STATEMENT OF CHRIS SHUEY

Before the Subcommittee on National Parks, Forests, and Public Lands

Natural Resources Committee

U.S. House of Representatives

March 28, 2008

This statement is provided at the request of the Subcommittee for the
purposes of (1) summarizing the health and environmental impacts of
historic uranium mining and processing, particularly in communities on
the Navajo Nation; (2) summarizing what is known about past uranium
mining around the Grand Canyon; (3) describing the results of recent
environmental assessments and ongoing public health studies in
uranium-impacted communities in New Mexico, and the implications of
these studies for uranium development around Grand Canyon National Park;
and (4) describing the potential impacts of new uranium mining around
GCNP.

In nearly 30 years of work studying the effects of uranium mining, I
have conducted water quality and radiological assessments and soil
sampling in residential areas near abandoned uranium mines; learned and
studied the medical literature on health status among uranium workers
and effects of long-term exposure to uranium; testified as an expert
witness in state regulatory proceedings on groundwater protection
standards for uranium; and designed and participated in epidemiological
studies in Navajo communities affected by uranium mining. I am the
director of the Uranium Impact Assessment Program at Southwest Research
and Information Center (SRIC), a multicultural, educational and
scientific organization founded in Albuquerque in 1971; I have been
employed at SRIC since 1981. I am a co-Principal Investigator for two
federally funded health studies in the Eastern Agency of the Navajo
Nation: the Diné Network for Environmental Health (DiNEH) Project and
the Navajo Uranium Assessment and Kidney Health Project ("Kidney
Study").[^1] And I managed field operations for the Church Rock Uranium
Monitoring Project (CRUMP) on the Navajo Nation between 2003 and 2007.

I hold a bachelor of university studies degree and masters in public
health degree from the University of New Mexico. My MPH degree focused
on environmental health science and epidemiology, and my professional
project examined epidemiological challenges for conducting
population-based health studies of the effects of ingestion of uranium
in drinking water. My biographic sketch is attached as **Exhibit A** to
this written statement.

Based on my education and experience in environmental science and public
health, and on the analyses and evidence presented in this statement, I
conclude that new uranium mining around Grand Canyon National Park is
not prudent government policy. New uranium mining threatens the
world-class natural resources of the Park, especially its hundreds of
springs and streams. Environmental impacts from mining are unavoidable,
regardless of the level of operational controls. To the extent that
there is uncertainty about the potential for irreversible impacts from
new uranium mining, withdrawing public land from mineral development is
sound public health and environmental policy consistent with the
Precautionary Principal.

[I. Summary of Impacts of Historic Uranium Development in the Four
Corners Area]{.underline}

Before describing the range of potential impacts of uranium mining in
the region of the Grand Canyon, I believe it is worthwhile to review
commonly accepted findings about the health impacts of exposure to
uranium and the history of uranium mining on the Colorado Plateau.
Previously, I prepared a brief review and summary of the literature on
this matter, and have appended a copy hereto as **Exhibit B.** The
following findings supplement the literature review:

-   Uranium is not only a Class A human carcinogen because of its
    radioactive properties, but is also a potent kidney toxicant, and
    its USEPA limit in drinking water is based on uranium's chemical
    toxicity to the human kidney. In short, uranium is very much a
    poison, and every effort should be made to limit its release to the
    environment by human activities. (Exhibit B, footnote 6)

-   Thousands of uranium mines were developed on the Colorado Plateau
    since the 1940s, and a large proportion of these were abandoned
    by 1970. Reclamation of these "Cold War Era" mines --- so-called
    because the uranium ore was purchased exclusively by the Federal
    Government for the nuclear weapons program --- was focused on
    eliminating or mitigating safety hazards, such as open shafts and
    adits. Controlling environmental releases from waste piles or
    cleaning up contaminated lands and water supplies has lagged far
    behind, and many past mining sites have had no reclamation.

-   A lack of baseline environmental data characterized many uranium
    mining sites developed between 1970 and the mid-1980s. As a result,
    environmental effects of these recent mining operations have been
    difficult to ascertain. Additionally, long-term monitoring and
    surveillance is nonexistent at many former mining sites.

-   Uranium mining by conventional open-pit or underground methods was
    *never* regulated by the Federal Government, and only in the last 15
    to 20 years have state governments enacted regulations for uranium
    mining. Federal land management agencies have relied largely on
    general standards for mineral development pursuant to their
    land-management obligations under federal law.

