Project Title: Uranium Mine Closure ROD Compliance Assessment
Client: Department of Interior, Bureau of Indian Affairs & Pueblo of Laguna
Pueblo of Laguna Jackpile-Paguate Uranium Mine Record of Decision Compliance Assessment - OA Systems Corporation was contracted to the Pueblo of Laguna for the confirmation of compliance with the Record of Decision (ROD) for the closure of the Jackpile-Paguate Uranium Mine.
The scope of this task project was to confirm that the requirements of the ROD were completed. There were five general classes of work that the ROD calls out to be performed: physical deconstruction, ground and surface water monitoring, radiological monitoring, revegetation, and miscellaneous monitoring. The miscellaneous data included meteorological sampling, air particulate sampling, soil sampling, salt build-up, subsidence, erosion, and site controls to restrict grazing.
The deconstruction and reclamation activities included demolishing, moving, restructuring or otherwise modifying past mining operational features to promote safe conditions, reclaim areas or generally render the site more environmentally sound. These features include: pit bottoms, highwalls, waste dumps, protore stockpiles, streams and drainage blockages, buildings, roadways, railroad spurs, water wells, drill holes, vent holes, adits and declines.
OAS used the Final Environmental Impact Statement (FEIS) to identify the specific features referenced in the ROD to compile a comprehensive list of areas requiring documentation of reclamation activities. In addition, OAS used topographic and construction maps to identify the mining features covered by the ROD and to identify the appropriate areas for later aerial photography review and field ground-truthing. Aerial photography was also used to assist in documenting larger undertakings such as building demolition, roadway tear out, and stockpile and waste dump removals. OAS also used monthly progress reports and contract work unit close out reports that determined the field activities that took place.
Generally, the field and laboratory data collected had not been interpreted or summarized; it was raw field or lab data. OAS reviewed the available data and identified data gaps with respect to the ROD requirements. Some of the types of data OAS used were: transport volumes, backfill volumes, trenching or boring logs, water chemistry, soil chemistry, radioactive readings, etc. OAS reviewed randomly selected portions of the existing laboratory QC reports in order to check the consistency of the laboratory methods and procedures.
OAS developed a database (in doQuments™) that assisted in the documentation process. In addition to the organization of typical laboratory and field data, the database allowed for linking supporting information in varied formats (electronic data tables, PDF files of closure reports & monthly progress reports, maps, photos, drilling logs, well closure report, etc.) to specific closure requirements in the ROD. Additionally, the database was used to generate summary reports identifying parameters that exceed the criteria specified in the ROD. Licensed copies of the software and several copies of the database were provided to the Pueblo of Laguna. At project completion, OAS had compiled, reviewed and assessed over 15 years of construction and monitoring data for compliance with a Tribal, BIA and Bureau of Land Management (BLM) agreement regarding the closure of what was once the worlds’ largest uranium mine. A database of technical documents and 100-page report of the findings were prepared for the Tribe.
Third Party Review of Mine Closure Plans on Lands Adjacent the Laguna Pueblo - OAS provided third part critical review and comment on behalf of the Laguna Pueblo for the document entitled “Existing Mine Permit Application, Closeout Plan, and Site Assessment – JJ No. 1/L-Bar Mine, Cibola County, New Mexico, May 2006” and the Closeout Plan and supporting documentation to address final site closure requirements at the St. Anthony Mine, Cibola County, New Mexico. The mines are located adjacent and up-gradient of the Pueblo of Laguna.