Ten-Year Plan to Address Impacts of Uranium Contamination in the Navajo Nation


TEN-YEAR PLAN

Federal Actions to Address Impacts of Uranium

Contamination

2020-2029

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TABLE OF CONTENTS

Executive Summary	

History	

Timeline	

Abandoned Uranium Mines	

UMTRCA Sites	

Contaminated Structures	

Water	

Drinking Water	

Tuba City Dump Site	

Health	

Community Involvement	

Navajo Workforce Development
Agency Authorities/Roles

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EXECUTIVE SUMMARY

The federal government continues to address the legacy of uranium contamination on the Navajo Nation.
This Ten-Year Plan builds on the work of the two previous Five-Year Plans (2008-2012 and 2014-2018),
including theTronox Addendum to the 2014-2018 Five-Year Plan.This plan makes adjustments based
on information gained during the previous Five-Year Plans and identifies the next steps in addressing
the human health and environmental risks associated with the legacy of uranium mining on the Navajo
Nation.

The Navajo Nation is actively engaged in all aspects of this work, and the accomplishments would not be
possible without the involvement of the Navajo Nation Office of the President and Vice President, Navajo
Nation Council, Navajo Nation Environmental Protection Agency (NNEPA), Navajo Nation Abandoned
Mine Lands Reclamation Program (Navajo A ML), Navajo Nation Uranium Mill Tailings Remedial Action
Department (UMTRA), Navajo Nation Department of Health (NNDOH), Navajo Department of Justice,
Chapter officials, community members, and other organizations.

The following federal partners will work with the Navajo Nation to implement this plan: the
Environmental Protection Agency (EPA), Department of Energy (DOE), Nuclear Regulatory Commission
(NRC), Department of Interior's Bureau of Indian Affairs (BIA), Indian Health Service (IHS), and Agency for
Toxic Substances and Disease Registry (ATSDR). While the past 10 years represent a significant start in
addressing the legacy of uranium mining and milling on the Navajo Nation, much more work remains.

1

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SUMMARY OF GOALS FOR THE NEXT TEN YEARS



Abandoned
Uranium Mines

Contaminated
Structures

Drinking Water

EPA will work with the Navajo Nation toward completing the
investigation and cleanup at the 230 mine sites where EPA and the
Navajo Nation have secured funding or a commitment to perform
work,

EPA will work with the Navajo Nation to bolster the capacity of
Navajo Nation agencies, including NNEPA and Navajo AML, to
perform assessments, cleanups, and the long-term operation and
maintenance of cleanups at abandoned uranium mine sites.

EPA will continue to coordinate closely with the Navajo Nation to
ensure traditional ecological knowledge and Dine Fundamental Law
are incorporated in the CERCLA decision making process.

DOE will work with EPA and the Navajo Nation to perform
verification and validation and to safeguard hazardous mine
openings as required at the unfunded abandoned uranium mine
sites located on the Navajo Nation.

DOE, under NRC oversight, will continue long-term groundwater
remediation, monitoring, surveillance and maintenance activities at
Tuba City Site, the Monument Valley Processing Site, Mexican Hat
Site, and Shiprock UMTRCA Title 1 Sites.

DOE will assess the need for a corrective action at the Mexican Hat
site and, if needed, work with the Navajo Nation and NRC to develop
and implement a corrective action plan.

EPA will work with NNEPA to conduct radiological assessments
at structures that meet program criteria and implement removal
actions where contaminated structures and surrounding soils are
found to pose a risk to residents.

Multiple studies will be conducted to investigate the potential
impacts of abandoned uranium mines on surface water and
groundwater. This will include studies at the Claim 28 mine in the
Tachee-Blue Gap chapter and the Saytah/George Simpson 1 Incline
mine in theTolikan chapter.

EPA will coordinate closely with NNEPA to ensure that cleanup
options implemented at abandoned uranium mine sites are
protective of surface water and groundwater.

1HS and EPA will continue to increase access to safe drinking water
in the abandoned uranium mine regions of the Navajo Nation by
funding high-ranking water infrastructure projects with available
funds.

2

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SUMMARY OF GOALS FOR THE NEXT TEN YEARS



Tuba City
Dump

Subject to Congressional funding and Hopi Tribal and Navajo
Nation consensus, 61A will begin waste removal at the Tuba City
Dump, implementing the cleanup option which currently involves
the removal of the Tuba City Dump waste to a newly constructed
repository.

Health



IHS will continue to support community-based services, including
health education, medical screening evaluations, assuring
continuity of care for affected individuals, and community-based
cancer screening.

IHS will collaborate with NNDOH Epidemiology Program on studies
including evaluation of cancer cases by geographic location and
known radiation exposure sources, evaluation of health status
of descendants of uranium miners/mill workers, and design and
establishment of a longitudinal human health impact study,

ATSDR and IHS will coordinate to provide training including
coordination with NNDOH to develop materials and provide training
to community health representatives-

Community
Involvement

Federal partners will work together to expand community outreach
through increased communication and coordination about uranium
issues, particularly focused on abandoned uranium mines and
former uranium mills and how each agency addresses and provides
services regarding uranium issues.

Navajo

Workforce

Development

Through contracts, grants and training, EPA will strive to build the
capacity of the Navajo Nation workforce and businesses to perform
investigation and cleanup work at mine sites.

3

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SUMMARY OF ACCOMPLISHMENTS (2008 - 2019)

%/y

Protecting Human Health and the Environment at Abandoned Uranium Mines
and Former Uranium Ore Processing Mill Sites

523

Q,

113

i-IX 4

a

Mines completed
preliminary site screens

230

$

to*i n u s assessed to determine
amount and extent of
contamination. If any.

Mines funded through
enforcement agreements
and settlements valued at
51,7 billion
and

11

Vine; have an Engineering
Evaluation/Cost Analysis, one
has been completed and ten are
in review.

16

MI I ion Dollars in grants to Navajo Nation.

