Northeast Church Rock 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
Description and History
NPL Listing History
NPL Status:
Proposed Date:
Final Date:
Deleted Date:
The Northeast Church Rock Mine (NECR) is a former uranium mine that was operated by United Nuclear Corporation (UNC) from 1967 to 1982. Most of the 125-acre mine permit area is held in trust for the Navajo Nation by the United States Government and is immediately adjacent to the Navajo Reservation. Approximately 40 acres are patented mining claim land owned by UNC. There is a small community of residents that live immediately next to the mine site on the reservation, downstream and down-wind of the waste piles. The residents graze sheep, cattle and horses, and collect herbs around the area.
The mining activities have resulted in a legacy of waste piles, sediment settling ponds abandoned building pads and mine equipment debris. When the mine was closed, several basic activities took place to protect future land users and neighbors. The majority of the buildings and equipment were cleared from the area. Some of the mine waste piles were returned to the shafts. Remaining 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.
While the mine was in operation the Nuclear Regulatory Commission (NRC) and the New Mexico Mining and Minerals Division regulated the site.
EPA has detected widespread radium contamination in 14 areas on and off-site, including the Sandfill areas, the ponds, the waste piles, the Non Economic Storage Area, the Boneyard. Beyond the permit boundary, Vent Holes #3 and 8, a parking area adjacent to the NECR 1 waste pile, a former trailer park, the unnamed arroyo and four residential yards also present elevated radium and uranium levels.
At present, there is an elevated health risk for people who frequent the site from inhaling radium contaminated dust particles, associated radon gas or utilizing contaminated rainwater and runoff that has pooled in the ponds. There is an elevated risk associated with livestock that may graze and water on the site. Elevated concentrations (activity) of Radium-226 have been detected throughout the 125-acre mine permit boundary and contiguous surface areas. Different radionuclides emit gamma rays of varying strength, but gamma rays can travel long distances and penetrate entirely through the body. Exposure to high levels of Radium-226 over a long period of time may result in harmful effects including anemia, cataracts, fractured teeth, cancer (especially bone cancer), and death. Exposure to high levels of uranium can cause kidney disease. It is not known to cause cancer, but can decay into other radioactive materials that may.
The following sections will cover the larger issues surrounding the NECR Mine Site by identifying the sources of health risks posing a substantial and imminent threat to human health and the environment that have developed in the time since active mining stopped, what agencies have responded and what their responses have been, the investigation of the site contaminants to identify areas that are contaminated and to assess the contamination levels in these areas, and what options exist to address the problem.
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Contaminants and Risks
Contaminated Media:
Surface Water
Air
Soil and Sludges
The sources of risk to people’s health comes from two aspects of this mine: dewatering the mine shafts while it was in operation and the mine waste piles that were created while removing the valuable ore.
Dewatering
The miners would tunnel 1600-1800 ft below the surface to extract the uranium ore that was processed at the nearby UNC uranium mill, now a Superfund cleanup site managed by the U.S. EPA Region 6 (Dallas) and the NRC. The uranium ore was situated in the ground immediately adjacent to an underground aquifer (groundwater). This resulted in groundwater seeping into the mine shafts. That water was pumped from the mine shafts to the surface and had the potential to carry uncontrolled radioactive sediments held in suspension to the surface. UNC was required to treat this water before it was released into a wash called simply the unnamed arroyo. Water pumped out of the mines was treated via a system of sequential treatment ponds where the suspended sediments would drop to the sides and bottom of the pond as the water flowed through and out of the third pond into the unnamed arroyo. The ponds have been drained for the most part, however they can fill up with seasonal precipitation. EPA has found that some of the sediments that dropped out of suspension were not completely removed from the ponds during active mining and NRC’s license closeout activities and lead to unhealthy surface water within the ponds. The water that flowed out of the final treatment pond carried contaminated sediments into the unnamed arroyo that flows between some of the residences.
Additionally, the State and NRC approved disposal of uranium mill tailings, concentrated with radium at the Site. Mill tailings were hauled to the Site, stockpiled in several areas known as Sandfills and were then slurried into the mine workings and stopes to prevent collapse. The sandfill areas and ponds present the most elevated radioactivity.
