Pacific Southwest, Region 9: Superfund
Serving Arizona, California, Hawaii, Nevada, the Pacific Islands, and Tribal Nations
Northeast ChurchRock Mine
EPA #: NNN000906132
State: Navajo Nation(NN)
County: McKinley
City: Churchrock
Congressional District: 3
Other Names: United Nuclear Corporation
Bulletin Board
EPA Announces Plan to Clean Up Largest Abandoned Uranium Mine on the Navajo Nation
US EPA September 29, 2011 Press Release
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Description and History
NPL Listing History
NPL Status: Non-NPL
Proposed Date:
Final Date:
Deleted Date:
Description and History
The Northeast Church Rock Mine (NECR) is a former uranium mine located at the northern end of State Highway 566 approximately 17 miles northeast of Gallup, NM in the Pinedale Chapter of the Navajo Nation. NECR is immediately adjacent to the Navajo Reservation boundary and most of the 125-acre mine permit area is held in trust for the Navajo Nation by the United States Government. Approximately 40 acres are patented mining claim land owned by the United Nuclear Corporation (UNC). There is a small community of residents that live immediately next to the mine site on the Navajo reservation, downstream and downwind of the waste piles. The residents graze sheep, cattle and horses, and collect herbs around the area. Due to the proximity of the residents to the mine site, this mine was identified as the highest priority for cleanup by US EPA and Navajo Nation EPA of over 500 abandoned uranium mines on the Navajo Nation.
NECR was operated by UNC from 1967 to 1982. During this time, approximately 3.5 million tons of ore was extracted making this the second highest producing mine on the Navajo Nation behind the Kermac Mine No. 22 in the Ambrosia Lake Area. While the mine was in operation, the New Mexico Mining and Minerals Division regulated the site. The uranium ore body is located up to 1,800 feet below grade at the NECR Mine Site. Therefore, the mining was conducted over 1,000 feet below the ground surface accessed through two main underground shafts. Other mining features included several vent holes, support buildings, roads and water extraction wells and treatment facilities. Portions of the site are located within an arroyo. Uranium ore from the UNC mine was processed at the adjacent UNC Mill Site, located on private property across Highway 566.
When the mine was closed, several basic closure activities took place. The majority of the buildings and equipment were cleared from the area. Waste piles were contoured to reduce movement of the material. The ponds were drained and a fence was installed around the mine site and associated areas. Tailings from the UNC Mill were brought to the UNC Mine Site and used to fill and stabilize some portions of the mine that had been excavated to remove uranium ore. The tailings were pumped underground using sand slurry which filled the mine workings and shafts. The shafts were then capped with concrete plugs.
In 2005, the Navajo Nation requested that US EPA Region 9’s San Francisco Office take the lead in investigating and cleaning up the mine site. Through investigations beginning in 2006, US EPA has detected radium contamination above safe levels both on the mine site and in the surrounding areas on the Navajo Reservation immediately downwind and downstream of the mine site. Contamination discovered on the Navajo Reservation and in the residential areas is being addressed through a series of short-term cleanup actions in 2007, 2009, and 2012. Contamination on the mine site is being addressed over a longer time period with an anticipated three year design phase and four years of construction. On September 29, 2011, US EPA determined a cleanup plan for NECR that will bring low levels of contaminated waste from the mine site to the UNC Mill Site for permanent disposal. This cleanup is contingent upon a Record of Decision for the UNC Mill Site by US EPA as well as a license amendment from the Nuclear Regulatory Commission.
Contaminants and Risks
Contaminated Media
- Surface Water
- Air
- Soil and Sludges
Contaminants
Radionuclides: As uranium breaks down over time, it turns into radium. Radium is a radioactive substance that breaks down over time, releasing alpha, beta and gamma radiation. Radium may be found in air, water and soil and plants may absorb radium in the soil. Breathing in high levels of radium can cause adverse effects to the blood, eyes, lungs, and teeth. Exposure to high levels of radium can result in an increased incidence of bone, liver, and breast cancer. The U.S.EPA and the National Academy of Sciences, Committee on Biological Effects of Ionizing Radiation, have stated that radium is a known human carcinogen that can cause cancer (ATSDR, 1999).