Ongoing Site Remediation*
conducted at former uranium
mill sites including
groundwater investigations at
multiple sites and disposal cell
long-term surveillance and
monitoring.

1 Design Plan completed for
Northeast Church Rock mine
cleanup.

Mill Site Analyses used
technical applications such
as computer simulated
groundwater flow models,
radiological assessments of
stained soils, and installation
of meteorological weather
stations.

Addressing Water Issues and Contaminated Structures

3809

%

Hon provided access
to piped water in the six
abandoned uranium
mine regions.

~4*

Watershed Assessment
completed in the Cove Wash
area, which contains 42
abandoned uranium mines.

fjfo 1100+

Water studies obtained
funding through U-S-/Navajo
Phase 2 settlement, including
Claim 28.

Structures assessed for
contamination arid

50+

i - ¦ were remediated.

Conducting Health Studies and Coordinating Outreach and Education

740

90

15

O

20+

W

Mother-infant pairs
participated in the Birth
Cohort Study to identify
health outcomes in a
population exposed to
uranium.

Community Health
Representatives trained by
the Navajo Nation
Department of Health,

with completed
Community Involvement
Plans that cover 193
abandoned uranium
mine sites.

Outreach events organized by
the interagency Community
Outreach Network to enhance
community understanding of
the multi-agencies work to
address uranium contamination
on the Navajo Nation.

Providing Economic Opportunities

8

W

Navajo Owned Businesses
received grants or contracts to
contribute to the work,

200+



Job', provided to Navajo
members.

30+

$nrrl

Internship provided to study
impacts of uranium issues.

4

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The Navajo Nation encompasses more than 27,000 square miles in the Four Corners area of Arizona
(AZ), New Mexico (NM), and Utah (UT).The unique geology of the region renders the Navajo Nation
rich in uranium, a radioactive ore in high demand after the development of atomic power and weapons
at the close of World War II in the 1940s. Approximately 30 million tons of uranium ore was extracted
during mining operations on or near the Navajo Nation from 1944 to 1989. The federal Atomic Energy
Commission was the sole purchaser of uranium until 1966. The Atomic Energy Commission continued to
purchase ore until 1970, although sales to the commercial industry began in 1966. Many Navajo people
worked at the mines and mills, often living and raising families nearby.

Uranium mining and milling activities no longer occur on the Navajo Nation, but the legacy of these
activities remains, including the presence of abandoned uranium mines, former mill sites, and homes
built with mine and mill waste. Elevated uranium and other elements are associated with mine and mili
sites, although the same elements also occur naturally at elevated levels in rock, soil, surface water, and
groundwater across the Navajo Nation and the broader Four Corners region. Health effects from exposure
to these elements can include lung cancer and impaired kidney function.

Among Navajo miners, millers, and their families, the health consequences of uranium mining and milling
have been widespread. In 2000, Congress expanded the Radiation Exposure Compensation Act to provide
monetary compensation to individuals who had been diagnosed with certain cancers and other serious
diseases due to their exposure to radiation while employed in the uranium industry. Over 1,431 claims
have been awarded on behalf of Navajo uranium miners, millers, and ore transporters for illnesses tracing
to occupational radiation exposure.

At a hearing held in October 2007, representatives of the Navajo Nation delivered testimony before the
United States House Committee on Oversight and Government Reform on the impacts of uranium mining
and milling on the Navajo Nation. At this hearing, the committee requested that EPA, along with BIA, NRC,
DOE, and IHS, develop the first Five-Year Plan (2008-2012) as part of a coordinated effort among federal
agencies to address uranium contamination. The National Center for Environmental Health (NCEH) and
the Agency forToxic Substances and Disease Registry (ATSDR) also contributed to health objectives.The
agencies prepared a second Five-Year Plan (2014-2018), building on the work in the previous plan.This
Ten-Year Plan (2019-2028) represents the federal government's commitments to continue working with
the Navajo Nation to reduce health and environmental risks and find long-term solutions to remaining
uranium issues on the Navajo Nation. As with prior plans, the federal agencies conducted government-to-
government consultation with the Navajo Nation during the development of this Ten-Year Plan.

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• Uranium discovered
on the Navajo
Nation, resulting
in mining of more
than 30 million tons
of ore

Atomic Energy
Commission created,
and becomes sole
purchaser of uranium
ore for defense-related
purposes

A rush to mine
uranium begins in
many areas of the
Navajo Nation

Shiprock mill begins
processing uranium
ore

Monument Valley
mill begins processing

Tuba City mill begins
processing ore

Mexican Hat mill begins
processing uranium ore
and copper

Mexican Hat mill ceases
operation

•	Tuba City mill ceases operation

•	A tomic Energy Commission
announces that it will stop
purchasing ore in 1970, and sales
to the nuclear po wer industry
begins

Monument
Valley mill ceases
operation

Shiprock mill ceases
operation

1940s

1947

1950

1954

1955

1956

1957

1965

1966

1968

Atomic Energy
Commission stops
purchasing uranium ore,
and the nuclear power
industry becomes the
sole purchaser of milled
uranium

EPA created

Congress enacts National
Environmental Policy Act

1970

Navajo

Environmental
Protection
Commission created

Atomic Energy
Commission
abolished and
Energy Research
and Development
Administration and
U.S. NRC created

NRC created with
a mission that
includes regulation
of nuclear materials

1972

1974

1975

Energy Research
and Development
Administration
dissolved and DOE
created

1977

Uranium Mill Tailings Radiation
Control Act establishes
the federal government's
requirements for the cleanup of
inactive uranium milling sites
and the long-term care and
management of legacy and
active uranium milling sites

United Nuclear Corporation's
Church Rock uranium mill spills
waste into the Puerco River, the
largest radioactive spill in U. S.
history

' Congress enacts the Comprehensive
Environmental Response,
Compensation, and Liability Act
(CERCLA), commonly known as
Superfund

> ATSDR created to implement health-
related sections of laws that protect
the public from hazardous wastes

