Map of Radon: lots of uranium!
Please email Mary at maryo@nirs.org about the NAS Study of Uranium in Va which is paid for by the Virginia Uranium Inc who is partly own by the Canadians. The study has several members with ties with uranium mining and nuclear power, so VUI got what they paid for because the study is flawed. Email Mary now!
Today's Topics:
1. Urgent: Sign on now for objective U-mining study
(Michael Mariotte)
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URGENT! SIGN ON TO SUPPORT TRANSPARENT AND OBJECTIVE STUDY ON URANIUM MINING! DEADLINE IS TUESDAY 5 PM EASTERN TIME
August 16, 2010
Dear Friends,
Your support is needed to ensure that a National Academy of Sciences' study of URANIUM MINING in Virginia is conducted in the most transparent and objective manner. Your response is needed by COB Tuesday, August 17, 2010. REPLY to maryo@nirs.org
A study of uranium mining of this magnitude has never been undertaken before. The scope of the study is vast and complex; it includes issues from legal framework to public health and safety to mining methods to reclamation and waste management to cultural issues to geology, climate
and water management. The findings will be relied upon by the Virginia General Assembly in deciding whether to allow uranium mining in Virginia.
But it will also set precedent for the entire uranium mining industry in the United States and the rest of the world.
If Virginia allows uranium mining, it may spur exploration and mining in other states on the East Coast, as potential uranium deposits have been detected in many locations, from New Jersey all the way to Florida.
The National Academy of Sciences is currently forming the study committee and has recently released the names of the provisional committee members selected to conduct the uranium mining study. Four of the proposed committee members appear to have conflicts of interest due
to their ties with uranium mining companies. In addition, the proposed study committee lacks a number of experts needed to examine specific issues included in the scope of the study.
Please help us bring these problems with the study committee composition to the National Academy of Sciences' attention by signing the joint comments on the composition of the provisional committee, which are below.
To sign on, please send your name, organization (if one), city and state
to maryo@nirs.org
.
You can view the Statement of Task of the uranium mining study at:
http://dels.nas.edu/global/besr/Uranium
You can read the provisional committee members' bios at:
http://www8.nationalacademies.org/cp/committeeview.aspx?key=49253
Thanks for all you do,
Michael Mariotte
Executive Director
Nuclear Information and Resource Service
August 18, 2010
Dr. David Feary
Study Director
Board on Earth Sciences and Resources
Division on Earth and Life Studies
National Academy of Sciences
500 Fifth Street, NW
Washington, DC 20001
Re: The Composition of Provisional Committee for the Study of Uranium Mining in Virginia, DELS-BESR-09-06
Dear Dr. Feary:
We appreciate the opportunity to comment on the composition of the provisional study committee on uranium mining in Virginia, established to examine the scientific, technical, environmental, human health,
safety, and regulatory aspects of uranium mining, milling, and
processing as they relate to the Commonwealth of Virginia. The
committee's work is extraordinarily important, as the findings of the
study will assist the Commonwealth in determining whether uranium
mining, milling, and processing can be undertaken in a manner that
safeguards the environment, natural and historic resources, agricultural
lands, and the health and well-being of its citizens.
Proposed uranium mining has been a controversial issue in the
Commonwealth of Virginia since late 1970s when the uranium mining
deposits were first discovered. For years, this matter has been an
issue of outmost concern for the communities that may potentially be
affected by uranium mining. For these reasons, it is very important
that this uranium mining study be performed by a well-balanced and
objective panel of scientists and experts who are free of any
obligations to the entities that may either benefit or be disadvantaged
by the findings of this study.
Unfortunately, it appears that several members of the provisional
committee have conflicts of interest that could significantly impair
their objectivity and further damage the credibility of this study in
the eyes of the public. As more fully discussed below, we respectfully
request that the Board on Earth Sciences and Resources (thereafter,
BESR) conduct a review of Dr. Corby G. Anderson, Dr. Lawrence W.
Barnthouse, and Dr. Michel Cuney for a potential conflict of interest,
and remove Mr. Henry Schnell from the study committee due to an apparent
conflict of interest.
It has been widely reported in the Virginia local press that the funding
for this study is coming from Virginia Uranium, Inc., the company
seeking to lift Virginia's 1982 ban on uranium mining, and that the
Virginia Center for Coal and Energy Research at the Virginia Polytechnic
Institute and State University is serving as a mere conduit for
funneling the study funds to the National Research Council. The
Governing Board Executive Council of National Academies was apprised of
this situation in an October 2, 2010 letter signed by over 30 concerned
citizens. Because of the nature of the end source of funding, the
study's credibility is already being questioned by the public.
