HomeMy WebLinkAbout20083213.tiff Date: 10 November 2008
To: Our Weld County Commissioners
Re: Weld County Comprehensive Plan—Need for Buffer Zones Around Uranium Mining Facilities
As a twenty year resident of western Weld County,I respectfully request that you consider the establishment of adequate
buffer zones surrounding uranium mining facilities.
I consider myself"pro nuclear,"it representing a partial solution to our national energy independence and carbon reduction
needs.I have worked as a consultant to the Nuclear Regulatory Commission and several major nuclear power producers.And
while I believe nuclear generation Is inherently safe,I would never condone establishing such a facility in Island Grove Park
The same for a more hazardous part of the nuclear fuel cycle—mining.It is an activity best kept as far as possible from
population centers.
It is critical the Commissioners consider the potential hazard of windborne contaminated dust and particular matter.While
understandably the major concerns for potential environmental threats has focused on sub-surface water contamination,we
wish to call to your attention the possibilities for airborne contamination from facilities engaged in surface mining or processes
which would transfer to the surface contaminated coring materials as part of the in situ leaching drilling processes.
Attached are graphics which help illustrate several key points:
(1) Potential uranium mining related facilities are located within 20 miles of—275,000 persons,many in Weld County.
(2) According to the Colorado Climate Center,winds in this region blow in ALL directions,but over 40%of the time
are from the North through West,potentially carrying airborne materials into populated areas of Weld County.
(3) Strong winds are a reality in this region.On average,days with wind gusts above 50 mph occur more than twice
monthly in the region currently under consideration for active uranium mining.
(4) Wind blown material from processes which expose or transport radionuclide or heavy metal laden soils to the
surface could easily result in the transport of fugitive dust onto adjacent properties,and even onto highly populated
areas further downwind during high wind conditions.The very nature of open pit mining is the continual
disturbance of soil,creating ideal conditions for fugitive dust emissions and offsite transport.
(5) Besides strong downslope wind storms,other meteorological processes(tornadoes,dust devils,microbursta)can loft
and redistribute vast amounts of loose soil over many square miles.
(6) Analytical tools for quantifying the impact of fugitive dust emissions from such sources are crude.It is unknown if
the State of Colorado even has the technical expertise,or could make the appropriate measurements,to properly
quantify offsite transport of fugitive dust in extreme wind conditions.It is not certain that any required
meteorological monitoring will evaluate the strong wind gusts capable of lofting particulate materials into the
atmosphere.
(7) Considerable high definition video exists which clearly documents that dust lotted from local farming activities,
road traffic and other activities which expose disturbed soil to the elements can be transported for many miles from
their point of origin.
(8) Weld County properties downwind of mining activities could be impacted by fugitive dust contaminated with heavy
metals and radionuclides with(half)lifetimes of hundreds of thousands of years-essentially forever.
(9) Even if the resultant concentrations were eventually shown to be"minor,"the public perception of a contaminated
region could have devastating impacts on property values,recreation potentials and the ability to retain and attract
Industries(especially"green"ones)to the region.Just think Rocky Flats.
I will be happy to provide additional information or comments related to my field of expertise pertinent to this matter upon
request.Thank you for your careful consideration.
Respectfully submitted,
Walter A.Lyons,PhD.
Certified Consulting Meteorologist
Past President,American Meteorological Society
President,National Council of Industrial Meteorologists
FMA Research,Inc.
46050 Weld County Road 13
Fort Collins,CO 80524
970.568-7664
mdb om@'IYli.com
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AIRBORNE TRANSPORT OF FUGITIVE DUST AND AEROSOLS
How Windy Is It Here? Wind gusts recorded near ground level (6 feet) in western
Weld County reveal:
Number of times wind gusts equaled or
exceeded a given speed during a 27 month
monitoringperiod (fastest 78 mph)
75 MPH 4 times
70 MPH 6 times
Boundary far non-attainment of
Omone air Quabty standards (EPA) 65 MPH 11 times
60 MPH 23 times
.them tneter Site 55 MPH 34 times
50 MPH 69 times
> 275,000 residents lice 7 "i . •
downwind within 20 miles - _
of areas with known = . rio':Aitm
uranium deposits - ca[u_v
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Source: Colorado Climate Center
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AIRBORNE TRANSPORT OF FUGITIVE DUST AND AEROSOLS
There are many mechanisms which can inject dust and particles into the atmosphere allowing transport for
many miles, even without strong regional winds . My disturbed soil containing radioactive and heavy metal
elements could be easily transported substantial distances. Such windblown fugitive dust was one of the
main concerns about offsite contamination in the Rocky Flats clean up effort.
Weld County has,in some Dins Iltil(Il)t, Dust clouds kicked up from
Torlilnadoes years,had more small the surface during
tornadoes than any county downslope and bora
in the US. Contaminated windstorms in spring and
soil particles lifted from winter can reach far
the surface can he downwind.—scattered over many
square miles. sirempt
!MsDry qlk ur st i from Grass Fl Contaminated soil settling
thunderstorms occur many _ - onto grasses and bushes
WWI
— times each summer with can be re-suspended by
opmmoi gusts >40-50 MPH. Loose grass fires and travel many
soil can be lofted and miles before returning to
_ carried for many miles the surface.
downwind.
Dust Devils Quite common on hot, Heavy transport vehicles on
summer days. These dry,dirt roads can re-suspend
whirlwinds can vacuum large amounts of potentially
large amounts of soil into
the atmosphere for contaminated soil allowing it
dispersal over many square to drift onto adjacent
farmland and beyond. Some
mikes.
of the Brown Cloud consists of
such road dust.
Hello