Risks
Current conditions at the NECR Mine Site present risks due to the lack of an engineered containment system for the mine waste and the wind and water transport mechanisms that have previously contaminated the NECR Mine Site and the residential areas located north of the NECR Mine. The Human Health Risk Assessment indicated that there are three predominant human exposure pathways of concern for uranium and radium. Whole body radiation may be experienced by nearby residents and trespassers on or near the NECR Mine Site itself or at secondary sources (e.g., water or windborne). Radium in the soil may be absorbed by plants and may concentrate in terrestrial organisms. Persons and wildlife may also directly ingest radionuclides which then may be transported to organs or other sites in the body. Radionuclides such as radium, radon and decay products may be inhaled creating alpha radiation sources in the lungs.
Much of the contaminated material at the NECR Mine Site is fine-grained and therefore likely to result in human exposure via inhalation or ingestion. Persons occupying or traversing the NECR Mine Site may be exposed to contaminated dust by inhalation or ingestion of contamination sorbed to particulate matter. Incidences of direct contact with natural and mechanically generated dust during these activities account for known contamination exposure scenarios at the NECR Mine Site. Radium may be entrained in naturally and mechanically generated dust and/or transported on shoes and clothing of residents passing over contaminated areas.
Activities that occur in contaminated areas that may put persons at risk include walking, hiking, livestock grazing, gardening and yard work, and modes of transportation including all-terrain vehicle, motorcycle, or horseback. Persons may drive their vehicles over contaminated areas as well. This activity may also contribute to exposure pathways via dust generation. Rainfall events may lead to transport of the contamination from the NECR Mine Site. Soil erosion may indicate transport of contamination from the NECR Mine Site constituting a release of hazardous substances and resulting in secondary contamination sources. In addition, contaminants may migrate during wind events, due to adherence to windborne dust particles.
Without the excavation and removal called for in the September 29, 2011 action memorandum (see Records of Decision section below), contaminated mine waste and soils from the NECR Mine Site may migrate off-site via wind and water transport mechanisms.
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Who is Involved
Northeast Church Rock Mine Site: US EPA Region 9 is the lead on the mine Site according to the terms of a Memorandum of Understanding (MOU) with the Navajo Nation and EPA Regions 6 and 8. US EPA is closely coordinating all site related activities with the Navajo Nation EPA.
UNC Mill Site: The UNC Mill Site is located across Highway 566 from the Northeast Church Rock Mine Site and will be the repository for low levels of contaminated mine waste. EPA Region 6 has the lead for groundwater remediation, while the Nuclear Regulatory Commission (NRC) has the lead for soil remediation at the UNC Mill NPL Site, located on private property.
Quivira Mine Site: The Quivira Mine Site is located across Red Water Pond Road from the Northeast Church Rock Mine Site. US EPA Region 9 is also the lead agency for cleanup of the adjacent Quivira mine site. More information about this mine site can be found at http://yosemite.epa.gov/r9/sfund/r9sfdocw.nsf/3dec8ba3252368428825742600743733/22a4a391459e47b08825784d007ee6fd!OpenDocument.
Initial Actions
In March 2005, the Navajo Nation Environmental Protection Agency (NNEPA) requested that the U.S. EPA (EPA) conduct a response action under the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA) at the Site. In February 2006, the EPA submitted a consultation agreement to the NNEPA to conduct good faith government-to-government coordination of CERLCA response activities.
Site Studies
In November 2006, UNC, under order by the EPA, conducted a removal site investigation campaign to assess the 14 areas that are contaminated and to the severity of the contamination. EPA and NNEPA had several personnel overseeing the month-long effort. UNC collected 375 surface and subsurface soil samples and over 900 gamma survey points. A copy of the draft Removal Site Evaluation is located in the Technical Documents section.
