STAY THE COURSE - KEEP THE BAN!

This is to clarify some misconceptions about the National Academy of Sciences (NAS) study of uranium mining currently underway.

Firt, the NAS study is simply not designed to provide the depth of information that needed to determine whether mining can be done safely in Virginia. This is not a reflection on the NAS National Research Council or on the qualifications of the panel members. The scope of the NAS study calls for secondary research, a review of the literature and experiences with mining elsewhere. The statement of work reflects the dual constraints of budget and timing, i.e., completion in time for the 2012 session of the Virginia General Assembly.

Without the more costly primary research, i.e., longer-term studies of actual sites where mining could occur in Virginia, key questions related to risks of mining, tailings waste storage and groundwater impacts in Virginia 's climate and hydrology will remain unanswered when the NAS study committee completes its work. For example, for mining risk assessment, an understanding of groundwater impacts by definition requires a site specific study.

Secondly, intensive study of the site appears to be needed to answer basic questions. According to Dr. Sinha of Virginia Tech, a state of equilibrium characterizes part of the Coles Hill site (where rocks, ore and water are moving in a closed system without migration to ground and surface water). Dr. Sinha stated that no one knows what will happen when the overburden is removed. He indicated that a robust study of several years would be needed to model changes, such as migration of water through the strata, etc. if the current state of equilibrium is altered.

Third, a substantive study of uranium tailings risks and containment cell monitoring and maintenance is not expressly included in the NAS study scope of work. Tailings are mentioned only in the context of identifying best management practices in recent decades and are not mentioned along with the examination of other phases of uranium mining, milling, processing and reclamation in the statement of task.

Several geologists have emphasized that while mining, milling, processing and reclamation in Virginia raise questions, it is the tailings, the most enduring phase of the uranium mining lifecycle, that are most problematic: the very long-term storage and monitoring of enormous quantities of wastes containing radionuclides, chemicals and heavy metals. The responsibility for these wastes will ultimately pass to the taxpayer after the mining company shuts down -- with risks and costs to be passed along to future generations of Virginians.

Due to the decay chain, tailings wastes become more dangerous over time, according to international experts. There is concern regarding the lack of a track record with these materials and with the containment cells in Virginia 's climate and hydrology. Information needed to adequately assess risk is not available. Virginia Uranium Inc. in a letter to the City of Virginia Beach stated that VUI does not have information on tailings requested by the City. As we know, the City of Virginia Beach is attempting to assess the risks of upstream uranium mining operations and waste storage on downstream drinking water supplies. The City is, first and foremost, looking at the hazards of tailings storage in a region that is subject to heavy storms and flooding.

Virginia Uranium Inc. does not have answers to basic questions related to water - quantity needed; source of water; quantity, quality of wastewater; treatment, discharge of wastewater. With the NAS study scope as written, these most basic of questions will likely remain unanswered.

There is no study underway that will provide by 2012 the information needed to determine whether uranium mining can be done in the Commonwealth of Virginia in a manner that safeguards Virginia 's people and environment.

With recent events in Japan , assumptions related to risk assessment and safety are called into question. The market for the product is changing. Even China , the growth market for uranium, is, according to reports, taking a closer look at its plans for nuclear expansion.

The conservative stance is to support keeping the ban - to stay the course, given what we know -- and, more importantly, don't know.