Mine Waste Piles
The waste piles are a result of removing dirt, rock, and rubble (overburden) from the mine shafts surrounding the valuable uranium ore bodies. Within these waste piles exists low-grade uranium, associated radioactive minerals, such as radium, and other heavy metals that were not separated from the overburden. This has resulted in large wastepiles of contaminated soil on the surface of the site, where plants have begun to grow and people may come into contact if walking on the site. Additionally, the contaminated overburden is carried off the Site by wind and water erosion.
Who is Involved
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.
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. The two sites share a continguous boundary.
US EPA Region 9 is also the lead agency for cleanup of the adjacent Quivira mine site.
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Investigation and Cleanup Activities
EPA has taken an initial action to completely fence the Site and mitigate imminent and substantial endangerment to several residences near the Site. EPA is also conducting a study to determine the best approach to long-term cleanup of the affected area.
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. The rest of the Site will be addressed using Non-time Critical Removal Action authority.
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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.
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Documents and Reports
 | Administrative Records |
|  |
| | Drainage East of Red Pond Road Removal AR | |
| | EE/CA Non-Time-Critical Removal Update 1 AR | |
| | Non-Time-Critical Removal | |
| | Residential Removal #1 AR | |
| | Step-Out Interim Removal AR | |
| Community Involvement |
| |
| 02/03/09 | New Mexico Environmental Department (NMED) Comments on EPA's May 30, 2009 Engineering Estimate and Cost Analysis | |
| 02/19/09 | Nuclear Regulatory Commission Comments on EPA's December 16, 2008 Draft Engineering Evaluation and Cost Analysis | |
| 06/15/09 | Department of Energy (DOE) Comments on EPA's May 30, 2009 Engineering Evaluation and Cost Analysis | |
| 06/22/09 | Multicultural Alliance for a Safe Environment (MASE) Comments on EPA's May 30, 2009 Engineering Evaluation and Cost Analysis | |
| 06/23/09 | The Red Water Pond Road Community Association Comments on EPA's May 30, 2009 Engineering Evaluation and Cost Analysis | |
| 07/01/09 | New Mexico Environmental Law Center Comments on EPA's May 30, 2009 Engineering Evaluation and Cost Analysis | |
| 07/07/09 | Bluewater Valley Downstream Alliance Comments on EPA's May 30, 2009 Engineering Evaluation and Cost Analysis at Public Hearing July 7, 2009 | |
| 07/07/09 | Individual comments on EPA's May 30, 2009 Engineering Evaluation and Cost Analysis at Public Hearing July 7, 2009 | |
| 07/07/09 | Northeast Church Rock Mine Removal Public Meeting Transcript, Pinedale Chapter | |
| 07/07/09 | Written Comments on EPA's May 30, 2009 Engineering Evaluation and Const Analysis Submitted at the July 7, 2009 Public Hearing | |
| 08/25/09 | Northeast Church Rock Mine Removal Public Meeting Transcript, Church Rock Chapter | |
| 09/08/09 | University of New Mexico's College of Pharmacy Comments on EPA's May 30, 2009 Engineering Evaluation and Cost Analysis | |
| 09/09/09 | Navajo Nation Environmental Protection Agency (NNEPA) Comments on EPA's May 30, 2009 Engineering Evaluation and Cost Analysis | |
| 09/09/09 | Navajo Nation Environmental Protection Agency (NNEPA) Comments (Additional) on EPA's May 30, 2009 Engineering Evaluation and Cost Analysis | |
| 09/09/09 | New Mexico Environmental Justice Working Group (NMEJWG) Comments on EPA's May 30, 2009 Engineering Evaluation and Cost Analysis | |
| 09/09/09 | Southwest Research and Information Center (SRIC) Comments on EPA's May 30, 2009 Engineering Evaluation and Cost Analysis | |
| 09/09/09 | The National Mining Association (NMA) Comments on EPA's May 30, 2009 Engineering Evaluation and Cost Analysis | |
| 09/09/09 | United Nuclear Corporation-General Electric Comments on EPA's May 30, 2009 Engineering Evaluation and Cost Analysis | |
