Uranium Mining and Remediation Exchange Group UMREG

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1 Uranium Mining and Remediation Exchange Group UMREG Balancing the Uranium Production Cycle Remediation of Uranium Production Legacy Sites Executive Committee: Alexander Thomas Jakubick, Donald Metzler, Peter Waggitt

2 Origins Activities started as a bilateral US/German Exchange Group in Albuquerque (1993) and Chemnitz (1994) - initiated by Ralph Lightner (USDOE) and Diethardt Mager (German Fed. Min. of Economics) with the purpose to provide an inofficial platform for discussion among proponents, regulators, consultants and scientist re remediation of the legacy sites left behind by the U industry in course of the cold war. The aim was to find economically/environmentally balanced remedial solutions and pragmatic administrative approaches based on sound scientific/engineering principles and available technologies. The bilateral soon became multilateral meetings, such as in Sudbury1995 ( with Canadian and South African delegates), in Berlin (1995) Australia and France followed. During the meetings invancouver (1997), Denver (1998), Schlema (2000) and Bruges (2001) the started appearing in the discussion. Freiberg 2002, Oxford 2003, Freiberg 2005 and Bruges 2007 attracted participation of Uranium producing countries in Africa, Latin America, Central and Eastern Europe and Central Asia. During UMREG participation in the Red Book meeting 2007 the need of preventing creation of the legacy sites became apparent and in follow up was added to the UMREG objectives. Since the 2008 meeting in Freiberg an active cooperation with the IAEA has been established.

3 For Official Use NEA/NDC(2008)20 Organisation de Coopération et de Développement Economiques Organisation for Economic Co-operation and Development 03-Jul-2008 NUCLEAR ENERGY AGENCY COMMITTEE FOR TECHNICAL AND ECONOMIC STUDIES ON NUCLEAR ENERGY DEVELOPMENT AND FUEL CYCLE 41st MEETING OF THE JOINT NEA/IAEA URANIUM GROUP SUMMARY RECORD Item 12. Presentation on the Uranium Mine Rehabilitation Exchange Group (UMREG) Mr. Jakubick made a presentation outlining the history and accomplishments of UMREG. In order for this information to be as widely distributed as possible, Mr. Jakubick requested the UG to consider including a short summary of this work in the Red Book. After some discussion, the UG unanimously agreed to include a short outline of UMREG as an appendix in the 2007 edition. IAEA Headquarters, Vienna, Austria October 2007 Robert Vance robert.vance@oecd.org JT

4 Worldwide Development The demand for uranium production is moving to fast-growing economies, which plan to have nuclear power generation in their electricity production mix. Do we need, along with the key uranium production indicators, indicators of degree of impact of the mine and processing plant? Share of ISL/ISR increasing. Less impact on the surface but does the underground process control performs always satisfactorily? Is the monitoring of impact on ground water adequate?

5 Current and future activities UMREG continues providing a non-commercial forum for exchange of ideas, approaches and strategies among producers, mining and remediation companies, regulators and stakeholders for both prevention of new and mitigation of the old legacy sites. optimization of UPC and remediation of legacy sites. Experience shows that cash flow and low-impact UPC for U production projects can be kept balanced if the limitation potential of waste generation is realized and the process optimized at each step of the Uranium Production Cycle (UPC). In this respect U mining companies are recommended to implement a life-cycle economics in their development projects. With the growing number of U producing countries it is desirable to keep a good account and transparency of the U production waste streams and yellow cake produced. These accountabilities are best assured by experts directly at source.