-   Uranium mines generate wastes in the form of overburden, waste rock
    and low-grade ore. When exposed to air, the hazardous and
    radioactive substances native to the rock are oxidized and released
    to the environment through runoff and wind dispersion. The toxic
    constituents of mine waste include uranium, arsenic, cadmium, lead,
    molybdenum and selenium, and the radioactive constituents include
    uranium, thorium, radium, and lead.

-   Milling, or processing, of uranium ore to extract uranium oxide for
    use as fuel in nuclear reactors was not regulated by the federal
    government or the states until the late 1970s. Since 1978, more than
    50 "inactive" and "active" uranium mills and tailings disposal
    facilities --- more than half of which are located on the Colorado
    Plateau --- have been consolidated and covered to mitigate releases
    of radioactive tailings and radon gas. *Every* uranium mill has
    extensive, localized groundwater contaminant plumes that are still
    years, if not decades, from being fully remediated.

-   While numerous epidemiological studies have been conducted among
    uranium workers, no comprehensive public health study has ever been
    conducted in Navajo communities where uranium mining and processing
    took place. (Shuey, 2007b) Health studies in uranium-mining
    communities are expensive, time-consuming and scientifically
    challenging, but they can and should be done.

The legacy of abandoned uranium mines on the Navajo Nation has received
increasing attention recently as a result of national news coverage in
2006 (Pasternak) and congressional oversight hearings in October 2007
(U.S. House of Representatives, 2007). The Navajo Nation's description
of the extent of the uranium problem is described in the testimonies of
Navajo officials and residents of communities affected by mining. I
recommend the Subcommittee take notice of these testimonies and other
evidence gathered by the House Committee on Oversight and Government
Reform. See, <http://oversight.house.gov/story.asp?ID=1560>.

[II. Results of Recent Environmental and Health Studies in Navajo
Communities in New Mexico]{.underline}

II.A. Churchrock Environmental Assessments

The Church Rock Mining District in northwestern New Mexico near the town
of Gallup was heavily mined in the 1950s and 1960s, and again between
1969 and 1983. Nearly 20 mines and 1 uranium mill and tailings facility
were located in the district, which includes portions of the Navajo
chapters of Churchrock, Coyote Canyon, Iyanbito, Nahodishgish and
Pinedale. The community is noted, infamously, for the July 16, 1979,
uranium mill tailings spill at the United Nuclear Corporation (UNC)
uranium mill. (See Exhibit B, footnote 17.) However, more radioactivity
was released in nearly 20 years of dewatering of three major underground
mines than in the one-time tailings dam breach. (Wirt, 1994)

Uranium mining and processing in the Church Rock district ended in 1983,
and little long-term environmental monitoring was conducted by state or
federal agencies after that. In 2003, Churchrock Chapter of the Navajo
Nation obtained a private grant to conduct monitoring of water, soils,
and outdoor and indoor air around abandoned mines and in residential
areas located close to abandoned mines. With the assistance of various
Navajo Nation, state and federal agencies, including USEPA, extensive
radiological assessments were performed along major highways and roads
in the community; soils were sampled for uranium and other trace metals
in areas not impacted, moderately impacted, and highly impacted by
mining wastes; radon was measured in the indoor air of more than 150
homes; and dust levels were monitored in communities close to abandoned
mines. The results of these studies, which I coordinated and
participated in, were documented in the "Report of the Church Rock
Uranium Monitoring Project (CRUMP), 2003-2007" (SRIC, 2007); the
executive summary and recommendations of the report can be viewed at
[www.sric.org/Uranium](http://www.sric.org/Uranium). Findings relevant
from the CRUMP studies for potential new uranium mining around the Grand
Canyon included:

-   Gamma radiation rates from two times background to more than 20
    times background were detected in soils along highways and roads
    where uranium ore was last hauled *nearly 25 years ago.* (SRIC,
    2007)

-   Soils around homes in an area sandwiched by two abandoned uranium
    mines contained concentrations of uranium nearly 100 times greater
    than local background, and concentrations of radium more than 400
    times greater than local background; uranium was observed to have
    *increased* with depth in the soil column. (Shuey, 2007a)

