completed an exhaustive, line-by-line critical analysis of the U.S. Geological
Survey's Scientific Investigations Report 2010-5025 released February 24,
2010. His remarks, comments, corrections and suggestions about the
Page 5, paragraph 2 -- the two-year period is a "segregation", not a "withdrawal". Climate section -- "microclimates" are ubiquitous/common everywhere on earth and not just common to northern Arizona.
Page 8, last paragraph -- what about the primary hydrologic feature of the Redwall-Muav aquifer?
Page 9, paragraph 2, that springs are "...a critical water source for..". This needs to be substantiated or better qualified, as it is clearly not so in the regional sense for most of the biota inhabiting the area because most of the segregated area is extremely remote from the few springs and creeks in the region.
Page 9, second to last sentence of paragraph 2 is so imprecise as to be meaningless.
Page 9, column 2, last sentence. This is a scientifically incorrect statement. There is no geochemical doubt that the country rock outside of breccia pipes has (volumetrically) the greatest potential for remobilization of radiochemical elements in the subsurface.
Page 10, column 1, last paragraph, second sentence. This is a tautological statement of the biological kind.
Page 12, column 1, paragraph 3, sentence 2. Thickness of sedimentary rock cover is definitely not the only control of depth to mineralization in breccia pipes.
Page 12, column 1, paragraph 4, sentence 1. Not all barren breccia pipes are barren because of 'ore dissipation'. Some were never mineralized to begin with.
Page 13, column 2, paragraph 2, sentence 3. This is an untrue statement, and the following sentence 4 is misleading to the new reader. Mineralized pipes and their intact contents only 'weather' rapidly when exposed to oxygen-rich water. This happens only with exposure by erosion, in rare geological cases where more than normal amounts of groundwater are funnelled through subsurface breccia, or when ore is removed from pipes by mining. Because milled ore is much more valuable than stockpiled ore, the occurrence of stockpiled ore left at the surface and exposed to weathering conditions is extremely rare.
Page 14, column 1, acknowledgments. Funding support was not provided by the BLM and USGS leaders, but by the American taxpayers. (Remember the federal government is an open system.)
Page 23, column 1, paragraph 2 of abstract. Use of the 12% figure against the context of the "total" seems disingenuous and unfortunately strongly suggests a bias on the part of the writer or editor. The last sentence of the paragraph would have been sufficient for the purposes of the EIS analysts.
Page 23, column 2, paragraph 2, sentence 2. The phrase "a few of which contain uranium mineralization" is untrue and critically misleading. Numerous (many more than "few") pipes contain mineralization, a portion of which contain economic quantities of mineralization. Apparent bias on the part of writer or editor emerges again.
Page 28, last sentence continuing to page 29. This relationship is not dependable, despite the representations provided in the report. Witness the Hermit Mine, Pinenut, and Arizona-1 cases.
Page 31, column 2, sentence 1. An inaccurate statement. Quaterra has reportedly conducted VTEM survey over 85 square miles, but does not necessarily own the mineral rights to the whole surveyed area.
Page 31, column 2, last sentence of paragraph 2. An early instance of the result of the USGS not talking to all companies working in the area -- there at least 4 more drill-tested mineralized breccia pipes in the Tusayan Ranger District.
Page 32, column 2, last sentence of paragraph 3: An egregious error in statement of geological fact for an organization called the "United States Geological Survey" to make -- see Red Butte in the KNF for one example of volcanic rocks and younger sedimentary rocks within the segregation area.
Page 34, column 2, last sentence, and continued to page 35: This inaccurate statement with regard to the KNF does not take into account that, thus far, average ore grades and median ore body sizes in drill-explored breccia pipes south of the Grand Canyon are consistently greater than those discovered on the north side of the Canyon.
Page 36, column 1, first sentence is an inaccurate statement of US mining law regarding timing of mining claim validity exams during a segregation period -- and practically speaking, given the time required to process so many claims, it would also be an impossible undertaking.
Page 36, 'Conclusions'. The writing in this section makes up manfully for all the wriggling and dodging apparently going on in page 23.
Page 50, column 2, sentence 3. Nice early statement of multiple possible causes.
Page 50, column 2, introduction, paragraph 1, sentence 2. Reading the rest of this chapter of the report, this sentence is a false statement inasmuch as the Hacks Canyon work of the report indicates the workers neglected consideration of the effects of pre-1980s breccia pipe mining work at Hacks 1.