6 Legacy sites of uranium production In the uranium industry underwent a structural change at the end of which a very low U spot price had been established. During this period a large number of conventional uranium mines discontinued production and the main producers prior to 1992 ended up with huge volumes of uranium mining and processing wastes, extensive areas of degraded land and surface and ground water resources contaminated on an unprecedented scale. Large programs for remediation of these liabilities were deployed in several countries. The best known of these programs were: The Uranium Mill Tailings Remedial Action (UMTRA) of the US Department of Energy. The Wismut Remediation Program of the German Federal Ministry of Economics. Individual remediation projects in Canada (e.g. the National Uranium Tailings Program and decommissioning in Elliot Lake and elsewhere) and Australia (e.g. Rum Jungle and Mary Kathleen). Numerous uranium legacy sites remediation pilot projects were started in Central and Eastern European Countries within the European Commission s Multi-Country Phare Program. The first two programs became the largest remediation programs in the world. Important lessons have been learned from all of the mentioned projects.

7 What do the unit remediation costs imply*? Country Average U price in 1992: Spot = 10 USD/lbU3O8; Multi-annual = 35 USD/lbU3O8 Cumulative Production of U 3 O 8 by end of 1992 in metric tones Unit Remediation Costs (URC) in USD/ lb U 3 O 8 Sweden Slovenia Spain Hungary Gabon Namibia Australia South Africa Germany (Wismut) Canada USA (UMTRA, Title I) USA (UMTRA, Title II) *The data are based on a project of German Ministry of Economics commissioned to Uranerz GmbH

8 What have we learned from the remediation of the legacy sites? Remediation costs may exceed the mining profits if the balance of production and waste generation is not kept under control. Remediation becomes more costly if the site has been abandoned. It is more cost efficient and environmentally prudent to remediate immediately upon closure while personnel, infrastructure and machinery are still in place and available. In case of ISR projects, use the possibility of concurrent production and remediation to reduce remedial costs. Make remedial planning and the assurance of remedial funds a mandatory regulatory requirement for the new projects. By far the best strategy is to prevent/minimize the generation of legacy wastes and site impacts and to plan for remediation already at the stage of design of the mine and processing plant.

9 Balancing the Uranium Production Cycle (UPC) No Uranium Production Phases Waste, Health, Environmental and Societal Issues Exploration of Resources; Proving up Reserves; Feasibility study, Project Preparation and EIA; Evaluation and design of mining and processing options; Planning of operations; Licensing Mining of Ore Transportation Ore Processing Yellow cake (U 3 O 8 or other forms) Closure planning; Decommissioning and demolition Preparation of remedial design and planning; Implementation of remedial works and water treatment; Regulatory clearance Regulatory assignment of the long term institutional control for management of the sites Pre-Construction Segregation and disposal of exploration wastes, radioactive (e.g. ore samples, cores) and conventional; Minimization of health and environmental impacts, waste generation, and discharges at all stages of UPC. Estimation of the Environmental Baseline. Remediation funding Construction and Production Monitoring of operations and environmental baseline; Minimize contamination due to mine waste; Control of health and environmental risks. Diligent tailings management. Good record keeping of output. Segregation of radioactive/non-radioactive wastes. Post-Production For containment of wastes, clean up of ground, sediments, water, ground water and handling of discharges. To reclaim land and water for utilization wherever possible. In accordance with the set criteria and after-use plan. Long term stewardship and maintenance (LTSM) of the site; Monitoring of integrity of containment and drainage. Safekeeping of data, records and remedial designs.

10 Remarks to Balancing the Uranium Production Cycle The assessment of potential health and safety impacts is not only for obtaining the initial permit/license. The results should be actively used when making decisions at all stages of the UPC. Formal checking procedures should be used to identify and weigh the risks at all stages of the UPC, i.e. the likelihood and extent of potential impact(s). Safety and Contingency plans should be in place for regular operation and emergency situations.

11 Balancing Uranium Production at Key Stages of the Cycle Decommissioning and remediation must be part of the planning and design of the mining project and construction. The mining option selected is critical for the type and costs of remediation required after closure. Therefore they must enter the feasibility study. Cost efficient open pit mining with large capacity trucks is by far the largest producer of waste rock. The social feasibility of the selected option must be cleared with the regulator and stakeholders. To avoid requests for changes after planning and design, which are difficult and costly. Development of Waste Management Plans must be an integral part of the mining project planning In order to prevent/minimize potential impacts by suitable siting and design of waste management facilities and waste generation at source. If characterizations show presence of acid generating rocks, special measures must be planned for the mine wastes to avoid high remediation costs. Consider concurrent production and mine waste disposal into open pits or depressions.

