6. Reclamation implementation

(September 1995) Before any work for the long term management of the mines, waste piles, and mill tailings can be started, a comprehensive investigation of the environmental impacts that have already occured, and of potential future hazards must be carried out.

The reclamation goals must be defined in parallel. Since the health of the residents living in the area now, and of future generations is affected, the fundamental requirements can only be defined by legislation, not by regulations issued by agencies, nor by any commissions without a legal mission.

Based on the legal provisions for the reclamation goals, the reclamation concepts can be elaborated. These must undergo a critical review, including participation of the public, concerned communities, independent experts and environmental organizations, before the decision between various management options is made, and the concepts are realized.

During the first phase of investigations and planning, only such steps should be undertaken that are necessary for protection from immediate hazards, and respective of not interfering with long-term management. These include the as-complete-as-possible collection and treatment of all seepage, or the location and collection of contaminated material outside the site borders.

In Germany, the reclamation of the uranium mining legacy in the Eastern German uranium district is not subject to the nuclear law. Therefore, no public hearings take place, as are known with other nuclear projects. Neither are environmental organizations involved in the decision processes, as is known with other large-scale projects of environmental importance; so far, they were only invited to give their comments on the decommissioning concept for the Königstein mine, since this is located in an environmental conservation area.

Another problem is the access to environmental data gathered about the aftermath of uranium mining. For those sites that are still owned by Wismut, the data is gathered by Wismut itself; for those sites that were returned to the local authorities before 1962, the Federal Radiation Protection Agency (BfS) performs the monitoring. For its sites, Wismut only publishes rather general annual reports, while BfS has not yet published any results at all. In other countries, such as Poland and Rumania, all information concerning uranium mining is still subject to secrecy.

In each country concerned, the legal basis for reclamation must be created, since the existing legal regulations are insufficient in all European countries. This should be done cooperatively to insure uniform standards. The basic requirements for reclamation must be laid down in law:

Reclamation goals

• Definition of the categories of persons to be protected (it is not sufficient to protect the average healthy adult; children and the sick must also be considered; moreover, the protection of future generations has to be assured),
• Definition of the acceptable excess health risk caused from the uranium mining legacy,
• Definition of the period of time, the reclamation to be carried out has to be efficient in the long-term,
• Provisions to assure authorization only for those reclamation options requiring no active maintenance,
• Fixing of a time limit for completion of the reclamation action.

Compensation claims

• for miners, residents, concerned communities

The details can then be fixed in regulations:

Standards for systematical site monitoring

• Type and extent of the site investigations, monitoring data acquisition, contaminants to be monitored, monitoring periods, etc.
• Quality assurance for the monitoring program

Rules for ranking of hazards

• Set clear priorities in case that reclamation actions have to be deferred due to lack of funds

Dose limits

• Dose-effect ratios to be used for calculation of derived dose units
• Dose limits corresponding to the acceptable excess health risk defined above
• Calculation rules for computing the radiation doses

Reclamation standards

• Standards for the continued release of contaminants (radon exhalation from surfaces, contaminant releases with waste water, dust releases, gamma radiation,...)
• Contamination standards (radon concentrations in free air and in dwellings, contaminant concentrations in soils and groundwater, surface contamination for unrestricted reuse of metal scrap and construction rubble...),
• Determination of measures that are regarded suitable to ensure the confinement of the contaminants during the whole period defined as the long-term protection goal,
• Standards for stability against seismic events, flood, and erosion,
• Determination of measures for the quality assurance of the whole reclamation process,
• Determination of measures for eventual necessary maintenance,
• Determination of measures for long-term monitoring and its financing

Administrative responsibilities and procedures

• Definition of the responsibilities of Federal and State Agencies for the licensing process of the reclamation,
• Definition of the licensing procedures,
• Definition of the legal process

Public participation

• Ensuring free access to all relevant information,
• Ensuring public participation during the planning stage, during the licensing procedure (hearings), and for supervision of the action being taken,
• Supply of funds, to enable concerned individuals, communities, and associations to contract experts of their choice.

Wismut receives DM 700 - 800 million (US$ 500 - 570 million) annually from the German Federal Budget for its reclamation efforts so far. But, Wismut is only responsible for the reclamation of those sites that were not returned to the local authorities before 1962. The communities are responsible for the other sites, but they are not nearly able to pay for their reclamation. The communities should therefore receive compensation for their former Wismut sites from the Federal Budget. This position is also supported by an expert analysis ordered by the Saxonian State Ministry of Environment. At present, the State Ministry is searching for a community that could sue the Federal Government for paying its reclamation cost.

Unlike Germany, most other countries in Central and Eastern Europe, do not nearly have enough funds required for the reclamation of the uranium mining legacy. In some cases, as in the Czech Republic, preparations are at least made for an analysis of the problems and possible management options. The European Union is now obviously willing to contribute to the solution of these problems in the Central and East European countries under its PHARE program [NF Sept. 26, 1994].