CERCLA amended to increase focus
on human health problems posed by
hazardous waste sites and to encourage
greater citizen participation in decisions
regarding how to clean up sites

DOE completes surface remediation of
the former Shiprock mill and continues to
monitor the site

NNAML created

Last uranium mine
near the Navajo Nation
closed

NNAML begins addressing physical
hazards at abandoned uranium
mines

DOE completes Tuba City mill site
surface remediation and continues
annual inspections
EPA conducts interim removal
actions at five uranium mines in
eastern Navajo Nation
Congress enacts Radiation
Exposure Compensation A ct

¦ Congress convenes
joint hearing on
uranium waste on
the Navajo Nation

EPA investigates mines and
conducts an aerial radiation
survey in the King Tutt Mesa
area of the Red Valley Chapter

DOE transfers the Monument
Valley mill material to
Mexican Hat and completes
surface remediation in Cane
Valley; and continues annual
groundwater sampling at the
Monument Valley UMTRCA
Title I Former Processing site

Navajo Nation
Environmental Protection
Agency created

DOE completes Mexican
Hat mill site remediation,
determines no groundwater
monitoring is required, and
annual inspections continue
at the UMTRCA Title I
Disposal site

EPA develops a three-step process to
investigate abandoned uranium mines
on the Navajo Nation, including aerial
radiation surveys, water sampling, and
surveys of potentially contaminated
homes

DOE conducts aerial radiation survey of
1,144 square miles of the Navajo Nation
over a three-year period

1 U.S. Army Corps of
Engineers begins
sampling water
sources in areas of
abandoned
uranium mines
and at potentially
contaminated
structures on the
Navajo Nation

1978

1979

1980

1986

1988

1989

1990

1993

1994

1995

1997

1998

•	U.S. Congress expands
the Radiation Exposure
Compensation Act (RECAj

' Navajo Superfund Program
created

•	EPA publishes the Navajo
Abandoned Uranium
Mines Project Atlas

' EPA, NNEPA, and NNAML
embark on a project
to identity and locate
uranium mines on the
Navajo Nation, and
gather information about
the mines and potential
impacts

EPA develops the
Abandoned Uranium
Mine Project
Management Plan
in partnership with
NNEPA

DOE begins
groundwater
remediation at the
Tuba City UMTRCA
Title I Disposal site

DOE begins
groundwater
remediation at the
Shiprock UMTRCA Title
I Disposal site

A domestic water
supply system is
installed to provide
potable water to all
Cane Valley residents.
The project was jointly
funded between IHS
and DOE

EPA publishes the
Navajo Abandoned
Uranium Mine
Screening Assessment
Report and Atlas with
GeospatialData

U.S. House Committee
on Oversight and
Government Reform
convenes hearing on
legacy of uranium
mining on the Navajo
Nation

Navajo Nation CERCLA
statute enacted

First Eive-Year Plan
created by EPA, DOE,
NRC, M, and IHS
< EPA removes waste
from Skyline mine that
had migrated near
homes

' At the Northeast
Church rock Mine,
between 2009 and
2012, over200,000
tons of contaminated
material is removed
from a residential
area and returned to
the mine site for safe
storage

' EPA filed a claim
in the Tronox
bankruptcy that
yielded $13 million
in the initial
settlement

> ATSDR initiates
the Navajo Birth
Cohort Study,
first prospective
epidemiologic
study of pregnancy
andneonatal
outcomes in a
uranium-exposed
population

Second Five-Year Plan
created by EPA, DOE,
NRC, BIA, IHS, and
ATSDR

U.S. Government
Accountability Office
issues report on the
federal government's
progress to implement
the Five-Year Plan

DOE published
Defense-Related
Uranium Mines Report
to Congress

Tronox bankruptcy settlement provides 51
billion to clean up more than 50 abandoned
uranium mines on or near the Navajo Nation
Community Outreach Network created by
ATSDR, BIA, DOE, EPA, IHS, NRC, NNEPA,
NNAML, and NNDOH
The Navajo Nation approves creation of
the Dine Uranium Remediation Advisory
Commission

Phase 1 Settlement Agreement by and
among the United States of America and the
Navajo Nation

' Phase 2 Settlement Agreement
by and among the United States
of America and the Navajo
Nation

< DOE completes pilot studies
to remediate contaminated
groundwater at the former
Monument Valley mill
> DOE establishes Community
Outreach Office

United States and the Navajo Nation
enter into a settlement agreement
with Cyprus Amax and Western
Nuclear to clean up 94 mines

EPA awards first multimillion dollar
Tronox contract to a Navajo-owned
business

EPA awards $85 million contract to
assess abandoned uranium mine
sites on the Navajo Nation

DOE establishes the Defense-Related
Uranium Mines (DRUM) program and
begins Campaign # 1, inventorying
mines on public land

First meeting of the Dine Uranium
Remediation Advisory Commission
EPA awards a nearly $ 1 million
contract to a Navajo-owned business
Design of the Northeast Church Rock
mine completed
The A [SDR funded Birth Cohort
Study was completed; the study
has transitioned to the National
Institutes of Health's Environmental
Influences on Child Health Outcomes
(ECHO) Program

• EPA completed 85
mines assessments
(Removal Site
Evaluations) and
time-critical actions
at nearly 30 mines
' Community
Outreach Network
began conducting
Uranium 101 at
Chapter Houses
«Groundwater
remediation
continues at Tuba
City and Shiprock

2000	2002	2003	2007	2008	2009	2010	2014	2015	2016	2017	2018	2019

6

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The Phase 1 Trust (16 Mines)
The Phase 2 Trust (30 Mines)

Cyprus Amax/Western Nuclear (94 Mines)
1 Tronox (55 Mines)

Abandoned Uranium Mines
on and Near Navajo Nation

Navajo Nation Boundary

N

a epa

Private Companies (37 Mines)
All Other 304 Mines

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7

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BACKGROUND

EPA and NNEPA have identified 523 abandoned uranium mines on or near the Navajo Nation, with more
than 1,000 mine features such as rim strips, mine openings, and waste piles.This includes 485 abandoned
uranium mines on the Navajo Nation and 38 abandoned uranium mines within 1 mile of the Navajo Nation
in the neighboring states of New Mexico (30 mines), Arizona (6 mines), and Utah (2 mines). Since 1989,
Navajo AML conducted significant reclamation at many of the sites on the Navajo Nation, but their work
did not include fully assessing and mitigating risks related to radiation exposure. From 2008 through
2012, EPA conducted screening level assessments of the 523 abandoned uranium mines. Based on these
assessments, EPA and NNEPA prioritized 46 mines, including 43 mines with elevated radiation levels near
where people live and 3 mines that may affect water resources.