12 Accountability for Uranium Production Estimates of uranium resources are inherently imperfect and mine production rates are difficult to estimate because the ore grade varies from mine to mine and within the mine. The rate of mine production often varies according to season and due to technical reasons. The uranium production and waste generation rates can be approximately derived from the size (capacity) of the processing plant (mill) and machinery employed. Based on the capacity of trucks used, the average ore grade and frequency of the feed ore supply a crude estimate of the plant output can be obtained. Although the efficiency of the mill can vary, the production rate may be estimated from the mill throughput and concentration of uranium in the feed ore ( head grade ); both are usually reasonably constant. The production rate is estimated by measuring the operating time of the plant. The produced yellow cake (U 3 O 8 ) or any other uranium ore concentrate (UO 4, ADU, MgDU, etc), is packed in standardized drums and shipped in special containers to the conversion plant. A transparent and accountable record of the number of drums produced should become the regular practice at every plant.

13 Non-technical risks factors affecting the UPC Stability: The uranium market is strongly affected by non-technical factors. The public acceptance of nuclear energy is widely divided. The regulatory practices and structures applied in various countries are inconsistent. Uranium production in some countries is dominated by governmental initiatives. Strong and stable market conditions would be needed to secure stable long term supply and encourage the practice of balanced UPC. Cash flow: (especially for small to medium sized operators). More reliable calculations of UPC costs are needed to reduce the risk of generating new legacy wastes and sites. This requires a higher degree of regulatory harmonization in the producing countries. Because the valuation of long term benefits of a total UPC costing is likely to draw market repercussions the issue must be addressed with the mining companies, development banks and regulators. Transparency: The international U market and production are far from transparent. A better exposure of the risk management and safety practices of the producers and producing countries would be desirable. If sufficient data/information were disclosed, the regulator and legitimate stakeholders could make their own due diligence rather than rely on, and react to, pressure groups. A greater transparency of uranium production and market should be achievable by extending the scope of the Red Book and making it generally accessible as a data pool.

14 A new business model and international harmonization Although essential, the valuation of long term savings over the entire UPC is not merely an issue of production adjustments. There are important planning and accounting issues that must be resolved on the executive corporate level. The change to a UPC based planning and accounting system must respect that the cash flow projections are the basis for the market value of the mining project. But, it must not ignore that the uranium market is strongly affected by environmental and stakeholder issues. International co-ordination would be essential to ensure consistency between international recommendations and national actions for regulating uranium production. While it must be respected that national regulations need to be attuned to individual circumstances, uncoordinated national-international actions using diverging approaches only confuse the producers and distort competition. A strengthening of the leadership role of IAEA is needed. Through engagement of IAEA with the regulators, stakeholders and industry an environment should be created that is protective of the public and environment whilst ensuring the transparency of the UPC and move towards consistency in regulatory practice.

15 This is an example of an un-remediated legacy site. We want to prevent the generation of such sites and remediate the remaining legacy sites

16 A well remediated landscape of a former Uranium mining site This is an example of an un-remediated legacy site. (Ronneburg open pit mine site of Wismut GmbH) We want to prevent the generation of such sites and remediate the remaining legacy sites