Under these circumstances, it is especially important that the study
process be conducted in a manner ensuring transparency and an ample
opportunity for public comment.
Accordingly, we respectfully request that the BESR extend the comment period until August 30, 2010. Pursuant to Section 15(b) of the Federal Advisory Committee Act (thereafter,FACA), the National Academy of Sciences "shall ... provide a reasonable opportunity for the public to comment on ... appointments before they are made or... in the period immediately following the appointments."
While a 20-day comment period has been the National Academies'
long-standing practice, limiting it to 20 days is not required by law.
In this particular case, given the controversial nature of the issue to
be examined in the uranium mining study, and the fact that most of
Virginia residents received either no notice or insufficient notice of
the commencement of the comment period, the BESR should extend the
public comment period until August 30, 2010 to allow all interested
parties to comment on the composition of the provisional committee.
In addition, we urge the BESR to conduct public hearings to provide an
open public forum for interested parties to participate in the study
committee discussions in accordance with Section 15(b)(3) of FACA, and
to promptly make available to the public a summary of any committee
meetings and any materials provided to the study committee in compliance
with Sections 15(b)(3)-(4). The general public should also be provided
with a sufficient notice of at least thirty (30) days prior to the date
of the public meeting and an opportunity to submit written comments on
the public committee discussions.
We believe that public meetings should be conducted so as to include all
the locations in the Commonwealth of Virginia that may potentially be
affected by uranium mining. Historically, uranium companies have shown
interest in uranium in Culpeper, Fauquier, Franklin, Floyd, Henry,
Madison, Nelson, Orange, Patrick, and Pittsylvania Counties and leased
mineral rights on approximately 50,000 acres in the 1980s. Downstream
from these areas, there are counties and municipalities whose drinking
water could be affected by uranium mill tailings. These counties
include Brunswick, Fairfax, Halifax, Mecklenburg, Virginia Beach,
Chesapeake, and others. If the uranium mining ban is lifted, we would
likely see exploration for uranium in the black shale of Southwest
Virginia, in crystalline granite throughout the Blue Ridge, and in
sedimentary rock in the Coastal Plains, as well as further exploration
in the Northern and Southern Piedmont. Conducting public meetings at
multiple locations will ensure the utmost degree of transparency of the
study process for such a controversial issue as uranium mining.
Potential Conflict of Interest
The National Academies have established policies and procedures for
addressing potential conflicts of interest to be used by committees in
the development of its reports. This policy states that "[i]t is
essential that the work of committees of the institution used in the
development of reports not be compromised by any significant conflict of
interest. For this purpose, the term "conflict of interest" means any
financial or other interest which conflicts with the service of the
individual because it (1) could significantly impair the individual's
objectivity or (2) could create an unfair competitive advantage for any
person or organization. Except for those situations in which the
institution determines that a conflict of interest is unavoidable and
promptly and publicly discloses the conflict of interest, no individual
can be appointed to serve (or continue to serve) on a committee of the
institution used in the development of reports if the individual has a
conflict of interest that is relevant to the functions to be performed."
We wish to bring the following matters of concern to the attention of
the National Academies and the BESR regarding employment, existing
fiduciary duties, consulting services, and promotional activities of Dr.
Corby G. Anderson, Dr. Lawrence W. Barnthouse, Dr. Michel Cuney, and Mr.
Henry Schnell that to the best of our knowledge have not been publicly
disclosed as potential conflicts of interest in regard to the uranium
mining study.
Dr. Corby G. Anderson currently serves as s trustee for the Northwest
Mining Association, a trade association, whose stated purpose is to
represent and inform members on legislative, regulatory and technical
issues, to support and advance the mineral resource and related
industries, and to foster and promote economic opportunity. Among the
members of the Northwest Mining Association are Denison Mines Corp., a
publicly traded company operating three uranium mines and two uranium
mills in North America, and Uranium One Inc., one of the world's largest
publicly traded uranium producers. As a trustee of this trade
association, Dr. Anderson has a fiduciary duty to the association and
its members to act in their best interests. Although the study is
designed to examine the feasibility of uranium mining in the
Commonwealth of Virginia, the outcome of this study, similar to all
studies completed by the National Academies, will set precedent for the
entire uranium mining industry here in the United States and possibly
around the world. The study findings will serve as the basis for the
Virginia General Assembly's determination of whether to lift the 28-year
ban on uranium mining. The Virginia General Assembly's action on the
uranium mining ban has a potential of impacting economic opportunities
for many uranium mining companies, including the companies that are
corporate members of the Northwest Mining Association.
