Comment: Uranium mining and milling will polluate the rivers, lakes, wells in Virginia. Uranium mining will happen all over VA and not just at Coles Hill! No to u mining and milling!
Endangered species-Colorado River Fish
The direct, indirect and cumulative impacts of milling and associated mining operations may impact four federally endangered fish species: the razorback sucker, the humpback chub, the bonytail chub and the Colorado pikeminnow.
All four of the endangered Colorado River fish species may be present in the Colorado River just downstream from the confluence with the Dolores. Colorado pikeminnow occurred historically in the Dolores River and still persist in the Colorado River downstream from the confluence 1 Hinck, J.E., Linder, G., Finger, S., Little, E., Tillitt, D., & Kuhne, W. (2010). Biological pathways of exposure and ecotoxicity values for uranium and associated radionuclides.
Found at: http://pubs.usgs.gov/sir/2010/5025/pdf/sir2010-5025_biology.pdf
2 International Atomic Energy Agency. (2004). The long term stabilization of uranium mill tailings—Final
report of a coordinated research project 2000–2004: International Atomic Energy Agency IAEA-TECDOC-140 (as cited in Hinck, et al.).
3 Jones, K.C., Lepp, N.W., & Obbard, J.P. (1990). Other metals and metalloids, in Alloway, B.J., ed.,
Heavy metals in soils: New York, Blackie/John Wiley & Sons, Inc., (as cited in Hinck et al.).
4 Hem, J.D. (1992). Study and interpretation of the chemical characteristics of natural water (3d ed.): U.S.
Geological Survey Water-Supply Paper 2254, (as cited in Hinck et al.).
5 Zhang, P.C. & Brady, P.V. (2002). Geochemistry of soil radionuclides: Madison, Wis., Soil Science
Society of America, (as cited in Hinck et al.).
with the Dolores River. The razorback sucker may occur in the Colorado River downstream from the confluence with the Dolores River and is stocked in the Colorado River upstream of the confluence with the Dolores River. There are relatively large and healthy populations of humpback chub in the Colorado River near the confluence with the Dolores River. One of the very few remaining wild populations of bonytail occurs in the Colorado River upstream from the confluence with the Dolores River, and since 1996 bonytail have been stocked in the Colorado River in Utah near the confluence with the Dolores River. In addition, critical habitat for all four of the endangered Colorado River fish has been designated in portions of the Colorado River downstream from the confluence of the Dolores River.
Uranium milling and associated mining operations may affect these fish species in two synergistic ways: water depletion and pollution.
Milling operations will result in the loss of 227 acre feet per year in the Colorado River Basin. Mining operations on the ULP tracts will result in consumptive use of a minimum of 140 acre feet of water per year from the Dolores and Colorado River Basins.
For example, Edge Environmental confirmed that the Dolores River has flowed at less than two cubic feet per second 14 times in the past 40 years.
Use of 141 gallons per minute from the aquifer is 15 percent of river flow at that level, enough to harm the Colorado pikeminnow, which grows up to 80 pounds, and is found in the Dolores River.6
These depletions must be considered in combination with past, present and reasonably foreseeable other actions on DOE lease tracts and BLM lands in the region that have depleted water from the Dolores and Colorado Rivers.
The direct, indirect, and cumulative effect of these depletions to the fish must be considered. Those effects may include loss of aquatic habitat, reduced quantity of river habitat, and reduced quality of habitat, especially those habitat attributes associated with minimum base and peak flows (such as spawning and backwater habitats) that may be affected by reduced water availability.
Reduced water volumes in the Dolores and Colorado Rivers will exacerbate pollution effects of uranium milling and associated by increasing the concentration of milling and mining pollutants in the river. Uranium mining and milling operations may result in discharges of pollutants that may be toxic to the fish, including uranium, selenium, ammonia, arsenic, molybdenum, aluminum, barium, copper, iron, lead, manganese,
vanadium and zinc. Selenium is an element of particular concern, as elevated selenium can be taken up directly from water by aquatic organisms, resulting in acute toxicity at relatively high concentrations, and accumulate in the aquatic food chain.7
This can result in myriad adverse effects on fish and waterfowl populations, including impaired reproduction, deformities, reduced survival and other problems.8 Selenium contamination in the Colorado River basin has been implicated in the decline of the four endangered 6 Colorado Division of Wildlife. (2010). Species profiles: Colorado Pikeminnow.
Found at:
http://wildlife.state.co.us/WildlifeSpecies/Profiles/Fish/PikeMinnow.htm
7 Hamilton, SJ. 2004. Review of selenium toxicity in the aquatic food chain. Science of the Total Environment 326: 1-31. See also Lemly AD. 1999. Selenium impacts on fish: an insidious time bomb. Human and Ecological Risk Assessment 5: 1139-1151.
8 Id. Colorado River fish species, and may be impeding their recovery.
9 There is evidence that high selenium levels may adversely affect reproduction and recruitment in these fishes.
10Treatment of high levels of selenium in Energy Fuels’ Whirlwind mine has proven elusive. Selenium has contributed to numerous violations of water quality standards and the current shut-down condition of the Whirlwind mine.
11bLM designated sensitive species of fish Colorado Division of Wildlife (DOW) states that the presence of the mill would also impact three sensitive species of fish in the Dolores River through aquifer drawdown:
bluehead sucker, flannelmouth sucker, and roundtail chub. DOW requested that water used for milling operations not be hydrologically connected to the Dolores River12, but there is a hydrological connection, as established by the loss of 227 acre feet per year from the Colorado River Basin.
Aquatic species
Hinck et al. explains that metals concentrate in sediments at the bottom of streams. In streams receiving drainage from uranium mills, aquatic species which feed on or near sediments have higher concentrations of uranium and thorium than predatory fish.13 Although the proposed mill is supposed to be a “zero containment” facility, Golder Associates explained that significant runoff will occur during spring snowmelt and high precipitation events14. Any runoff into streams from the site will harm bottom feeding fish.
Read more:
http://www.sheepmountainalliance.org/ftp/docs/wildlife_comments.pdf