|
| |
| 07/01/06 | Site Sampling Fact Sheet | |
| 05/01/07 | Press Release | |
| 02/28/08 | Gamma Goat: The Dangers of Uranium | |
| 06/08/09 | US EPA Announces Public Release of Engineering Evaluation and Cost Analysis (EE/CA) and Announcement of 30 – Day Public Comment Period and Public Meetings | |
| 04/22/11 | Mine Waste Cleanup Work – Community Update | |
| 09/01/11 | Northeast Church Rock Mine Site Cleanup - Community Update | |
| Images |
| |
| 08/31/07 | Residential Removal - Excavation | |
| 08/31/07 | Residential Removal - Stockpiled Soil | |
| 08/31/07 | Residential Removal - Verification Scanning | |
| Legal Documents |
| |
| 09/27/06 | NECR Removal Site Evaluation AOC | |
| 04/27/07 | NECR Residential Removal UAO w/ appendices | |
| 07/24/09 | NECR Interim Action AOC w/ appendices | |
| Maps |
| |
| 08/31/07 | Site Map | |
| Records of Decision |
| |
| 04/18/07 | Action Memo | |
| 05/29/07 | Action Memo | |
| 08/31/07 | Action Memo - Residential Removal | |
| 06/01/09 | Northeast Church Rock Mine Engineering Evaluation and Costa Analysis (EE/CA) & Appendices | |
| 07/23/09 | NECR Interim Removal Action - Action Memo | |
| 09/26/11 | Action Memorandum: Request for a Time-Critical Removal Action at the Northeast Church Rock Site Drainage East of Red Water Pond Road (Step Out Area #2), McKinley County, New Mexico, Coyote Canyon Chapter of the Navajo Nation Indian Reservation | |
| 09/29/11 | Action Memorandum: Request for a Non-Time-Critical Removal Action at the Northeast Church Rock Mine Site, McKinley County, New Mexico, Pinedale Chapter of the Navajo Nation | |
| Technical Documents |
| |
| 08/30/06 | Draft - Final Removal Site Evaluation Work Plan Northeast Church Rock Mine Site | |
| 10/01/07 | Final Removal Site Evaluation Report Northeast Church Rock Mine Site | |
| 10/01/07 | Final Removal Site Evaluation Report Northeast Church Rock Mine Site (Narrative only) | |
| 04/21/11 | Revised Northeast Church Rock Well Sampling-2010 | |
| 05/18/11 | Evaluation of Consolidation and Water Storage Capacity Related to Placement of Mine Material on the Existing UNC Mill Site Tailings Impoundment | |
| 09/01/11 | Draft Regional Groundwater Assessment of Impacts from Historic Releases of the NECR Mine and UNC Mill Facilities Navajo Nation | |
| 09/27/11 | Northeast Church Rock - Post EE/AA Analysis of Alternatives, Alternative Off-Site Disposal Locations | |
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Community Involvement
Public Meetings: Public Meetings:
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.
Inform the public to keep people and livestock away from the area of concern.
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
Panelists:
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
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Public Information Repositories
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.
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
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Contacts
|
Name |
Phone Number |
Email |
Address |
| EPA Site Manager |
Sara Jacobs |
415-972-3564 |
Jacobs.Sara@epamail.epa.gov |
Mail Code SFD63
75 Hawthorne Street
San Francisco, CA 94105 |
EPA Community
Involvement Coordinator |
Dana Barton |
415-972-3087
1-800-231-3075 |
Barton.Dana@epamail.epa.gov |
Mail Code SFD63
75 Hawthorne Street
San Francisco, CA 94105 |
EPA Public Information
Center |
|
415-947-8701 |
r9.info@epa.gov |
|
| State Contact |
Navajo Nation EPA Contact: Michele Dineyazhe
New Mexico Environment Dept: Earle Dixon
New Mexico Mining and Minerals Division:
Holland Shepherd |
928-871-7820
505-827-2890
505-476-3437 |
dineyazhe.michele@epa.gov
earle.dixon@state.nm.us
holland.shepherd@state.nm.us |
|
| PRP Contact |
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| Community Contact |
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| Other Contacts |
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After Hours
(Emergency Response) |
US EPA |
(800) 424-8802 |
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