-   Field studies of storm runoff and sediment transport, coupled with
    bench-scale leaching tests on contaminated soil samples, indicated
    that uranium is present in a highly soluble form (+VI) and mobile in
    both surface waters and soils. (deLemos and others, 2007) The
    potential for uranium to leach into shallow, alluvial groundwater
    supplies was previously demonstrated in studies conducted by the
    U.S. Geological Survey (USGS) in the early 1990s. (Wirt, 1994; Van
    Metre and Gray, 1992)

The environmental assessments conducted by CRUMP demonstrated that it is
never too late to look for long-term environmental effects of past
uranium mining. The radiological and heavy metal contaminants from
uranium mining do not disappear or go away with time; they simply move
to other locations. The CRUMP assessments also provided scientifically
valid data that was later used by USEPA and the Navajo Nation to conduct
regulatory investigations under authority of the federal Superfund law.
As a result, USEPA conducted a Superfund emergency removal of nearly
6,000 cubic yards of radium-contaminated soils from around six Navajo
residences in May and June 2007.

[II.B. Eastern Navajo Health Studies]{.underline}

To address the paucity of health studies in uranium mining-impacted
communities and to investigate the causes of high rates of chronic
kidney disease in the Eastern Navajo Agency population in northwestern
New Mexico, a consortium of community-based, academic and medical
organizations embarked on a series of environmental health and
epidemiological studies in 2001. Funded by grants from the National
Institute of Environmental Health Sciences (NIEHS), the Diné Network for
Environmental Health (DiNEH) Project[^2] is conducting a thorough health
and water-use survey among 1,300 residents of 20 chapters of the Eastern
Navajo Agency, testing and sampling water in up to 160 unregulated water
sources, using soil data from the CRUMP studies to estimate
environmental exposures, and obtaining permission from participants in
the study to test blood and urine samples for uranium and for biomarkers
of kidney damage and kidney disease. The second phase of the DiNEH
Project, the Navajo Uranium Assessment and Kidney Health Study, is the
largest cross-sectional epidemiological study of the role of
environmental exposures in kidney disease ever conducted in the U.S.

As of this month, the DiNEH Project team has surveyed more than 550
residents of the study area; sampled nearly 100 unregulated water
sources for uranium and other trace metals that are documented kidney
toxicants; and collected blood and urine samples from 22 individuals out
a projected sample of 450 participants in Kidney Study. Findings of this
work include:

-   The number of abandoned uranium mines in a Navajo community is a
    predictor of four self-reported diseases: certain auto-immune
    diseases; chronic kidney disease; diabetes and high blood pressure.
    (Lewis, 2007)

-   Arsenic and uranium occurred in concentrations exceeding the USEPA's
    maximum contaminant levels of 10 micrograms per liter (μg/l) As and
    30 μg/l U in only 14 percent and 6 percent, respectively, of water
    sources tested. (Shuey, 2007b)

Later this year, our team will be reporting results of
logistic-regression modeling of kidney disease risk factors for more
than 500 survey participants. Included in the model are socioeconomic
data, body mass index, existing health and disease patterns,
environmental exposures to uranium wastes, occupational exposures
(uranium mining and milling and other jobs), and distance of residence
from abandoned mines. Initial results of the modeling indicate that
environmental exposures, including living within 0.8 kilometer of an
abandoned mine site, are significant predictors of kidney disease and
diabetes. These findings are consistent with self-reported disease
status in relationship to living in a community with greater numbers of
abandoned mines, and will be replicated several times as the study
progresses. We will share these results with the Subcommittee when they
are published.

[III. Historic Uranium Development Near the Grand Canyon]{.underline}

In preparing for this testimony, I reviewed available data on historical
uranium production in the region; assessments of uranium mining sites on
both the South Rim and North Rim; plans of operation for new uranium
exploration and mining; and published literature and data on water
quality of springs in the Grand Canyon and hydrogeologic models of
groundwater flow in the region. Between 1980 and 1985, I reviewed and
commented on regional environmental assessments for uranium mining in
the Arizona Strip and for site-specific mining proposals in the Kaibab
National Forest south of the Grand Canyon. Historically, uranium was
produced from Orphan Mine on the South Rim in the 1950s and 1960s, and
from several mines that were constructed in the Kanab Creek area on the
North Rim in the 1980s. The uranium was deposited in breccia pipes,
which are described in more detail later in this testimony.

