Many persons have died over the years due to radiation exposure from working in the uranium mines and mills and having been exposed to fallout from atmospheric nuclear weapons testing conducted in Nevada. Now come nuclear waste dumps. One has sprung up right under our noses at White Mesa in San Juan County. 
     It's not that many of us haven't tried to keep the mill from bringing in the hazardous Manhattan Project wastes. On several occasions, some of us in San Juan County provided written and oral statements to the Utah Radiation Control Board. White Mesa Ute leader, Norman Begay, often led his troops to Salt Lake City to object. The Ute people followed this up by marching and demonstrating at the mill itself. 
     But the perilous material keeps piling up. The dumping issue first arose in 1993 when material was received from Teledyne Wah Chang in Oregon by UMETCO Minerals. The State rightly challenged the basis of the approval about whether the material was being processed primarily for its source material content or whether it was to be stored in White Mesa's waste dump. The material was returned to Oregon without being processed although the NRC upheld the amendment request.
    After that incidence, the NRC drafted the "Guidance on Alternate Feed Materials" in 1995. This established the regulatory and policy framework for uranium mills that accepted alternate feed materials. The criteria dictated that the materials "(1) meets the definition of ore, (2) could not contain listed hazardous waste, and (3) had to be processed primarily for source material content."  These criteria have not been faithfully followed.
     In 1996, Energy Fuels and its successor, International Uranium Corporation, first requested license amendments for alternate feed materials. Materials came from Allied Signal, Cotter Concentrate, and Cameco.

     And then the flood gates opened: from the Cabot Corporation near Boyertown, Pennsylvania with its leaky containers; from Linde, New York with its 100,000 cubic yards of dangerous waste; from the Ashland 2 site at Tonawanda, New York; from the W.R. Grace Corp. site in Chattanooga, Tennessee with its 93,000 cubic yards of waste; from the Ashland 1 and Seaway sites near Tonawanda; and from the St. Louis area, with a whopping 1,000,000 cubic yards of waste. This material has minimal uranium content but a much higher volume of other assorted waste materials. 
     On July 5, 2000, an amendment request was made to receive up to 2000 cubic yards of "alternate feed material" from the Heritage Minerals Site in Lakehurst, New Jersey. A request for a hearing was filed by Sarah Fields of Moab and that case is still before the NRC.
     There may be no end in sight to the requests International Uranium might make. The State, in September 1998, raised several concerns and filed a formal administrative action regarding the Ashland 2 materials. The State alleged that these materials from Tonawanda, New York and shipped to the White Mesa mill, contained hazardous waste and that its handling and disposal could violate applicable laws and could harm humans, wildlife and natural resources, including ground and surface water.  A federal administrative judge ruled on February 9, 1999, that the complaints were unfounded.
     Whether the material was being processed primarily for the source material content was a major concern. Also questioned was whether the current tailings' impoundment liner system and the groundwater-monitoring program were appropriate to handle these new wastes. 
     State officials, in objecting to the shipments, indicated that International Uranium had received a windfall $4,050,000 to handle a material that contained no more than $600,000 worth of uranium.
     The processing of materials with minimal uranium content while the facility received a huge "recycling" fee constituted "sham disposal" the State said.  The mill had become a true "de facto" radioactive waste dump. Uranium extraction was only a pretext to dispose of the waste in the mill's waste dump. 
     On April 9, 1999, the Utah Radiation Control Board considered a rule that would require a minimum uranium contents of 0.05% for the so-called "alternate feed material" for processing in a uranium mill. The rule was tabled, and the Board seemingly wiped its hands of the matter:

     "However sympathetic or empathetic the Board may be to one or both parties, Utah is not an Agreement State with the Nuclear Regulatory Commission regarding the processing of uranium ore or the on-site disposal of byproduct material. Thus, the Board has no authority to act for either proponents or opponents of the White Mesa Mill regarding routine milling operations or the existence of the mill per se...interested parties are encouraged to address their issues to the agencies with regulatory authority."