By the end of 2019, detailed assessments were completed at 113 mines, which included 43 priority mines
near homes. Involving community members and other interested stakeholders is an important part of the
mine assessment and cleanup process. EPA Community Involvement Plans, developed with community
input, describe how EPA will provide Navajo Nation community members with accurate, timely, and
understandable information that is considerate of their communication preferences and culture.
Community Involvement Plans also document how EPA will coordinate with community members and
tribal leaders to ensure that EPA understands community concerns and considers community goals in its
decision-making process.

The Navajo Abandoned Mine Lands Reclamation Program closed portals like
the one shown here at the Charles Keith mine.

In 2016, EPA Community Involvemen t Coordinator spoke at a community
meeting about abandoned uranium mine work progress in the Cove area. Geoprobe taking soil samples 10 feet below the surface at the Mariano Lake Mine.

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ABANDONED URANIUM MINES:
SUMMARY OF ACCOMPLISHMENTS (2008-2019)

Assessm ent of
Abandoned Uranium
Mines with Detailed

Assessments
of those Most Likely
to Pose Environmental
or Health Problems



J EPA and Navajo Nation EPA entered into enforcement agreements and
settlements to assess and cleanup 230 of 523 abandoned uranium
mines on and near the Navajo Nation and an additional ISTronox mine
sites in the Grants Mining District of New Mexico.

S EPA, In coordination with Navajo Nation, completed field work
assessments of! 13 mines that provide information needed to
determine the extent and volume of contamination at these mines.

¦/ Preliminary assessments and site investigations were completed at
seven mines located in two watershed areas:

• Section 9 Lease at the Little Colorado River near Cameron, AZ; and
« Mesa I Mines 10 through 15 at Cove Wash near Cove, AZ.

¦/ Additional studies were conducted at Cove mines including water, crop
irrigation, and livestock study.

Advancements
toward cleanup
of the Northeast
Church Rock
Mine Site and
Additional High
Priority Abandoned
Uranium Mine Sites

y UNC/GE, under a Settlement Agreement with US6PA, completed the
Northeast Church Rock mine cleanup plan (Or "remedy") design.

¦/ UNC/GE submitted License Amendment Request and NRC has initiated
their safety and environmental reviews,

/ Time-critical actions at nearly 30 sites were completed, 14 of which are
priority mines, to reduce potential risks to human health of residents
near the abandoned uranium mines.

REPORT OF FUNDING

EPA and the Navajo Nation have secured funding to assess and clean up 230 of 523 abandoned uranium
mines on or near the Navajo Nation and an additional 16Tronox mines in the Grants Mining District of
New Mexico. This funding is largely derived from a combination of enforcement agreements and
settlements valued at over $1,7 billion.This amount includes funding from the United States secured
through settlements with the Navajo Nation (Trust Settlements) and through settlements with private
companies (Tronox Settlement). On top of this, EPA has consistently invested up to $5 million per year
toward investigating and cleaning up contaminated structures and supporting the involvement of Navajo
agencies in the assessment and cleanup process. The following table gives an overview of the estimated
total budget from all funding sources, approximate number of mines covered by each funding source,
and amount spent up until the end of 2019.

NAME OF AGREEMENT

FUNDING SOURCE

EPA ROLE

NUMBER
OF MINES

BUDGET

SPENT TO DATE

Tronox Settlement

Bankruptcy
Settlement

Lead

55

$1 billion

$41.2 million

Cyprus Amax and Western
Nuclear Settlement

U.S. Settlement with
Cyprus Amax and
Western Nuclear

Oversight

94

5670 million

$7.3 million

Trust Settlements

U.S. Settlement with
Navajo Nation

Oversight

46

521,8 million

$14.3 million

Settlement Agreements
with Private Companies

Enforcement
Agreements

Oversight

37

To be determined

$9.6 million*

EPA

US. Government
Appropriation

Lead

5

$4 5 million/yr

$29 million

• Thfcmm ttitf iepc««iSsfWs wtnigf* Mils to date.

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(§ SETTLEMENT AGREEMENTS

Funding or work commitments to assess and clean up mine sites are secured through enforcement
agreements with potentially responsible parties and settlements with the United States. Such
settlements have enabled EPA to leverage a relatively small contribution of federal funding to begin
the assessment and cleanup process at 230 of the abandoned uranium mines on and near the Navajo
Nation and 16 Tronox mines in the Grants Mining District of New Mexico.

Summary of Enforcement Agreements and Settlements Valued at Over $1.7 Billion

TRONOX
SETTLEMENT

When Tronox, a successor to Kerr-McGee, filed for bankruptcy in
2009, EPA and the Navajo Nation, among others, filed claims and
received settlements in the bankruptcy. The United States, on behalf
of EPA and other agencies, then filed a lawsuit against Anadarko,
another successor of Kerr-McGee, seeking additional funding for the
abandoned uranium mines. The United States and others involved
ultimately achieved a $5 billion national settlement in 2014, of which
EPA received almost $900 million for cleanup of more than 50
abandoned uranium mines associated with Kerr-McGee. This
includes 16 Tronox mines in the Grant Mining District of New
Mexico. In addition, EPA received close to $90 million for the Quivira
mine. The Navajo Nation received $44 million. The funds allocated to
EPA are mandated by the court to be spent by EPA to address
contamination at the abandoned uranium mines listed in the Tronox
settlement.