III.A. Orphan Mine

The Orphan Mine is located on the South Rim between Powell Point and
Maricopa Point. It produced 4.26 million pounds of uranium between 1953
and 1969 (ADGF, 2007), and consists of two parts: The upper level on the
lip of the South Rim, which still hosts the mine headframe, ore pads and
support buildings, and the lower level sited on a terrace in the canyon
wall about 1,500 feet below the South Rim. In the early days of the
mine, ore was transported in a large bucket from the lower level to the
upper level by a tram and pulley system. Later, ore was brought to the
upper level on the South Rim through a main vertical shaft.

Several radiological and environmental assessments have been conducted
at both levels of the Orphan Mine. (Day and others, 1981; Tetrault,
1985; Harding Lawson Associates, 1993; Harding Lawson Associates, 1996;
SSPORTS Environmental Detachment, 1999; Aguirre Engineers, Inc., 2001)
These surveys showed gamma radiation levels exceeding local background
by up to 500 times *outside* of the safety fence that surrounds the
upper level section of the mine (Harding Lawson Associates, 1996, figure
2.3), and gamma rates nearly 800 times background inside the fenced
area. These radiation readings underscore the fact that radiological
impacts of uranium mining last virtually forever, and certainly long
after ore was last produced.

Mine wastes are still present at lower level of the mine. This site is
located between Horn Creek on the east and Salt Creek on the west. Two
separate water quality surveys in these creeks suggest that mine waste
at the lower level may be contributing to uranium levels exceeding the
USEPA drinking water standard of 30 μg/l. An investigation by Fitzgerald
and colleagues between 1993 and 1995 revealed a maximum uranium
concentration of 92.7 μg/l in Horn Creek during high-flow conditions.
(Fitzgerald and others, 1997) A second and more comprehensive water
quality assessment of South Rim springs and seeps was conducted in by
USGS and NPS in 2000-2001. (Monroe and others, 2004) Uranium levels in
water in Horn Creek ranged from 8.6 μg/l to 29 μg/l, and from 29 to 31
μg/l in Salt Creek. At the upper end of these ranges, the uranium levels
approached or exceeded the USEPA drinking water standard of 30 μg/l.

Fitzgerald and others concluded that the probable source of uranium in
the creek was waste rock from the mine that had intermixed with
streambed alluvium. The authors of the USGS study did not assess reasons
for the elevated uranium levels in Salt Creek and Horn Creek. However,
those two water sources had the *highest* uranium levels in the 20
springs and seeps tested in the study. No other spring had a uranium
level greater than 8.3 μg/l, and about half of the samples had uranium
concentrations between 1.1 and 2.7 μg/l --- levels typically thought of
as "naturally occurring" in groundwaters throughout much of the Earth's
crust.

The Orphan Mine was acquired by the National Park Service in 1987, and
since then, NPS and Grand Canyon National Park have worked closely with
the USEPA to conduct remedial action investigations that will eventually
lead to reclamation and cleanup of both parts of the mine. Tens of
thousands of tourists walk by the mine site on the South Rim trail every
year. Accordingly, excavation and removal of contaminated soils and
wastes, especially from the upper mine next to the South Rim trail,
would be prudent to protect the public health.

III.B. Kanab Mines

The original Hack Mine produced nearly 5,000 pounds of uranium between
1951 and 1964. (ADGF, 2007) Between 1980 and 1990, more than 17 million
pounds of uranium were produced from six new mines developed in the
Kanab Creek area north of the Canyon --- Hack 1, 2 and 3, Pigeon,
Hermit, and Kanab North. Three more uranium mines were developed in the
Kanab Creek area, but never produced uranium. Similarly, the Canyon Mine
was constructed on Forest Service land a few miles west of the village
of Tusayan, but no uranium ore was produced from this facility. Little
publicly available information exists on environmental conditions at the
Kanab Creek mine sites. Photos on the Internet show that the Hack Canyon
1 and Pigeon mines were reclaimed after mining ended in the late-1980s.
(Weinrich, 2008)

[IV. Potential Impacts of New Uranium Mining Around the Grand
Canyon]{.underline}

IV.A. Types of Mining Expected in Grand Canyon Area

Several mining companies have identified sites for exploration and
possible future mining (see, e.g., VANE Minerals, 2007), and virtually
of all them are targeting uranium-mineralized breccia pipes. Mining of
the breccia pipes common on both the North and South Rims in the Grand
Canyon area will most likely involve underground methods, consistent
with the limited history of mining of these pipes since the 1950s. Mines
previously developed in the breccia zones included shafts sunk on one
side of the pipes, with the orebody inside the pipe accessed *beneath*
the zone of mineralization.