Initial Actions
In April 2007, the EPA initiated a time critical removal action of radium contaminated soils from the three residences and side yards nearest the NECR mine site based upon validated data from the site investigation report. EPA addressed one additional yard close to the Kerr McGee site as a fund-lead (Residential Removal #2). The removal around the residences was viewed as a priority due to the high use immediately around the home sites. EPA chose an action level of 2.24 pCi/g Radium 226. Approximately .5 feet of soil from approximately 1/2 acre around each structure was excavated, stockpiled at the NECR mine. EPA conducted verification soil samples and 100% gamma scans prior to backfilling. Approximately 6,000 cubic yards of soil were trucked to an off-site radioactive TSD in Grandview, ID. A berm and french drain were installed as interim actions. Soils were backfilled and hydroseeded with native grasses. Residents were asked to participate in a temporary lodging program to minimize disruptions to their daily lives while removal activities occurred.
Site Studies
In Spring 2009 the EPA finalized an Engineering Evaluation and Cost Analysis (EE/CA) for the removal action at the remainder of the mine site (Non-Time Critical Removal Action). EPA held a ninety-day public comment period in the Summer, concluding on September 9, 2009. Upon concurrence with the Navajo Nation, the EPA will negotiate with UNC to conduct a removal action on the remainder of the Site.
Cleanup Ongoing
In 2009, EPA ordered UNC to conduct an Interim Time Critical Removal Action involving approximately 100,000 cubic yards of radium contaminate soil from the Step-Out Areas beyond the Mine Site, including the Unnamed Arroyo and vicinity residential areas. The work, with EPA oversight, involved excavation, consolidation and capping of radium contaminated soils on the mine site. Excavation activities were completed in January 2010 and UNC demobilized for the Winter. To complete the Removal, UNC reseeding and fencing will be completed in the Spring. Additional excavation, fencing, reseeding, and installation of soil erosion control measures in certain areas were accomplished in 2010. Ongoing monitoring and any necessary maintenance or improvements of soil erosion control measures will continue.
Remedy Selected
On September 29, 2011, US EPA completed the action plan for the final cleanup of the Northeast Church Rock Mine site (See Figure 1, Area
A in the Northeast Church Rock Mine Cleanup Fact Sheet below). The location selected in the Action Memorandum, and determined to be suitable in the Engineering Evaluation and Cost Analysis previously issued, is the nearby United Nuclear Corporation (UNC) Mill Site. Placement of the waste at the Mill site is contingent on two additional approvals including an amendment of the UNC Mill site facility’s NRC license and documentation in an appropriate decision document from US EPA Region 6. The plan is based on more than six years of work and over 10 public meetings with the local community, the Navajo Nation, and others to ensure that EPA heard, considered and addressed the questions and concerns of all stakeholders.
Cleanup Results to Date
Initial site activities were conducted using Time Critical Removal Action authority cleaning up over 100,000 cubic yards of contaminated material on the reservation and temporarily storing it on the Mine Site until the final cleanup. The 2012 cleanup action is expected to remove an additional 20,000 - 30,000 cubic yards of contaminated material from the reservation. Contaminated soil on the mine site will be addressed using Non-Time Critical Removal Action authority.
Potentially Responsible Parties
Potentially responsible parties (PRPs) refers to companies that are potentially responsible for generating, transporting, or disposing of the hazardous waste found at the site.
United Nuclear Corporation is performing investigation work under the terms of an Administrative Order on Consent. EPA issued a Unilateral Administrative Order to remove and dispose of residential contaminated soils at an off-site TSD facility.
Documents and Reports
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Community Involvement
Public Meetings:
See the "Documents and Reports" Section above for Fact Sheets and additional information.
Date: March 3, 2006
Location: Church Rock Chapter House
Purpose: Chapters to give suggestions to NN EPA and US EPA on the removal action and community involvement plan.
