to protect the workers and the public. The risks from natural uranium and modern uranium recovery are in fact very low. The authors make no attempt to acknowledge this fact, thereby leaving readers (intentionally or not) without a complete picture.
In failing to present all the facts, the article leaves ProPublica readers with a deliberately skewed picture of American uranium mining. This is regrettable, as the domestic uranium recovery industry plays a vital role not only in America’s clean energy portfolio, but in national efforts to address global climate change and lower carbon dioxide emission.
ProPublica’s Code of Ethics notes an essential prerequisite in its business is to tell the truth. Unfortunately, this article falls short of that. It is our hope that you consider the above to present an accurate account for your readers.
Travis Deti is the Executive Director of the Wyoming Mining Association
Dr. Nancy Standler M.D.,(University of Pittsburgh), PhD, (University of Rochester’s Department of Radiation Biology and Biophysics), is a practicing board certified pathologist who has contributed to this article
References
Mortality among a cohort of uranium mill workers: an update
Boice: A cohort study of uranium millers and miners of Grants, New Mexico, 1979–2005
Toxicological Profile for Uranium
Five-Hundred Life-Saving Interventions and Their Cost-Effectiveness
A Citizen’s Guide to Uranium Mining
Grand Rounds: Nephrotoxicity in a Young Child Exposed to Uranium from Contaminated Well Water
Acute Chemical Toxicity Of Uranium
Geology of the Lost Creek schroeckingerite deposits, Sweetwater County, Wyoming
Water Resources of Sweetwater County, Wyoming Scientific Investigations Report 2004-5214
Data On Groundwater Impacts At The Existing ISR Facilities – NRC-075
NRC Staff Requirements Memorandum dated January 8, 2009, SRM M081211
NUREG-1910 – Generic Environmental Impact Statement for In-Situ Leach Uranium Milling Facilities