The breccia ore deposits are not likely to be mined by the *in situ*
leach (ISL) mining, or solution mining, method.[^3] ISL mining is
amenable only in relatively thin, narrow and horizontally elongated
fluvial sandstone beds derived from ancient stream channels. These beds
are almost always water-bearing, and in fact, successful extraction of
uranium from the host rock depends on using the native groundwater to
move uranium-laden fluids from injection wells to production wells. Most
often, the ore deposits (variously called "roll fronts" or
"redistributed ores") are on bounded above and below by less permeable
beds, called "confining layers," or by tighter and less transmissive
rocks that bound the ore deposits on either side. This generalized ore
depositional pattern is typical of operating and proposed ISL mines in
Nebraska, New Mexico, Texas and Wyoming.[^4]

The breccia zones, by contrast, are oriented vertically with dimensions
measuring up to 300 feet in diameter and from 1,000 to 3,000 feet from
top to bottom. They are conglomeritic and poorly cemented, and according
to company reports, water passes through the breccia pipes readily,
meaning little water is stored in the pipes themselves. (Weinrich and
others, 1995)

IV.B. Potential Groundwater Impacts of Breccia Pipe Mining

That little groundwater is stored in breccia pipes does not necessarily
eliminate the potential for water quality impacts from uranium mining
near GCNP. The Kaibab Formation contains the surface expressions of
literally thousands of copper- and uranium-mineralized breccia pipes.
(Billingsley, 2000) The published and academic literature is replete
with references to the rapid recharge of snow pack and rainfall through
the karst limestone topography of the Kaibab Formation, into the
underlying sedimentary strata, especially on the North Rim. (Ross, 2005;
Huntoon, 2000) Roaring Springs, a perennial spring on the Bright Angel
Fault that provides municipal water supply for both the North Rim and
South Rim facilities of GCNP, is said to recharge over a very small area
of the mesa. (Ross 2005) On the South Rim in the immediate vicinity of
Grand Canyon Village, springs in the Mississippian Redwall-Muav
Limestone complex are recharged through snowmelt and rain flowing
through the Kaibab and Toroweap formations, Coconino Sandstone, Hermit
Formation and Supai Group. (Monroe and others, 2004) Groundwater flow is
northward to dozens of springs on the South Rim. At some point near or
south of the village of Tusayan, groundwater flow is to the south toward
the village of Valle and town of Williams. (GCNP 2003)

Huntoon (2000) postulated that uranium mineralization in the breccia
pipes was caused by the *upward* movement of groundwater from the
Redwall in Triassic time. Today, however, groundwater flow through the
breccias in the GCNP area is *downward*, and Huntoon states that many if
not most of the breccias that are buried inside the high-elevation
Permian-Pennsylvanian sequence in GCNP and on the Kanab Plateau to the
north are unsaturated. Nonetheless, a 1981 investigation *inside* the
underground workings of the Orphan Mine encountered 3 feet of standing
water (likely originating from the Coconino Sandstone and Esplanade unit
of the Supai Group) in the mine tunnel at the 400-foot level. (Tetrault,
1981)

Breccia pipes clearly are conduits for groundwater flow --- whether
upward in response to hydraulic pressures, downward in response to
gravity, or even laterally as a result of poorly cemented fractures and
solution cavities in the pipes themselves. They are by no means "dry."
The implication of the pipes carrying groundwater is that the uranium
minerals would be oxidized in mining operations, allowing uranium and a
host of native, and toxic, trace metals --- Ag, As, Ba, Cd, Co, Cu, Mo,
Ni, Pb, Se, V and Zn --- to be dissolved into the flowing groundwater.
Increased contaminant concentrations could occur at discharge points
from the pipes, such as the springs on the Canyon walls or in springs
and wells producing from the underlying Redwall Limestone around the
village of Tusayan.

