Location
The Section 27 Mine site is located in Section 27, Township 14N, Range 9W of the New Mexico Principal Meridian and is approximately 17 miles north of Milan, New Mexico
Ownership and History
The United Nuclear Corporation (UNC) operated the Section 27 Mine as an underground uranium mine between 1970 to 1977. The Section 27 Mine was an underground, conventional room and pillar mine that intercepted groundwater. Pumping groundwater was required to develop the underground mining operation. The mineral lease covered approximately 200 acres. A private party holds surface ownership at the mine and Hecla Mining Company holds ownership of the mineral estate. UNC surrendered the mineral lease in 1988 and conducted closure activities in the same year. However, the owner of the leased portion of the site did not provide UNC permission to conduct reclamation on the leased areas. In 1996, UNC was acquired by General Electric (GE), and UNC continues to oversee the reclamation of its former sites, including the Section 27 Mine (pending access).
Reclamation & Regulatory Jurisdiction
UNC conducted initial closure activities of the Section 27 Mine in 1988, which included removal of stockpiled ore, buildings, and machinery, as well as sealing shafts and vents. UNC also conducted voluntary reclamation activities at all of UNC’s land holdings in Section 27, except on the leased lands where access to the site has been denied by the landowner.
NMED
In August of 2004, the New Mexico Environment Department (NMED) sent a letter to UNC that an Abatement Plan was required for the Section 27 Mine Site. The decision was based on water quality results and site inspections conducted from 1997 to 2004 that indicated that groundwater was impacted. Between November 2005 and September 2006, UNC drafted and finalized the Stage 1 Abatement Plan Proposal. On October 13, 2006, NMED conditionally approved the work plan in the proposal.
The Stage 1 Abatement Plan Proposal was fully approved February 12, 2010. Additionally, the company submitted annual reports for five years (2010 to 2015) and requested an adjustment to the approved sampling program, for which they received NMED’s approval in June 2015. In the 2019 annual groundwater report, UNC stated groundwater monitoring would not continue. NMED responded in a letter dated January 12, 2021, that monitoring shall continue as approved. Communications between NMED and UNC on abatement began again with a letter dated October 14, 2022. In the letter, NMED requested UNC submit a Stage 2 Abatement Plan proposal. Negotiations between NMED and UNC continue on the submittal of a Stage 2 Abatement Plan Proposal.
Regulatory Tracks
- No discharge permits are registered with NMED.
- Under NMED, Section 27 Mine is regulated under an abatement plan, which addresses remediation of groundwater impacts, and long-term groundwater monitoring.
- UNC/GE is required to submit a Supplemental Closeout Plan.
EMNRD-MMD
In July 2003, the New Mexico Department of Energy, Minerals, and Natural Resources (EMNRD) Mining and Minerals Division (MMD) received a Permit Application and Site Assessment from UNC followed by the submittal of a Closeout Plan in January 2004. Based on MMD and EMNRD comments, UNC submitted a Revised Closeout Plan to MMD in August 2008 and a Supplement to the Closeout Plan in November 2008. MMD approved a reclamation-only permit (Mining Act Permit No. MK005RE) including the Closeout Plan in October 2009. In April 2010, UNC initiated reclamation in accordance with the approved Closeout Plan.
In May 2010, MMD discovered additional surface radiological contamination within, outside, and adjacent to the permit boundary that was not characterized in the previous site assessments. In June 2010, MMD sent a letter to UNC requiring the Closeout Plan be amended to reclaim the additional radiologically contaminated areas consistent with the Reclamation Plan for the ore and ball mill reject piles. In an August 2010 letter, UNC rejected MMD’s request to amend the Closeout Plan for the additional radiologically contaminated areas. MMD sent a letter to UNC in September 2010 stating that if UNC did not amend the Closeout Plan that MMD would issue an appropriate order to comply. In October 2010, MMD received a letter from MWH Global Inc. on behalf of UNC including a Post-Reclamation Risk Evaluation for the Section 27 Mine that was followed by a letter in June 2011 with a Supplemental Characterization Survey Results Report. Also in June 2011, UNC applied for permit modification including a Supplemental Closeout Plan to MMD. MMD deemed the application administratively complete and began a technical review of the application under Modification 11-1. In March 2016, MMD and NMED drafted a “Joint Guidance for the Cleanup and Reclamation of Existing Uranium Mining Operations in New Mexico” (Joint Cleanup Guidance). The Joint Cleanup Guidance Radiation Cleanup Criteria for Existing Uranium Mines mirrors the U.S. Environmental Protection Agency’s Uranium Mill Tailings Radiation Control Act “5/15 standard.”
In February 2018, MMD sent UNC comments on the Supplemental Closeout Plan indicating that UNC should revise the plan to meet the Joint Cleanup Guidance Radiation Cleanup Criteria. In June 2018, UNC sent a letter in response to comments MMD made on the plan. UNC refused to apply the Joint Cleanup Guidance to the Supplemental Closeout Plan with respect to soil cleanup levels.
In a letter dated July 20, 2023, UNC agreed to submit a Supplemental Characterization Workplan for Surface Reclamation, to be conducted under a Supplemental Closeout Plan. The reclamation goal is to fully release permits with completed groundwater abatement and long-term monitoring. Currently, an updated Closeout Plan is needed for the next step.
MMD is currently awaiting submittal of a Supplemental Closeout Plan for this site that is in accordance with the Joint Guidance for the Cleanup and Reclamation of Existing Uranium Mining Operations in New Mexico. UNC has agreed to submit the initial Characterization Workplan as a next step in this process. This workplan is currently due according to the schedule UNC provided, but it has not been submitted to MMD as of the writing of this report.
Timelines for the Completion of Cleanup Activities
NMED and MMD are working with UNC to develop a path and implementation schedule for outstanding activities at the site.
Coordination Between State and Federal Agencies
The Section 27 Mine is predominately regulated by two State of New Mexico Agencies; NMED and EMNRD-MMD. Section 27 Mine is not regulated by the Nuclear Regulatory Commission nor the Department of Energy.
Anticipated Funding Requirements
Funding for all site reclamation, abatement, remediation, and long-term monitoring actions regulated by NMED and MMD are covered by UNC, the responsible party for the Section 27 Mine. There is no anticipated funding needed from the state or other entity for the Section 27 Mine. UNC is responsible for all costs associated with closure and abatement. MMD holds $377,000 of financial assurance on this site.
Disclaimer
Site reviews in this report provide the reader with a general history and status of permitted mines and mills. For brevity, they may not provide all relevant details or agency actions related to each site.