Violations at Nebraska mine?

EDGEMONT — Powertech’s Dewey Burdock in situ uranium mine Project Manager Mark Hollenbeck recently told the editorial board of the Black Hills Pioneer that one of the more frustrating aspects of his company’s hotly-contested state-level application hearings for the proposed mine in the Southern Black Hills is the presentation of incorrect assertions of fact by the project’s opponents. He specifically noted the opposition’s repeated touting that the Crow Butte in situ uranium mine operating outside of Crawford, Neb. has been issued dozens of U.S. Nuclear Regulatory Commission (NRC) violations. Hollenbeck maintains that the actual number is two, while the others are monitor well excursions, which are not classified as violations. But several hours of research on the NRC’s publically accessible online databases yield a different number entirely: Eight.

These violations are noted in the NRC’s conjoined Inspection Reports and Notices of Violation, which are filed on the commission’s Agencywide Documents Access and Management System (ADAMS) database. Powertech is not affiliated with the Crow Butte mine.

The first notice of violation the NRC has on file for the Crow Butte mine was issued in September of 1999, after the NRC discovered that Crow Butte ran its yellowcake uranium drying and packing operation out of NRC specifications for eight months. The NRC’s standard operating procedures state that when a yellowcake dryer emission control system fails to operate in spec the “the drying and packing room shall be immediately closed-in as an airborne radiation area,” and “heating and operations shall be switched to cool down or operations shall be temporarily suspended.” This was amended to the NRC’s satisfaction at the end of that eight-month period, but still received a violation.

Crow Butte Resources received two license violations in October 2007. The first was for the company’s failure to collect groundwater samples from several of its wastewater evaporation ponds in the third and fourth quarters of 2006. The company chose to report this issue itself after it discovered an employee marked these wells off the sampling list before they’d been sampled. Crow Butte Resources compared samples of those wells from the first quarter of 2007 to the last samples collected in 2006 and found “no adverse trends.” Even so, the company was issued a non-cited violation.

The second violation reported in the NRC’s October 2007 Crow Butte Resources Inspection Report was also self-identified: the shipment of “byproduct material” without performing the required container survey indicating radiation and contamination levels and notification to the environmental health and safety department in September of that year. This violated not only NRC requirements, but those of the Department of Transportation as well. Crow Butte maintained that the “actual safety significance was low because the survey results of all other containers met DOT requirements.” Regardless, the company received another non-cited NRC violation.

An NRC document from August 2008 shows that Crow Butte Resources received a non-cited violation for missing several required 5-year mechanical integrity tests on its injection and production wells due to corruption of the company’s mechanical integrity test database. Additionally, the NRC’s on-site inspection of the Crow Butte Facility that subsequently produced the report in question included a review of spill records for the prior year — 21 spills occurred in total in that time period, resulting in a total of 10,574 gallons of “unrecovered fluids,” 1,463 gallons of which was “production fluid.” That’s an admittedly small amount of total liquids spilled in comparison to some of the other spills that occurred over the years at the Crow Butte in situ uranium mine.  

In early January 1993, for example, the Ferret Exploration Company of Crawford, Neb. spilled approximately 23,000 gallons of injection fluid containing radium 226 on the ground, out of a failed injection trunkline in a future Crow Butte ISR uranium production well field. The spill moved out of the well ring, down a small drainage, and into a floodplain adjacent to nearby Squaw Creek. According to a January 1993 Ferret Exploration letter to the NRC, an “undetermined amount of spill water entered the Squaw Creek drainage.” The letter says the spill came into contact with then-frozen Squaw Creek and moved downstream atop the ice for about a quarter mile. Analysis of the injection water in use that day revealed radium 226 levels of 1,550 picocuries per liter (pCi/L), more than 300 times the EPA’s established combined radium 226/radium 228 drinking water maximum contaminate limit (MCL) of 5 pCi/L. Analysis of a spill water sample taken at what Ferret Exploration officials considered the “northernmost extent of the spill” showed radium 226 levels of 0.2 pCi/L. The letter states: “The action of the warm injection water melting and co-mingling with existing snow and ice apparently caused significant dilution of the spill water.”