As noted by several investigators, groundwater recharging through the
Kaibab Formation and into underlying sediments discharges to hundreds of
springs and seeps in the walls of the Grand Canyon and its dozens of
major tributaries. Water quality in these springs and seeps varies from
one location to another, and on occasion, trace metals like arsenic
occur naturally in concentrations exceeding human drinking water
standards. But a close examination of the available water quality data
shows clearly that the *overall quality* of the Canyon's water resources
is exceptionally good. (Monroe and others, 2004; Mazzu and Rihs, 1995)
The springs and seeps of the Canyon are crucial for maintaining riparian
habitats, sustaining stream flows that provide water for wildlife and
hikers, and providing water supply for the Native Americans who live
downstream in and outside of the Canyon.

In a water-short region where numerous long-term water-supply strategies
have been proposed to address the massive population growths of the
region, the Redwall Limestone is seen as a vital but diminishing
storehouse of high-quality groundwater for current and future human
drinking water supply. The Redwall also hosts the bottom third of most
of the mineralized breccia zones. Virtually every geologic drawing in
the literature shows the base of the breccia pipes bottoming out in the
middle of the Redwall. Mining of the breccias would introduce oxygen
into the ore zones, oxidizing the rock. From our experience in New
Mexico, we know that uranium, when oxidized, dissolves readily (as U+6)
and moves rapidly downward in the soil column. Little attention seems to
have been given to the impacts of oxidation of the uranium --- and
consequently, adverse effects on groundwater quality --- in the breccia
zones *after* mining were to begin. Should mining cause changes in the
chemistry of groundwater leaving the breccia pipes, high-quality
groundwater that now supplies water to wells near Tusayan and to springs
and seeps in the Canyon could become contaminated. Restoration of the
original groundwater quality after mining is highly unlikely because of
the porous nature of the pipes themselves.

IV.C. Mining and Milling Wastes

Conventional uranium mines, including breccia-pipe mines, generate large
volumes of solid mining wastes: overburden, waste rock from the ore
zones, and low-grade ores that are not profitable for processing. These
wastes also contain trace metals and radioactive elements and must be
consolidated and controlled *during mining operations* to prevent
releases to adjacent lands, arroyos and alluvial groundwater systems.
After mining has ended, these wastes must be consolidated, covered and
armored to protect against erosion from water and wind. That mine wastes
present at the lower level of the Orphan Mine are the likely source of
high concentrations of uranium in Horn Creek is evidence enough of the
potential for breccia pipe mines to be significant sources of
radioactive and chemical contaminants to the Grand Canyon environment.

No new uranium milling capacity has been identified for the uranium ore
that would be produced from mines built by VANE Minerals, Liberty Star
or other companies seeking exploration permits around the Grand Canyon.
If mining is approved on Forest Service and Bureau of Land Management
lands without the necessary milling capacity to support it, uranium ores
would have to be stored on or near the mining sites. Storage of uranium
ore in the open environment could lead to contaminant releases to
surrounding lands and water resources.

[V. Conclusions and Recommendations]{.underline}

Uranium mining in the Four Corners Area has been, and in many cases
continues to be, a source of widespread environmental contamination and
potential public health risk for residents of communities where mining
was conducted. Reclamation of abandoned mines has been the *exception*,
not the rule, for many mining companies, even those operating under new
regulations. Certainly, uranium mining practices have improved since the
1970s, as evidenced by the fact that companies that operated mines in
the Arizona Strip appear to have reclaimed significant portions of their
mine sites. But the fact is that mining disturbs the land and landscape
in irreversible ways, even when controls are in place. Reclamation of
mines only *mitigates* their long-term effects; it does not *eliminate*
them, or return the land to its original conditions. Water quality,
wildlife, native plants and the ecosystem at large are permanently
*altered* by mining.

As predicted by some scientists, new mining may *not* leave noticeable
scars on the landscape, commit large tracts of land to waste disposal,
or adversely affect groundwater and the hundreds of springs that breathe
life to the Canyon's plant and animal life. But if mining *does* detract
from the recognizable vistas, require commitment of land for long-term
waste management, and adversely impact water quality, those impacts are
likely to be irreversible. In that case, then, the conditions attendant
with proposed uranium mining around the Grand Canyon warrant evoking the
1998 Wingspread Statement on the Precautionary Principle. (See
<http://www.sehn.org/precaution.html>.) The principle reads:

> \"When an activity raises threats of harm to human health or the
> environment, precautionary measures should be taken even if some cause
> and effect relationships are not fully established scientifically. In
> this context the proponent of an activity, rather than the public,
> should bear the burden of proof. The process of applying the
> precautionary principle must be open, informed and democratic and must
> include potentially affected parties. It must also involve an
> examination of the full range of alternatives, including no action.\"