- Date: July 26, 2006
Location: Church Rock Chapter House
Purpose: Discuss Upcoming Sampling and Next Steps
Date: June 23, 2009
Loction: Pinedale Chapter House
Purpose: Discuss Engineering Evaluation/Cost Analysis (EE/CA), Respond to Questions, and Solicit Community Comments and Concerns
Date: July 7, 2009
Location: Pinedale Chapter House
Purpose: Public Hearing for Engineering Evaluation/Cost Analysis (EE/CA)
Date: August 25, 2009
Location: Church Rock Chapter House
Purpose: Additional Public Hearing for Engineering Evaluation/Cost Analysis (EE/CA)
Date: November 4, 2009
Location: Gallup Inn, Gallup, NM
Purpose: Listening Session
Date: March 10, 2010
Location: UNC Building, Hwy 566
Purpose: Presentation on Revegetation and NECR Status Update
Date: March 30, 2010
Location: Church Rock Chapter House
Purpose: Health and Risk Workshop
Henry Tso, Medicine Man Association
Andrew Bain and Daniel Stralka, US EPA
Michele Dineyazhe, NN EPA
Libby Vianu, ATSDR
Dr. Douglas Zang, IHS
Johnnye Lewis, UNM DiNEH Project
- Date: May 13, 2010
Location: Church Rock Chapter House
Facilitator: Phil Bluehouse, Navajo Peacemaker
Purpose: Discuss Peacemaking Process and Expanding Cleanup of Red Water Pond Road Area
Date: June 10, 2010
Location: Church Rock Chapter House
Facilitator: Phil Bluehouse, Navajo Peacemaker
Purpose: Follow Up to Previous Action Items and Discussion of Community Goals
Date: October 4, 2010
Location: Church Rock Chapter House
Facilitator: Phil Bluehouse, Navajo Peacemaker
Purpose: Follow Up to Previous Action Items and Discussion of Community Goals
Date: December 2, 2010
Location: Church Rock Chapter House
Facilitator: Phil Bluehouse, Navajo Peacemaker
Purpose: Discussion of Red Water Pond Road Community Conceptual Plan
Date: April 26, 2011
Location: Local Residence
Purpose: Update on Northeast Church Rock and Quivira Activities - Distribute Fact Sheet
Date: May 24, 2011
Location: Local Residence
Purpose: Review Results from East Drainage Area Characterization
Date: September 27, 2011
Location: Local Residence
Purpose: Announce Imminent Clean Up Plan for Northeast Church Rock Mine Site
- The plan is based on more than six years of work and over 10 public meetings with the local community, the Navajo Nation,
and others to ensure that EPA heard, considered and addressed the questions and concerns of all stakeholders. The
result is a cleanup plan that will:
• Provide unlimited surface use of the mine site after cleanup
• Use the most stringent uranium mine cleanup standard
in the country
• Add a cap and liner system at the United Nuclear
Corporation (UNC) site to ensure that the mine waste
does not affect people and the environment
• Send waste containing high levels of radium or uranium
off -site for reprocessing or approved disposal
• Clean up contaminated drainage area east of Red
Water Pond Road
• Provide voluntary housing options during the cleanup
for community members living near the mine
• Provide job training and employment during the cleanup
United Nuclear Corporation/General Electric (UNC/GE)
has also agreed to:
• Hire locally through a Navajo hiring preference
• Provide a scholarship program for Navajo students to
attend the University of New Mexico or Arizona State
University
• Improve Pipeline Canyon Road near the area of the
mine and mill sites
• Provide building materials for ceremonial hogans
requested by the Red Water Pond Road community
residents
Public Information Repositories
The public information repositories for the site are at the following locations:
Local Repositories:
Navajo Nation Library
204 Post Office Loop Road
Window Rock, Arizona
(928) 871-6376
Octavia Fellin Public Library
115 West Hill Ave.
Gallup, NM 87301
(505) 863-1291
The most complete collection of documents is the official EPA site file, maintained at the following location:
Superfund Records Center
Mail Stop SFD-7C
95 Hawthorne Street, Room 403
San Francisco, CA 94105
(415) 820-4700
Enter main lobby of 75 Hawthorne street, go to 4th floor of South Wing Annex.
Contacts
EPA Site Manager
75 Hawthorne Street
San Francisco, CA 94105
EPA Community Involvement Coordinator
1-800-231-3075
75 Hawthorne Street
San Francisco, CA 94105
EPA Public Information Center
State Contact
New Mexico Environment Dept: Earle Dixon
New Mexico Mining and Minerals Division:
Holland Shepherd
505-827-2890
505-476-3437
earle.dixon@state.nm.us
holland.shepherd@state.nm.us
PRP Contact
Community Contact
Other Contacts
After Hours (Emergency Response)