Page 54-56, 'Soils over Grand Canyon pipes': This section of the report fails to take into account the very large difference in depths to mineralization among mineralized pipes. See the attached figure. Primary mineralizing system metal lithogeochemical values are diluted by distance from source. For example, outcrop on the west side of the Pigeon pipe shows cap sulfides extend to current surface at Pigeon, which fact has strongly raised the local soil and rock geochemical background there. Comparing the soil chemistry of very deeply buried mineralized pipes like those south of the Grand Canyon (SBF and Canyon) to those of very shallow mineralized pipes like Pigeon is consequently invalid for the purposes of estimating post-drilling or post-mining surface impacts and anticipating pre-mining activity soil geochemical values.
Page 64, column 1, paragraph 1, sentence 2, and 'n' on Figure 7, page 65. I recall that this 'poorly revegetated' area is the location of limited naturally outcropping sulfide cap at Pigeon Mine. If this recollection is correct, it is understandable that revegetation efforts have yielded poor results in this location.
Page 66-77, Figure 9 sample analyses for reclaimed Pigeon pipe mining area (pipe surface projection per se) -- would probably have been useful to have provided contour maps of the pipe area sample data in order to better see if there is any correlation with the wind direction rose diagram referenced later on page 103. (Would have also been helpful if this rose diagram was reprinted in the report.) Note generally that speculations in text describing apparent surface contamination by wind at Pigeon and Kanab North could still be easily tested by conducting repeat chemical analyses on different particle size pulps from the soil samples already collected.
Page 104-110, Figures 14 and 15. Ditto the above comments for Kanab North.
Page 110, column 2, paragraph 2, sentence 3. This interpretive difficulty would have been lessened if the USGS had made provisions to sample the soils over known mineralized but undisturbed breccia pipes in the adjoining Game Preserve. Assuming regional controls of mineralization depth, easterly Game Preserve mineralized pipes proximal to the Kanab South, Kanab North, Pigeon, etc., would very likely be appropriate orientation study sites for pre-mining cases.
Page 116-119, Hacks Mines. It is unfortunate no work was conducted to determine volume of mine-related waste remaining in Hacks Canyon. Reporting concentration of trace metals in samples of waste found in the canyon without accompanying estimates of volume of such rock is not very useful for any purpose except needlessly alarming the public. This same comment goes for the Kanab North, Kanab South, Pigeon, and Hermit type cases as well. Also, given the extreme weathering and rounding of much of the mine waste material shown in the Hacks Canyon photos of the report, it appears probable that an appreciable portion of the waste material observed by the USGS in Hacks Canyon is derived from pre-Energy Fuels mining operations at the Hacks 1 breccia pipe. See Figure 27. The strong iron oxide staining of terrace gravel matrix suggests the dissected gravels are 1) relatively old (possibly pre-1980s), and 2) relatively radioactive due to cumulative uranium daughter product absorption against the gravel matrix iron oxides. Refer to the attached graphic from OFR 88-0648 by Chenoweth that shows waste and ore material from the original Hacks mine was indeed directly deposited on the canyon bottom by pre-Energy Fuels Hacks 1 mine operators.
Page 119-129, 'Leaching of Waste Materials': It was extremely gratifying to see that the USGS experimental uranium-leaching data obtained the same magnitude of values that DIR used in its modeling of the effects of exploration drilling water on Redwall-Muav groundwaters in its draft Environmental Assessment provided to the Kaibab National Forest a year ago. Note especially the amount of natural uranium 'contamination 'derived from the Orphan breccia pipe orebody calculated by DIR on the basis of annual groundwater recharge and observed Horn Creek average water uranium concentrations are in line with USGS leaching data, which indicates that historical mining of the Orphan pipe has had no augmentative effect on.
Page 129, Summary, sentence 1. The data provided by the USGS are wholly insufficient to justify the statement made in sentence 1, due to lack of waste rock/contaminated soil volumetric data. Concentration values of samples are almost completely meaningless without accompanying waste volume data. Estimates can be made about possible magnitudes of contamination by making assumptions of waste or contaminant volumes, but these estimates are not here provided by the USGS. Rather than utter the red herring statement made, then, the USGS would have been more scientifically correct to be silent on the "legacy of contamination" until at least some estimates of contamination impact have been calculated by making a range of reasonable contaminant volume assumptions.