CYPRUS AMAX AND
WESTERN NUCLEAR
SETTLEMENT

The United States on behalf of EPA and other federal agencies
entered into a historic settlement with Cyprus Amax and Western
Nuclear in 2017 for the cleanup of 94 abandoned uranium mines on
the Navajo Nation. The settlement requires Cyprus Amax and
Western Nuclear to perform the work. The United States will pay
approximately half of all costs, including EPA and the Navajo Nation
Environmental Protection Agency oversight costs, through a trust
funded at $335 million. Cyprus Amax and Western Nuclear will fund
the other half of the work. This settlement has an estimated value of
$670 million.

SETTLEMENT
AGREEMENTS WITH
PRIVATE COMPANIES
{BABBITT RANCHES, BNSF,
CHEVRON, EL PASO
NATURAL GAS, ENPRO,
HOMESTAKE, UNITED
NUCLEAR CORPORATION)

PHASE 1

SETTLEMENT

PHASE 2
SETTLEMENT

EPA has entered into settlement agreements with seven parties to
assess contamination or take other removal actions at 37
abandoned uranium mines, and to install interim safety measures
such as fencing and signage. EPA intends to enter into additional
agreements to clean up the mines, as necessary. EPA funds the
Navajo Nation Environmental Protection Agency oversight of these
agreements via grants.

The Navajo Nation negotiated with the United States to address the
U.S. Atomic Energy Commission's role in developing historical
uranium mining on Navajo lands. As a result, the United States and
the Navajo Nation entered into two legal agreements {the Phase 1
Settlement in 2015 and the Phase 2 Settlement in 2016) that provide
funds to assess and clean up 16 "priority" mines (as needed), assess
an additional 30 mines, and conduct two water studies located on
the Navajo Nation. The Navajo Nation has selected Navajo trustees
to manage the trust funds and do the work under the oversight of
EPA and the NNEPA. The United States provided $13.2 million for the
Phase 1 settlement, and $8.5 million as the initial payment for the
Phase 2 settlement. The agreements also provide for payments of
the EPA and the NNEPA oversight costs. Both agencies have received
$800,000 as the initial amount for oversight costs.

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%s%

ABANDONED URANIUM MINE CLEANUP PROGRESS

EPA is addressing abandoned uranium mines on the Navajo Nation through EPA's Superfund program
in partnership with NNEPA's Superfund program. This section provides an outline of the Superfund
process and the status of work performed at the 523 abandoned uranium mines on or near the Navajo
Nation, including the 46 priority mines.

Navajo Abandoned Uranium Mine Superfund Progress
Status of the 230 Funded Mine Sites

193

113

2 JO mnes (wtr 40%) wit*

lo^il K)

•rid clwn up the mine*. < J

of ihtt* us priority maei

Community
lnvolv*ment Marts

(CBH)

f ff* C
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(^COMMUNITY INVOLVEMENT

The EPA Superfund Program places a high value on public participation during investigation and
cleanup of abandoned uranium mine sites. EPA believes that allowing communities to have a voice in
the decision-making process often leads to better environmental results.

The Community Involvement Coordinators (CIC) in the Superfund Division are the conduit between
Navajo communities and technical staff working on abandoned uranium mine projects on the
Navajo Nation. Working in coordination with NNEPA, CICs are assigned to specific projects to assist
communities in their interaction with EPA and ensure that technical staff are aware of issues that
concern the public in relation to the work EPA is doing. As liaisons between the community and
technical staff, CICs provide opportunities for two-way communication throughout the life of a
remediation project.

During the past five years, EPA has implemented several significant steps aimed at meeting the
following objectives:

Provide Navajo communities with accurate, timely, and understandable updates about EPA's
assessment and cleanup activities;

Educate Navajo communities about the Superfund process and translate risk assessment and
technical aspects of the cleanup process in the Navajo language;

Relay questions and concerns expressed by community members and local leaders for EPA to
consider in its decision-making process, including those related to reuse goals;

Develop fact sheets, flyers, and other communication tools related to site work;

Work with potential responsible parties and other entities that are lead for cleanup to assist in
communication and coordination between those entities, agencies, and community members;

Facilitate engagement with the Navajo Nation government; and

Support NNEPA's goal of implementing Dine Fundamental Law and consideration of the
Navajo traditional lifeway, traditional ecological knowledge, and laws of nature in the cleanup
process.

In 2017, EPA Community Involvement Coordinator discusses past mining activity and abandoned uranium mine concerns with a community member, the
information is captured in a Community Involvement Plan.

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In 2015, EPA hired two CICs with extensive knowledge of working with rural Navajo communities.
These CICs are from the Navajo Nation and are fluent in the Navajo language. Last year, the two CICs
were reassigned to work out of offices in Window Rock and Flagstaff, Arizona. This has given EPA
consistent presence on the Navajo Nation and significantly strengthened EPA's understanding of
community concerns, interests, and Navajo lifeways and EPA's ability to work with the Navajo Nation
government. The CICs are able to communicate effectively about the abandoned uranium mine
work with the communities and convey input from the community members for consideration in the
decision-making process.

EPA also develops Community Involvement Plans (CIP) for uranium-impacted communities on the
Navajo Nation.The CIP is a tool used to better understand the community, the Navajo culture, and
concerns from community members that are obtained through interviews.The CIP outlines specific
outreach activities to ensure that information sharing and dialogue regarding EPA's activities in that
community is participatory and meaningful. To date, EPA has finalized five CIPs for 193 of the mine
sites, encompassing 15 Chapters.

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LLJ

(§ ASSESSMENTS

From 2008 through 2012, EPA and NNEPA conducted screening level assessments of 523 abandoned
uranium mines (AUM). In coordination with the Navajo Nation, EPA developed criteria to prioritize
work at AUMs based on the ievel of radiation and proximity to homes and sensitive environments. This
screening-level assessment led EPA to focus initial efforts on conducting detailed assessments referred
to as removal site evaluations at 46 mine sites (referred to as "priority mine sites").