17 Prevention by Balancing Production Waste Generation in the UPC No Uranium Production ( Maximization of Production and Revenue ) Waste Generation, Discharges and Spills ( Minimization of Waste generation, Risk and Expenses) 1 Exploration of Resources; Proving up of Reserves; Feasibility study and Project Preparation; Evaluation and design of mining and processing options; Planning of operations; Licensing Construction and Operation: a) Mining of Ore b) Ore Processing Yellow cake (U 3 O 8 or other forms) c) Transportation Segregation of radioactive (e.g. ore samples, cores) and conventional waste and disposal generated by exploration Assessment of waste generation, discharges, risks and associated costs for the entire UPC. EIA and Reference Environmental Baseline. Assurance of remediation funding Minimize contamination of land, water and waste; Monitoring of operations and baseline through the UPC; Respond to variations with ongoing improvements; Diligent control of output, release and transfer of product. 6 Closure planning; Decommissioning and demolition Segregation of radioactive/non-radioactive waste. 7 a) Preparation of remedial design and planning in accordance with regulatory clearance criteria and afteruse plans; b) Implementation of remedial works and water treatment c) Regulatory clearance EIA of long term stability of remediation; Handling of discharges from site; Likelihood of failure of containment and extent of impacts thereafter Benefits of reclaimed land utilization and provision of clean water. Implement long term beneficial land use where possible 8 Regulatory assignment of the long term institutional control for the legacy site Long term stewardship and maintenance (LTSM) of the site; Monitoring of integrity of containment and drainage. Safekeeping of data, records and remedial designs.

18 Ex Post Conclusions from the Multi-Country Phare Projects At all pilot legacy sites the consideration of local conditions and availability of machinery was crucial for the development of the conceptual remedial plan (e.g. for pile construction, cut-off wall / ditch construction, materials available in the vicinity of the sites, etc.) Under the moderate/wet climatic conditions of the CEEC, the remediation costs of uranium tailings ponds varied from 1 to 20 /m³ depending on the complexity of the situation and size (particularly thickness) of the tailings deposit. The costs/revenue allocation was not always transparent because of the income generated by sale of fixed assets, remaining inventory, materials and scrap metal. The remediation project costs were higher where the mines and mills had been closed abruptly, the infrastructure dismantled at short notice and the sites (more or less) abandoned before commencement of remediation. Most importantly, the Phare Program demonstrated that international seed money and partial funding of remediation can provide an effective incentive for the national governments to allocate funds (or match funding) to remediation of the legacy sites.

19 Duration of Production and Remediation at Various Average Levels of Unit Remediation Costs, URC* Years 0-2 URC ISL - Operator Conventional - Operator Wismut - government UMTRA Title I - government URC in USD (1992)/lb U 3 O 8 Black = Production Green = Remediation *The data are based on a project of German Ministry of Economics commissioned to Uranerz GmbH

20 What have we learned from these remediation projects? Remediation costs may exceed the mining profits if the balance of production and waste generation is not kept under control. Remediation becomes more costly if the site has been abandoned. It is more cost efficient and environmentally prudent to remediate immediately upon closure while personnel, infrastructure and machinery are still in place and available. Because of the possibility of concurrent production and remediation in cases of ISR projects additional remedial cost reduction may be achieved. For new mines a remediation plan and assured remediation funding need to be mandatory requirements of the authorisation or licence to start mining operations. Thus by far the best strategy is to prevent/minimize the generation of legacy wastes and site impacts as well as plan for remediation already at the stage of design of the mine and processing plant.

21 Balancing U Production and Waste Generation At the engineering and planning stage of the UPC, the remediation costs are most importantly affected by the quality of considerations given to the decommissioning and remediation aspects of the mine and processing plant design. Experience shows that the remediation expenditures for old mining projects done without considering environmental issues were considerably higher than for the more recent mining projects. While the objective at each stage is to achieve the reasonably highest possible efficiency of production, the decision-making must include both prevention and minimization criteria regarding waste and environmental impact generation. Use of the prevention and minimization criteria must become an integral part of company operations and must be integral to the corporate planning process. Although corporate commitment and leadership is crucial, incentives should be provided for the employees to come up with proposals for minimization of waste generation, environmental impacts and risks at each stage and, if promising, the proposals should be considered and implemented in the planning.