In addition, to the best of our knowledge, Dr. Anderson routinely
undertakes contracted projects for global industrial client projects,
including serving as an expert witness in mining litigation. Under the
National Academies' Policy on Committee Composition and Balance and
Conflicts of Interest, a consulting relationship, such as serving as an
expert witness in litigation, constitutes a potential financial conflict
of interest.
Furthermore, Anderson also serves on the Board of Directors of Phoenix
Minerals, Inc. and is President and COO of Getty Copper Inc. Both are
publicly traded mining companies. In connection with this, we
respectfully request that BESR investigate whether any of the two
companies currently operate a uranium mine or mill and whether they
presently have plans to mine or mill uranium.
Dr. Lawrence W. Barnthouse is an owner of LWB Environmental Services,
Inc., a consulting company that provides ecological risk assessments and
risk-based environmental restoration planning. Among Dr. Barnthouse's
clients are large law firms that represent clients from all over the
country in environmental litigation and environmental regulatory
proceedings. This appears to indicate that Dr. Barthhouse serves as an
expert witness for those law firms and their companies on the issues
that are the subject matter of the uranium mining study. The National
Academies' policy on conflicts of interest provides that serving as an
expert witness is a type of consulting relationship that may constitute
a financial interest. Accordingly, we request that BESR further
investigate Dr. Barnthouse for a conflict of interest based on the
nature of the consulting services he provides to his clients. BESR's
review should address whether Dr. Barnthouse serves as an expert witness
on issues that will be examined in the uranium mining study and whether
he provides expert testimony on behalf of uranium mining companies,
regardless of whether they are his direct clients or clients of his
clients.
Dr. Michael Cuney's industry consultation includes work for major
uranium mining companies, such as Areva and Uranor Inc. The findings of
the uranium mining study will determine future economic opportunities
for Dr. Cuney's corporate clients in the Commonwealth of Virginia.
Thus, Dr. Cuney's consulting relationship with uranium mining companies
constitutes a potential conflict of interest and warrants review by
BESR.
In addition, as stated in Dr. Cuney's biography, he has visited and/or
worked on most major uranium deposits of the world. BESR should
investigate in what capacity Dr. Cuney traveled to all those mining
sites, who funded his trips and whose interests he represented during
those trips and to which companies he provided the services in
connection with the trips, and whether these companies continue to use
his services.
Furthermore, Dr. Cuney participates in numerous international
conferences. In fact, he was a speaker at the Global Uranium
International Conference held in Colorado in May 2009, where the Coles
Hill, VA deposit was discussed at length. We, therefore, request that
BESR require Dr. Cuney to disclose whether he received any honorarium or
travel expense reimbursements for his participation in these activities
and any other uranium mining conferences and who sponsored his trips to
such conferences.
Mr. Henry Schnell has an apparent conflict of interest based on his
employment. Mr. Schnell holds a senior position in the Mining Business
Unit with Areva NC Inc., a multinational company that owns and operates,
either directly or through its subsidiaries, uranium mines in many parts
of the world, including North America. Specifically, Areva's subsidiary
Pathfinder Mines Corporation operates large uranium mines in Wyoming
that are currently undergoing reclamation. As stated above, the study's
finding will set precedent for the entire uranium mining industry and
will have a potential to affect economic opportunities for many uranium
mining companies, including Mr. Schnell's employer, Areva.
In addition, we would like to bring to BESR's attention the fact that
Areva Inc. is actively involved in promoting uranium mining in Virginia.
Virginia Energy Independence Alliance (thereafter, VEIA), whose two out
of three corporate members are Areva Inc. and Virginia Uranium, Inc.,
has been very outspoken and pro-active in its campaign to support
uranium mining in the Commonwealth. The VEIA Chairman Ray Ganthner has
just retired from his position of Senior Vice President with Areva.
Most recently Mr. Ganthner appeared on behalf of VEIA at the June 22,
2010 public hearing conducted by the Virginia Coal and Energy Commission
on uranium mining and spoke publicly on behalf of VEIA in favor of
uranium mining. Because VEIA at this time has only three corporate
members, one of which is Areva Inc., it is reasonable to conclude that
when the VEIA Chairman speaks on the subject of uranium mining, it
represents Areva's views and promotes Areva's best interests.
This demonstrates that Mr. Schnell's employer Areva may directly benefit
or may be disadvantaged by the findings of the uranium mining study.
Because of his employment and his employer's particular interest in
uranium mining in Virginia, Mr. Schnell's objectivity may be
significantly comprised. Mr. Schnell's participation in this study may
create an unfair competitive advantage for Areva. Accordingly, we
request that Mr. Schnell be removed from the study committee due to his
apparent conflict of interest.