The purpose of a removal site evaluation is to determine the extent and volume of contaminated
material as a result of historical mining activities. This assessment includes collection of data related to
historical mining activities, obtaining access agreements, conducting biological and cultural surveys,
and implementing interim actions where needed to prevent radiation exposure (e.g., posting signs,
fencing around the mine site, and covering contaminated soil).Through settlement agreements, EPA
has secured funding and work commitments to perform detailed assessments of 230 of the 523 AUMs
on or near the Navajo Nation. At the end of 2019, detailed assessments were completed at 113 mine
sites, which included 43 priority mine sites.

Cove and Lukachukai Mines

From 1950 to 1967, uranium ore was mined throughout the Lukachukai Mountains in the Cove
and Lukachukai Chapters of the Navajo Nation. Uranium ore was stored at two transfer stations in
Cove before it was moved to a nearby mill to be processed.

There are over 50 abandoned uranium mines in this area,
including four priority mines. The Tronox settlement funds
31 of these mines and the transfer station, and the Cyprus
Amax settlement funds nine mines. In 2018, using Tronox
funds, EPA completed the field work for detailed
assessments at 31 Tronox-funded mines.This included a
completed Irrigation and Farm Plot Study, as well as an
ongoing livestock study to assess the potential exposure
pathways. EPA also partnered with Dine College to conduct
a Cove Wash Watershed Assessment.

Dine College Interns conducting Cove Stream Health
Survey

TseTah Mines Area

From the 1940s to 1960s, uranium ore was mined in the TseTah area of the Navajo Nation.
Beginning in the 1990s, the Navajo AML Reclamation Program addressed physical hazards at
these mines. Funds are available to assess and clean up 31 of the 38 abandoned uranium mines in
TseTah, 81 percent of the mines in TseTah, nine of which are priority mines. Funds to assess and
clean up the mines are provided by:

• Two legal settlements between Navajo Nation and the
United States for three mines;

• A legal settlement with Cyprus Amax for 27 mines; and

• The Tronox settlement for one mine.

Under the direction of EPA, detailed investigations are
complete at three of the mines and will be complete at the
other 28 mines by 2020. In 2019, a community liaison was hired
for the TseTah area to keep residents informed and engaged in '

1 u ~J Phase 1 Trustees team of experts assessing soil

the assessment and cleanup progress. samples at Tse Tah abandoned uranium mine.

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^TIME-CRITICAL ACTIONS

One of EPA's primary goals is to expedite risk reduction through implementation of time-critical
actions to control or minimize ongoing threats to human health and the environment in advance of
implementing a final remedy at a mine site. During the assessment phase, EPA may determine that a
time-critical action is appropriate and will take quick action to respond to an imminent threat of human
or ecological exposure and/or prevent further migration of contaminants or further environmental
degradation.

To date, time-critical actions have been performed at nearly 30 mine sites, 15 of these are priority
mines. This includes posting signs, erecting fences around areas of contamination, stabilizing mine
waste with covers, and consolidating mine waste in interim repositories.

El Paso Natural Gas Mines

From the 1950s-1960s, uranium ore was mined by different companies,

Gas, in the Cameron area of the Navajo Nation. While the Navajo AML
program addressed many of the physical hazards associated with these
mines, EPA and NNEPA are working to address remaining chemical and
radiological hazards that may pose a risk to community members.

including El Paso Natural

In 2013, EPA signed a legal agreement called an Administrative Order

on Consent with El Paso Natural Gas to assess 19 abandoned uranium c =?

mine sites in the western Navajo Nation, two of these are priority mines.

To inform residents of the dangers of being on or near the uranium

mines, El Paso Natural Gas conducted a time-critical action to post signs

near the mines to minimize the exposure risks. In 2019, the two priority

mines had detailed assessments completed.

Some mines may have signs, like this one,

located behind the Cameron Trading Post.

Skyline Mine

From 1944 to 1962, uranium ore was mined at the Skyline mine located on top of a mesa in
Monument Valley, Utah. As part of regular mining operations, a gondola was used to transport
ore from the Skyline mine to the foot of the mesa where it was loaded into trucks for transport.
During the late 1990s, portions of the Skyline mine on top of the mesa were closed by the Navajo
AML program. Due to the steep terrain, residual mine waste at the eastern edge of the mesa and
the bottom of the mesa were not removed during mine closure activities.

EPA has not been able to identify a potentially
responsible party but because this is one of the 46
priority mines, EPA has performed interim cleanup
actions to minimize exposure to contamination. In
2011, 25,072 cubic yards of uranium mine waste and
contaminated soils were excavated and transferred
to the on-site repository. In 2018, under an EPA
grant, Navajo Nation AML took actions to address
erosion issues at the on-site repository.

In 2011, EPA conducted an interim action at the Skyline mine to
remove uranium waste and transfer to an on-site repository.

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W DECISION MAKING

The next step after the assessment phase is completed is to make decisions that include an evaluation
of cleanup options. Evaluation findings are summarized in an Engineering Evaluation/Cost Analysis. In
partnership with government partners, including NNEPA, EPA uses the Engineering Evaluation/Cost
Analysis to evaluate and select a preferred cleanup option. EPA presents the Engineering Evaluation/
Cost Analysis and preferred cleanup option to the community during a public meeting, which is followed
by a public comment period. EPA uses this additional feedback from the community to select a cleanup
option and issue an Action Memorandum, which documents and reserves funding for the decision.The
Action Memorandum includes a response to the public comments received at the public meeting or
submitted in writing during the comment period. In addition to the public comment period, a formal
consultation with the Navajo Nation takes place presenting and receiving input on the preferred
alternative.