Page 130, column 1, sentence 2: Hypothesis confusedly stated as fact. Previous text and following sentence admits that wind dispersal may not have been source for Pigeon Mine contamination but instead reflect the metal content of the soil parent material. Until further work has been completed to test the wind dispersal hypothesis, it is more scientific to be less definite about the potential role of wind dispersal at mines in the segregation area.
Page 130, column 1, paragraph 4, sentence 1. This statement unexplainedly ignores the historical small miner operations at Hacks 1 before Energy Fuels worked in the 'Hacks Mine Complex' and therefore unjustifiably ascribes blame for current presence of mine waste to EFN's activities there in the 1980s.
Page 130, column 2, 'Future Studies'. This list is largely an institutional mea culpa -- the need for these added data dimensions was forseeable. Note that item #8 of this 'we forgot to' list can now be realistically estimated by EIS risk analysts, given the geochemical data provided in the present report.
Page 143, column 2, paragraph 2, last sentence. The writer forgot to accurately qualify this statement with a final phrase to the effect, "...at harmlessly low concentrations due to dilution".
Page 147, Figure 4, is corrected in an attachment (see yellow arrows) to show that the Muav-Redwall aquifer groundwater north of the Grand Canyon flows west towards the Uinkaret Plateau, away from the Colorado River -- and not ESE towards Kanab Creek and the Colorado River as indicated in the original USGS Figure 4. This correction is based on contouring of Redwall-Muav poemtiometric water table elevations from the Pinenut, Hermit Mine, Hack Mine, and Pigeon Mine water wells.
Page 153, column 2, 'Water Chemistry', sentence 3 of the first paragraph of this section states, "Uranium mining of breccia pipes in northern Arizona through 1969 left waste rock and low-grade ore exposed at the surface, allowing subsequent remobilization of minerals and radio-nuclides and contamination of both surface water and groundwater systems in the region." This statement shows the writer or editor briefly mistaking hypothesis for reality. One of the major purposes of the current two-year segregation period is to determine whether or not such possible remobilization and contamination has occurred. Given the low precipitation rates, low aquifer recharge rates, and volumetrically small amounts of the waste rock and low-grade ore involved, there is very little probability that such remobilization has occurred so as to create significant contamination. Indeed, a recent study conducted on that 'primary hydrologic feature' of the region, the Colorado River, shows no such contamination has occurred. See attachment EWG2232009. (Elsewhere in this section of the USGS report, the authors or editor repeatedly 'own up' to the uncertainty regarding locally high trace metal concentrations in water samples and the 'legacy of mining'.)
Page 184, column 2, sentence 6: These listed researchers have hypothesized a link between mining activity at the Orphan Mine and in Horn Creek, but have not yet demonstrated a causal link. For example, waters in Horn Creek have an average age far exceeding the age of mining activity conducted at this breccia pipe, which fact strongly decreases the probability that there is a causal relationship between historical uranium mining activity at the Orphan Mine and trace metal values in waters of the Horn Creek drainage.
Page 193, column 1, 'Future Water-Quality Investigations', sentence 1. This is certainly true -- more work in an area always leads to better understanding. However, the data collected to date and presented in SIR 2010-5025 and related earlier USGS publications, do permit a dependable and reasonable determination of the degree of risk to surface and groundwater posed by uranium exploration and mining activities, even on the north side of the Colorado River.
Page 287 last sentence, continued on page 288: SIR 2010-5025 does not evaluate environmental impacts of uranium mining in the segregation area, and its authors have in fact largely and properly gone out of their way to not pre-judge the report observations that the EIS analysts will employ to conduct their risk assessment regarding northern Arizona uranium mining.
Page 289, last sentence of column 1: "Therefore, conventional mining creates relatively large quantities of waste materials characterized by low-level radiation, heavy metals, and other inorganic and organic materials, which are potential sources of chemical and radiation exposure to biota." This statement in the context of the problem it (and the report) is addressing shows a basic lack of understanding regarding northern Arizona breccia pipe ore quality. The ore in these pipes is anomalously rich in grade, which makes it possible to conduct conventional mining that does not create relatively large quantities of waste materials.
Chapter D, generally: This chapter and its concerns are procedurally ahead of need. The physical risk factors attached to uranium mining need to first be quantitatively and probabilistically evaluated (using, among other things, the data presented in Chapters A-C), and then compared to known or expected values of potential toxins and biota distributions and biota behaviors to see if there is apt to be any significant biological impact from uranium mining activities. Angsting about the intricate details of various biota-environmental interactions will turn out to be unnecessary if mining impacts are too insignificant to get anywhere close to damaging threshholds.