Balance of the Study Committee
Under the Statement of Task for the uranium mining study, the study
committee is called upon to examine 12 questions covering a wide range
of areas from legal framework to public health and safety to mining
methods to reclamation and waste management to cultural issues to
geology, climate and water management, etc. Despite the fact that the
scope of the uranium mining study is vast and complex, the study
committee is comprised of only 13 experts. It appears that some of the
issues included in the study will be examined by only one expert. A
committee that has only one expert per issue cannot be characterized as
balanced because the study process will fail to ensure peer review on
one or more issues. For this reason, we believe that the committee
membership must be expanded to include more experts, especially in the
areas highlighted below.
The first item of the Statement of Task directs the study committee to
"assess the potential short- and long-term occupational and public
health ... considerations ... including the potential human health
risks." Item 4 directs to "analyze the impact of uranium mining,
milling, processing, and reclamation operations on public health."
Comprehensive examination of items 1 and 4 of the Statement of Task
requires an expert in occupational and public health, as well as a
medical doctor. The provisional committee currently includes public and
occupational health experts and epidemiologists but no medical doctor.
We, therefore, request that the BESR appoint an expert with the medical
doctor degree to the study committee.
Pursuant to item 4 of the Statement of Task, the study committee is to
"analyze the impact of uranium mining, milling, processing, and
reclamation operations ... at sites with comparable .. hydrologic ...
characteristics to those found in the Commonwealth." In addition, item
9 directs the study committee to "identify the issues that may need to
be considered regarding the quality and quantity of groundwater and
surface water... As relevant, water and waste management ... may also be
considered." The potential impact of uranium mining on water supply has
been of utmost concern for the communities where uranium mines may be
developed and to the communities, like Fairfax and Halifax Counties and
the City of Virginia Beach, and all the communities in the Roanoke River
Basin including those in North Carolina whose sources of drinking water
are located in areas where uranium mining is likely to occur should the
uranium mining ban is lifted. For this reason, we respectfully request
BESR to ensure that the study committee includes a sufficient number of
experts with the expertise in hydrology and water-related issues.
Item 5 of the Statement of Task directs the study committee to "review
the ... cultural settings ... in the Commonwealth of Virginia." A
comprehensive analysis of the cultural settings requires an expertise in
environmental justice. Unfortunately, it is not apparent from the
information posted on the credentials of the provisional committee
members whether the committee includes experts in environmental justice.
Because uranium mining is likely to affect many communities with
relatively low socioeconomic status and very little influence over
legislative decisions and limited access to the legal system, it is very
important that the issue of environmental justice be examined thoroughly
in the study. To this end, the study committee should be expanded to
include at least two experts in environmental justice with experience of
addressing these issues in the communities affected by uranium mining.
We would welcome an opportunity to provide nominations for all
above-mentioned areas of expertise.
In addition, it appears that the majority of questions under the
Statement of Task require global expertise in uranium mining and broad
knowledge of world-wide trends and experiences of other U.S. states and
foreign nations with uranium mining. Unfortunately, the provisional
committee does not include experts with such level of expertise. We,
therefore, respectfully request that BESR expand the committee to
include at least four experts who have studied the effects of uranium
mining world-wide.
It is also unclear from the published bios of the provisional committee
members whether anyone of them has an expertise required for evaluating
post-mining impacts of tailings impoundments. We, therefore,
respectfully request that BESR ensure that an expert in this very
specific area is included in the committee.
Thank you very much for your time and attention. We hope that BESR will
give sufficient consideration to the concerns raised in these comments
and will ensure that this very important study proceeds in a most
transparent manner.
Sincerely,
Olga Kolotushkina, Annandale, VA
Karen B. Maute, Danville, VA
Annette G. Ayres, Summerfield, NC
Valentin Lukashuk, Fairfax, VA
Linda Worsley, Chatham, VA
Winnie Pruitt, Danville, VA
Wm. and Barbara Winn, Martinsville, VA
Andrew Lester, Keeling, VA
Sergey and Dina Lukashuk, Harrisonburg, VA
Carolyn A. Gibson, Ringgold, VA
Deborah Quinn Lovelace, Gretna, VA
Andrey and Larisa Lukashuk, Mount Solon, VA
Barbara Hudson, Chatham, VA
Terry H. Andrews, Halifax, VA
Ann M. Rogers, Boones Mill, VA
Nancy Gillespie, Roanoke, VA
Deborah Dix, Blairs, VA
Tony Dix, Blair, VA
Robert Pruitt, Danville, VA
Barbara Bass Thompson, Chatham, Virginia
Frank H. (Jesse) Andrews, Jr., Halifax, VA
Kenneth D. And Karen H. Schneider, Caswell County, NC
Phillip Lovelace, Gretna, VA
Ricky Simpson, Altavista, VA