In 2009, EPA completed the first Engineering Evaluation/Cost Analysis report at the Northeast Church
Rock mines. In 2019, four more Engineering Evaluation/Cost Analysis draft reports were completed
covering a total nine mines at Mac and Black Jack, Quivira, Mariano Lake, and Ruby Mines. Six of these
mines are priority mines. EPA expects to finalize the Engineering Evaluation/Cost Analysis reports for 20
priority mine sites in 2022, which will include these nine mine sites.

Mac and Black Jack Mines

From 1959 to 1971, uranium ore was mined at the four Mac
and Blackjack Mines located in the Mariano Lake and
Smith Lake Chapters. In 2014, Homestake Mining Company
entered into a settlement agreement with EPA to assess
four abandoned uranium mines, two of which are priority
mines.

In 2018, the removal site evaluation reports, which
determine the extent of soil contamination on the four mines,
were completed. Homestake is conducting an Engineering
Evaiuation/Cost Analysis to identify and evaluate all potential
cleanup options, and a draft was submitted to EPA in 2019.
Cleanup options will include consolidating mine waste in
an on-site repository and transporting mine waste to an
off-site licensed disposal facility.

Ruby Mines

From 1975 to 1985, uranium ore was mined at the four Ruby Mines located in the Smith Lake
Chapter in the eastern area of the Navajo Nation. In 1985, Western Nuclear, Inc. (Western Nuclear)
completed reclamation efforts at the Ruby Mines by covering the waste rock with clean soil under
the direction of the Bureau of Land Management and BIA.

In 2015, Western Nuclear, the potentially responsible party, completed removal site evaluations
defining the extent of soil contamination at the four mines, two of these are priority mines. In
2016, Western Nuclear, entered into a settlement agreement with EPA to perform an Engineering
Evaluation/Cost Analysis report that is part of the decision-making process to evaluate potential
cleanup options for the mine sites. Western Nuclear is working with other potentially responsible
parties of nearby abandoned uranium mine sites, Chevron and Homestake, to evaluate cleanup
alternative options of combining the waste from all the mines in one repository.

Before and after photos of hazards mitigation work by Una'
ba' at Blackjack#! Mine completed in 2018.

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0 DESIGN AND CLEAN UP

At this point in the Superfund process, EPA or the potentially responsible party can begin the design
and construction of cleanup on the mine site. As early in the process as possible, EPA works with
government partners including NNEPA and BIA, as well as the impacted communities to return sites to
productive uses. The community is informed of any planned work, truck traffic, and health and safety
precautions, After EPA determines that the physical construction at a site is complete, activities are put
in place to ensure that the cleanup actions will protect human health and the environment over the
long-term. For example, these activities may include routine maintenance at the site, such as making
sure signs and fences are intact or repositories are effectively containing, and preventing exposure
to mine waste rock. In 2018, the design of the Northeast Church Rock cleanup was completed and
approved by EPA for submission to NRC as part of a license amendment request.

Northeast Church Rock

The Northeast Church Rock mine was one of the highest producing uranium mines on the
Navajo Nation and became the highest priority for cleanup because it is near a Navajo residential
community. Uranium ore from the Northeast Church Rock mine and the Old Church Rock mine
was milled at the adjacent United Nuclear Corporation (UNC) mill. UNC operated the uranium mill
from 1977 to 1982. The mill, designed to process 4,000 tons of ore per day, extracted uranium by
application of conventional crushing, grinding, and acid-leach solvent extraction methods.

UNC, a company owned by the General Electric Company (GE), is responsible for cleaning up
the Northeast Church Rock mine, a priority mine, and reclaiming the UNC miil site. UNC/GE has
moved more than 200,000 tons of contaminated soil from within the residential community
to the mine waste pile, which is temporarily covered and stabilized. On September 24,2018,
UNC/GE completed a design to place approximately 1 million cubic yards of mine waste in a
permanent repository on the former UNC Mill site. In 2018, UNC/GE submitted a UNC Mill site
License Amendment Request to NRC to place the mine waste on the mill waste disposal cell. After
completing a review of the License Amendment Request for completeness, NRC held a public
scoping meeting in Gallup in March 2019 to get stakeholder input on the Environmental Impact
Statement it is preparing in support of its review of the License Amendment Request. Several
agencies, including NNEPA, New Mexico Environment Department, DOE, NRC, EPA Regions 6
and 9, and a representative from Red Water Pond Road Community Association assisted by a
representative from EPA'sTechnical Assistance Services for Communities contractor, were involved
in the remedial design of the mine waste repository to ensure that the proposed work does not
negatively affect the existing mill waste disposal cell.

The NRC staff estimates completion of the safety and environmental reviews of the License
Amendment Request by 2022. Dependent upon NRC approval of the License Amendment Request
for the UNC Mill Site, UNC/GE would enter into a consent decree with EPA and begin the
transportation and disposal of the mine waste.

UNC/GE is also cleaning up groundwater contamination from
the UNC mill site tailing cells, which were filled with the acid-
leachate slurry during the milling operation. Water from the
slurry has migrated into the subsurface and contaminated
water beneath the site.The UNC Mill site was placed on the
National Priorities List in 1983 and groundwater remediation
is ongoing. Surface remediation has been completed except
for two evaporation ponds that are still in use as part of the
EPA groundwater cleanup. Groundwater cleanup has been

ongoing at the site for more than 30 years. The groundwater contamination may potentially cross
over to Navajo Nation on the north end of the mill site boundary.

North East Church Rock cleanup photo circa 2009

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GOALS FOR THE NEXT 10 YEARS

EPA will work with NNEPA toward completing the investigation and cleanup at the 230 mine sites where
EPA and the Navajo Nation have secured funding or a commitment to perform work. The following
table reflects the milestones supporting this goal.These milestones will be reported on annually.

Number of Mine

Sites by Year*

Milestone

2022

2023

2024

2025

2026 2027

2028

2029

Assessment

84
46

100

EE/CA

4
26

Design

Cleanup

4
26

'Priority mine sites are shown in yellow-shaded

rows.

EPA will continue to conduct time-critical response actions at sites found to pose an imminent and
substantial endangerment to human health and the environment.

