Regulations DO NOT contain waste, they tell us how much we would be contaminated. Radiation would leak. “Best Management Practices” is legalized contamination.
After close analysis of Exhibit G titled “Engineering Design Best Management Practices Report” in the October 12, 2012, Uranium Mining Final Report we have arrived at the inescapable conclusion that the suggested policies, procedures, and standards for a regulatory framework for mining uranium and storing tailings are arbitrary, capricious, and unacceptable for the following reasons. FULL ANALYSIS
(1) They would legally authorize exposing workers and the environment to doses of radiation “ as low as reasonably achievable,” (ALARA standard) even though safe levels of exposures to many constituents listed are unknown and highly speculative.
(2) The fundamental prediction of waste management — namely, that containment structures can be engineered to prevent contamination — continues to be tested and proven false.
(3) “Best Practices” encapsulation engineering design and components for storing tailings described in Section G are similar to the failed engineering design and failed components for modern landfills.
(4) There are no standards that indicate the number of groundwater monitoring wells that must be installed, so monitoring often fails to detect groundwater contamination because the contaminated plumes often flow between the wells and are therefore not detected before contamination becomes widespread.
(5) Because of the inevitable failure of containment structures, the site boundary and exclusion area would need to be perpetually expanded so airborne contamination would be in compliance with regulations if the airborne effluent release could not be contained at the source
(6)There is an incentive to set the permissible maximum containment levels quite high in the regulations to ensure that contamination is in regulatory compliance and that the company’s license to operate continues, and to ensure the legal protection of principal parties responsible for contamination instead of protection of the environment, health, and natural resources.
(7) The waters run through both Virginia and North Carolina. Both states therefore must have sovereignty concerning the waters and must agree on any plan that would introduce toxic, hazardous, or radioactive waste facilities near the headwaters that supply drinking water for hundreds of thousands of people in North Carolina and Virginia, and eventually the city of Raleigh in times of severe drought.
(8) T0 promote uranium mining would be to endorse the delusional theoretical science of waste management, which, judging from the arbitrary and capricious suggested standards, policies, and procedures informing its regulatory framework, has become an ideology to be promoted and defended for vested interests, instead of a theoretical science needing to be challenged in light of the continuous failure of its fundamental prediction that containment structures can be engineered to keep waste from contaminating the environment.
This promotion of uranium mining is a model of economic development that is neither environmentally, democratically, nor economically sustainable.
“Best practices” cannot meet criteria that would preserve and defend Virginia, North Carolina, and this region of the South and beyond from pervasive radioactive contamination. Therefore, reasonable people, having read the Final Report would see lifting the ban on uranium mining as an arbitrary and capricious declaration of radioactive aggression and would do whatever is necessary to defend their lives and lands from uranium mining. (This is a summary, for the full report read more.)