     Where now does the State of Utah stand on the matter? The State is working to enact Agreement State status with the NRC to the regulation of uranium mills and tailings. This action would allow the State to regulate the alternate feed processing largely by itself.
     However, the environment continues to suffer. Violations are stacking up. In August 1999, chloroform levels 47 times higher than that allowed by Utah state rules, was found in a groundwater monitoring well at the White Mesa mill. On September 29, 1999, a truck that carried 20 tons of hazardous material, originating from the Ashland 1 site at Tonawanda, overturned near Cisco, Utah spilling much of its cargo.
     In March 2000, empty transportation containers exceeded contamination limits. 
     International Uranium in late February 2000 was required to send loads of imported Tonawanda waste back to Tonawanda because on inspection it was too heavy with chemicals. Some vehicles were reportedly found "externally contaminated upon arrival at Tonawanda." 
     The White Mesa mill received a shipment of hazardous waste from Boston, Massachusetts which was co-mingled with a pile of Tonawanda waste. The EPA took the matter under advisement. . The Utah Division of Solid and Hazardous Waste reportedly ordered International Uranium "to segregate and remove the hazardous waste component from the pile." 
     A citizen reported that some radiated debris may have been spilled along the roadway leading from the White Mesa mill, surmising  that this probably was due to spillage or from the water residue coming from trucks after faulty washing at the mill.
     Some truck drivers may not have been officially authorized or properly trained to haul the waste. Trucks carrying these dangerous cargos have often been parked on the streets and overnight in Moab. There have been continued administrative and testing infractions. 
But the question remains. Where is the mill to store these combined wastes? The tailings' capacity at the White Mesa mill is insufficient for the proposed processing of more alternate feed material. Its disposal cells 2 and 3 are rapidly filling. To make room for the prospective new wastes, the corporation has asked the NRC for approval to expand its area at White Mesa.
     In making its projections, the company discovered it had a shortfall of about 230,000 tons of capacity. It needed a modification of its Reclamation Plan to allow storage of 325,000 tons of material in another 9-acre cell impoundment area. This should trigger environmental impact studies.
     Health and environmental matters are being neglected. We need to push county, state and federal officials to prepare an Environmental Impact Statement (EIS) concerning this urgent matter. None had yet been prepared. 
     Information is not readily available to the public--records that enable water resource managers, scientists, and the public to find data about the quality of the water and other environmental factors. Often the information is not given at all, it is distorted, or it's presented in such a confusing style that most people don't understand.
     The present and long-term effects on agriculture and crops have not been established. This includes the wind drift onto the crops, which effects the cow and milk production. Standards have not been established.
     Chemical poisoning has been a problem. The chemicals in animals may affect their breeding, altering behavior, and disrupting their development, immunity and long-term survival.
     Cultural and spiritual heritage plays a great part toward one's happiness and welfare. So often this is overlooked, especially as it relates to our Native American peoples. The White Mesa mill sits on aboriginal lands and in an archeological zone in which there are many Indian burials.  Several sacred sites have already been disturbed.
     International Uranium should voluntarily submit to a State of Utah Groundwater Discharge Permit.  The company believes that there is no probable cause that its pollutants will affect waters of the State and that federal law doesn't require it. If this is not done voluntarily, the State must pursue immediate legal action to obtain and process a state groundwater discharge permit for the White Mesa mill. 
     The White Mesa drinking water is suspect and has not been monitored on a regular schedule. There is a major danger that the waste from the White Mesa waste dump could reach the San Juan River through the underlying Navajo Aquifer.
     We have already felt the impact of this hazardous  "alternate feed" and chemical wastes as truck after truck hauls the dangerous cargo through our towns en route to White Mesa.

     The situation is crucial. For many years we have been exposed to high levels of radiation in its many forms. Evidence may be mounting that cancer rates are on the increase in our region. With increasing radiation exposure, will cancer rates continue to rise? We surely need to look at cumulative impacts of radiation. We need epidemiological and toxicological studies that point to significant adverse health conditions.
     Meanwhile, the State, through the Attorney General's Office, should actively pursue resolution of issues through NRC administrative processes. This would include verification sampling at the White Mesa mill and the White Mesa Ute reservation. All components of the waste material should be known and listed. Furthermore, the Utah Radiation Control Board must actively appeal all adverse NRC rulings.
     International Uranium should be required to notify the State and the public of its amendment requests before its requests so that the public and the state have sufficient time to analyze all of the possible impacts. Environmental studies should be demanded on each amendment request. The company should report its mill activities to the Utah Radiation Control Board, to the Ute and Navajo Indian Tribal Councils and to the remainder of the public on a regular basis.
     International Uranium pays little to the county for the storage of these hazardous wastes. If hazardous waste is to be allowed into the county and along our highways, the company should pay for all damages and costs. This would include public health costs.
     No additional toxic and radiological materials should be accepted at the White Mesa mill until all of the proper environmental and health studies have been accomplished. Accordingly, the Glen Canyon Group of the Sierra Club recently called for these studies. 
     These studies will assuredly keep these dangerous wastes out in the future. Let's keep southeastern Utah nuclear free!