22 Checks and Balances of Decision Making Planning of decommissioning and remediation must enter the planning and design of the mining project and construction. The preferred mining option selected is critical for the type of remediation required after closure. The remediation costs must be considered in the feasibility assessment. Development of Waste Management Plans must be integrated into planning of the mining project Prevention and minimization of waste generation must be integrated into planning of the mining project. Suitable siting, design and construction of waste management facilities is the best warranty for prevention/minimisation of potential impacts. Keep in mind, cost efficient open pit mining with large capacity trucks also produces enormous quantities of waste rock. In case of acid generating waste rock special measures must be planned to avoid high remediation costs. Sometimes, disposal of waste rock into open pits or depressions can be initiated concurrently with mining. The social feasibility of preferred option must be cleared with the regulator and stakeholders. Corrections after selection, planning and design are difficult and costly.

23 Checks and Balances of Decision Making Environmental Impact Assessment (EIA) and Safety and Contingency plans The EIA is not only for obtaining the initial permit/license. The EIA should be an active document and the findings used in management decisions at all stages of the UPC project. Formal checking procedures should be used to identify and weigh the risks at all stages of the UPC, i.e. the likelihood and extent of potential impact(s). Safety and Contingency plans should be prepared along with EIA, for both regular operation and emergency situations.

24 Approximations of the Production and Waste Streams Estimates of uranium resources are inherently imperfect and production rates at the mine are difficult to estimate because the ore grade varies both from mine to mine and within the mine. The rate of mine production often varies according to season and due to technical reasons. The uranium production and waste generation rates can be approximately derived from the size (capacity) of the processing plant and machinery. The capacities of trucks used, the average ore grade and frequency of supply of the feed ore can provide a crude estimate of the plant output. Although the efficiency of the mill can vary, the production rate may be estimated from the mill throughput and concentration of uranium in the feed ore ( head grade ); both are usually reasonably constant. The production rate can be estimated by measuring the operating time of the plant. The product, the yellow cake (U 3 O 8 ) or any other uranium ore concentrate (UO 4, ADU, MgDU, etc), is packed in standardized drums and shipped in special containers to the conversion plant. The number of drums leaving the plant over a period of time is the production rate. A transparent and accountable record should be the regular practice at every plant.

25 Non-technical risks affecting the UPC Stability: The uranium market is strongly affected by non-technical factors. The public acceptance of nuclear energy is widely divided. The regulatory practices and structures applied in various countries are inconsistent. Uranium production in some countries is dominated by governmental initiatives. Strong and stable market conditions would be needed to secure stable long term supply and encourage the practice of balanced UPC. Cash flow: (especially for small to medium sized operators). More reliable calculations of UPC costs are needed to reduce the risk of generating new legacy wastes and sites. This would require a higher degree of regulatory harmonization in the producing countries. The valuation of long term benefits within a total UPC costing would generally draw repercussions in a market economy. This must be addressed with the mining companies, development banks and regulators. Transparency: The international U production and market are far from transparent. A better exposure of the risk management and safety practices of the producers and producing countries would be desirable. If sufficient data/information were disclosed, the regulator and legitimate stakeholders could make their own due diligence rather than rely on, and react to, pressure groups. A greater transparency of uranium production and market should be achievable by extending the scope of the Red Book and making it generally accessible as a data pool.

26 A new business model and international harmonization Although essential, the valuation of long term savings over the entire UPC is not merely an issue of production adjustments, there are important planning and accounting issues on the corporate level involved as well. The change to a UPC based planning and accounting system must respect that the cash flow projections are the basis for the market value of the mining project. But, it must not ignore that the uranium market is strongly affected by environmental and stakeholder issues. International co-ordination would be essential to ensure consistency between international recommendations and national actions for regulating uranium production. While it must be respected that national regulations need to be attuned to individual circumstances, uncoordinated national-international actions using diverging approaches only confuse the producers and distort competition. A strengthening of the leadership role of IAEA is needed. Through engagement of IAEA with the regulators, stakeholders and industry an environment should be created that is protective of the public and environment whilst ensuring the transparency of the UPC and move towards consistency in regulatory practice.

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