Based on my experience observing the uranium industry, I believe there
is *more uncertainty* than not that new mining operations would be
conducted safely and in compliance with all applicable rules and
regulations. The industry's track record, despite its assurances to the
contrary, speaks loudly here. Accordingly, withdrawing Forest Service
and BLM lands from mineral development contiguous to some of the most
sensitive areas of the Grand Canyon is prudent policy to protect the
natural resources that give the Canyon its global reputation ---
sparkling water from springs and seeps, unspoiled vistas revealing
hundreds of millions of years of Earth's history, unique flora and
fauna, and the remarkably sustainable cultures of the First People who
have called the Canyon home for a millennium or two.

REFERENCES

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Laboratory and Field Techniques: Applications to Grand Canyon, Arizona.
Thesis paper, master of science degree in geology, Northern Arizona
University, AE Springer, committee chair; May.

Aguirre Engineers, Inc., 2001. Letter from JR Ward to S Mulligan,
National Park Service, transmitting data for Lost Orphan Mine, AEI
Project No. 30031, April 10.

AGFD, 2007. Arizona Game and Fish Department and Commission. Uranium
Mining Activities, Past and Present. May.

Billingsley, 2000. GH Billingsley. Geologic Map of the Grand Canyon 30'
x 60' Quadrangle, Coconino and Mohave Counties, Northwestern Arizona.
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1.0.

Day and others, 1981. GJ Day, JG Sepulveda, RJ Jackson. Report of
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November 5-7.

deLemos and others, 2007. JL deLemos, M Menache, D Brugge, G Durant, B
Bostick, T Rock, C George, J Lewis. Geochemical controls on uranium
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Health Association Annual Meeting (Washington, DC), November 7.

Fitzgerald and others, 1997. JK Fitzgerald, DK Kreamer, KH Johannesson,
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thesis.

GCNP, 2003. Grand Canyon National Park. "Native Waters," National Park
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Harding Lawson Associates, 1993. Phase I Preliminary Assessment, Orphan
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0000036 et seq.

Harding Lawson Associates, 1996. Draft Risk Assessment/Engineering
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Park, Arizona. December 20.

Huntoon, 2000. PW Huntoon. Large-Basin Ground Water Circulation and
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Mountain Association of Geologists, 33(3): 71-84, July.

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Health Association Annual Meeting (Washington, DC), November 7.

Mazzu and Rihs, 1995. LC Mazzu, J Rihs. Final Report: Intensive
Reconnaissance Sampling of Grand Canyon Tributaries, Grand Canyon
National Park. National Park Service (Grand Canyon, Arizona).

Pasternak, 2006. J. Pasternak. "Blighted Homeland": Four-part series on
Navajo uranium mining. *Los Angeles Times*, Nov. 19-22, 2006.

Ross, 2005. LEV Ross. Interpretative Three-Dimensional Numerical
Groundwater Flow Modeling, Roaring Springs, Grand Canyon, Arizona.
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[^1]: Funded in part by Grant Nos. R25 ES013208, RO1 ES014565, P30
    ES012072 from the National Institute of Environmental Health
    Sciences.

[^2]: Partners in the DiNEH Project are the Eastern Navajo Health Board,
    Southwest Research and Information Center, University of New Mexico
    Community Environmental Health Program, Crownpoint Service Unit of
    the Indian Health Service, and University of Texas-Houston Medical
    School.

[^3]: ISL "mining" is actually a form of uranium processing, and as
    such, is regulated by the Nuclear Regulatory Commission pursuant to
    the Atomic Energy Act of 1954, as amended, and by the U.S.
    Environmental Protection Agency pursuant to the Safe Drinking Water
    Act, as amended. Uranium mining in breccia pipes is considered
    "conventional" underground mining and would be regulated only under
    federal land-use statutes and/or state or tribal mining statutes.

[^4]: Not all lenticular sandstone rocks are amenable to ISL mining,
    especially those that are highly fractured, are discontinuous over
    short distances and areas, or have been intruded by volcanic or
    other igneous has rarely exceeded 1,000 feet below land surface.
    Other problems plague uranium ISL mining, including the failure of
    virtually all commercial ISL projects to restore groundwater quality
    to *pre-mining conditions*, without regulatory intervention to relax
    restoration standards.