On June 29, 1999 Crow Butte Resources discovered a 140,941-gallon spill of injection fluid. An employee determined that the spill began five days earlier when an injection well was put into operation before its construction was verified complete. According to a September 1999 NRC inspection report, Crow Butte estimated that the spill released 605 million pCi of radium 226 and 1.09 million pCi of natural uranium into the soil, adding up to an average soil contamination concentration of 214 pCi per gram, spread over 138-square-feet of the well field area. The report says Crow Butte Resources recovered less than 100 gallons of the spilled injection fluid, as most of it had absorbed into the ground. Once the spill was discovered Crow Butte Resources informed the NRC via telephone and pursued recovery and cleanup by the book.

The very same NRC inspection report shows that Crow Butte officials spilled 7-cubic-feet of “contaminated stripped ion exchange resin” on May 9, 1999. The contaminated resin spilled in the main plant building’s restricted area, but migrated to the unrestricted area and the ground outside the building. This contaminated resin was estimated to contain 1.48 million pCi of uranium per cubic foot. The report asserts Crow Butte staff utilized appropriate NRC cleanup criteria and completed cleanup on May 19, gathering some 12-cubic-feet of contaminated dirt, which they placed in 55-gallon drums. Crow Butte’s post-spill soil sample results indicated the maximum residual radioactivity in the soil at 4.5 pCi per gram above the previously measured background of 1.6 pCi per gram.

None of the document’s related to the January 1993 spill, May 1999 spill, or the June 1999 spill on the ADAMS database say anything about whether NRC violations were issued.

But we’re still four violations short. Three of those appear in an August 2010 NRC Inspection Report. One of these violations pertained to the failure of the company to meet requirements that state at least one health physics technician with a total of 12 weeks of specialized radiation health protection training under their belt be on staff. At the time, Crow Butte Resources staff included two health physics technicians with 6.6 weeks and 9.4 weeks of training completed, respectively.

Another violation noted in this report was attributed to the company’s self-identified failure to perform NRC-required mechanical integrity tests on two injection wells that were taken out of service for a little more than a month and then put back into operation. When Crow Butte officials discovered this they immediately performed the required tests on those wells, both of which passed the tests. But the damage was already done and the company received one more non-cited NRC violation. The report also illustrates that Crow Butte Resources utilized “erroneous time factors” in the calculation of occupational doses of the radioactive decay products of radon (or “radon progeny”) to mine employees due to an accidental deletion of several of these factors from a spreadsheet, “which resulted in incorrect radon progeny exposure results for hundreds of samples.” This error was not corrected for several months. Crow Butte estimated that the corrected radon progeny exposure calculation would be “less than an additional 10 percent of the currently reported total dose.” The document does not appear to divulge whether the recalculated exposures were over limit. The NRC issued Crow Butte another non-cited violation for the calculation flub.

Crow Butte’s most contemporary license violation is reported in a July 2013 Inspection Report. The company was cited for failing to maintain doses of radiation in an unrestricted area to the required “less than 0.02 miliSievert (2 millirem) in any one hour.” The report states that an NRC inspector observed a does of 0.04 milliSievert (4 millirem) per hour in an unrestricted area next to the company’s restoration building. This is Crow Butte Resources’ eighth and latest NRC violation listed on the government agency’s ADAMS database.

While some of these violations may seem harmless, they could produce serious health, safety, and environmental issues if left unchecked and un-remediated. And the potential effects of some of the others require no further explanation.

The Crow Butte in situ uranium mine is owned and operated by the Canadian uranium mining company Cameco Resources and has been in production since 1991.

Look for further in-depth examinations into currently-operating in situ uranium mines in the U.S. in the Black Hills Pioneer in weeks to come.

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