EPA will work with the Navajo Nation to bolster the capacity of Navajo Nation agencies, including
NNEPA and Navajo AML, to perform assessments, cleanups, and the long-term operation and
maintenance of cleanups at abandoned uranium mine sites. Milestones supporting this goal are listed
below and will be updated and reported on annually.

By 2022, develop a plan, including an implementation schedule, for expanding NNEPA's role in
overseeing and conducting the assessment and
cleanup of mine sites.

By 2024, develop a plan, including an implementation
schedule, for Navajo Nation agencies to implement
long-term operation and maintenance measures at
mine sites.

Once finalized, these plans will be appended to this
Ten-Year Plan.

EPA will continue to involve communities and Chapter
officials in the assessment and cleanup process to ensure

that EPA understands community concerns and considers usmarniNNmmmmmnommfomiiKiknmth.m.
community goals in the CERCLA decision-making process, ^mmer2019.

EPA will continue to coordinate closely with the Navajo Nation to ensure that the Navajo Nation
government is consulted and that traditional ecological knowledge and Dine Fundamental Law is
incorporated in the CERCLA decision-making process.

EPA will work with the Navajo Nation to develop an approach for implementing long-term operation
and maintenance measures at mine sites, including roles and responsibilities, to ensure that the
selected cleanup options remain protective of human health and the environment.

EPA will continue to work with the Navajo Nation and federal partner agencies to find additional
sources of funding and/or support to complete detailed assessments at the approximately 300
abandoned uranium mines that are not presently funded under existing settlement or enforcement
agreements.

EPA will continue to explore avenues for EPA to have a greater field presence on and near the Navajo
Nation to effectively implement and support the goals described in this plan.

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DRUM Program:

Summary of Accomplishments (2017-2020)

/ Defined the number of mines on the Navajo Nation and other tribal
lands to be evaluated by the DRUM program. The U.S. EPA and Navajo
Nation EPA have entered into enforcement agreements and settlements
for 230 of 523 known abandoned uranium mines on and near the
Navajo Nation,

/ Reconciled the remaining 293 unfunded mines on the Navajo Nation to
confirm the land status, mine location, and ore purchase data for each

LM plans to secure funding for support and implementation of Campaign 2, and possibly safeguarding
of the remaining 293 abandoned uranium mines on or near the Navajo Nation and eligible abandoned
uranium mines located on other tribal lands. This funding is planned annually with forecasts covering
multiple years and largely derived from the Federal budget and appropriations process. From 2017
through 2020, LM has invested $21 million to the DRUM program toward V&V, risk screening, report
preparation, and safeguarding. Campaign 2 funding would support involvement of Navajo Nation

REPORT OF FUNDING

BACKGROUND

The U.S. Department of Energy (DOE) Office of Legacy Management (LM) Defense-Related Uranium Mines
(DRUM) Program is a partnership between federal land management agencies, state abandoned mine
lands (AML) programs, and tribal governments to verify and validate (V&V) the condition of a specific set
of abandoned uranium mines. The mines in question provided uranium ore to the U.S. Atomic Energy
commission (AEC) for defense-related activities. The program evaluates and reports on the risk screening
results and physical hazards presented by these mines while employing an interagency collaborative
approach to safeguarding identified physical hazards to protect the public and wildlife at many of these
sites. LM partitioned the program's scope using a multi-phased approach and is sequentially implementing
its DRUM Program in the following manner: public land (Campaign 1), tribal land (Campaign 2), and
private property (Campaign 3). Campaign 1 is underway and will be substantially completed by the end of
2022. This was chosen as the first campaign since this represents the majority of sites and they are freely
accessible. Campaign 2 is scheduled to commence field work in fiscal year 2023, while Campaign 3 field
work will begin in fiscal year 2024. Campaigns 2 and 3 will be completed by 2030.

https://www.enerav.aov/lm/proarams/defense-related-uranium-mines-proaram

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agencies, and potentially other tribal governments, in the collaborative development of the various
planning documents (i.e., work plan and risk screening), field V&V, safeguarding, and monitoring and
maintenance processes.

GOALS FOR THE NEXT 10 YEARS

Over the next 10 years, DOE will transition to Campaign 2 and 3. During Campaign 2, DOE will work with
EPA, Navajo Nation AML, and Navajo Nation EPA, along with other affected tribes, toward completing a
new DRUM work plan and risk screening process adopting risk scenarios and table values customarily
utilized by the Navajo Nation. Further, DOE will work collaboratively to V&V and safeguard hazardous mine
openings.

The DRUM program wili specifically work with the Navajo Nation agencies, including Navajo AML, to
bolster their capacity to perform V&V, safeguarding and long-term monitoring and maintenance of
abandoned uranium mine sites. Milestones supporting this goal are listed below and will be updated and
reported on annually.

By 2022, reach an agreement for incorporating the Navajo Nation AML role in overseeing and
conducting V&V and safeguarding activities at DRUM sites.

By 2023, begin field V&V activities at the remaining DRUM sites.

By 2024, collaborate with EPA to develop a plan for Navajo Nation agencies to implement long-term
monitoring and maintenance measures at DRUM sites.

CalcoMine, Gateway, Colorado

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BACKGROUND

DOE Office of Legacy Management (DOE-LM) is responsible for long-term surveillance and maintenance
of four former uranium-ore-processing milling sites within the Navajo Nation: Tuba City Site, Monument
Valley Processing Site, Mexican Hat Site, and Shiprock Site.

DOE-LM remediated the four sites according to standards developed by EPA. After closure of the
processing mills, DOE-LM placed radioactive tailings in NRC-approved engineered disposal cells. NRC has
formal regulatory responsibility over DOE's long-term stewardship responsibilities at the three disposal
sites on the Navajo Nation that have been transferred to DOE-LM under an NRC general license and the
former milling sites in Monument Valley.

As part of its long-term stewardship responsibilities, DOE-LM maintains and monitors disposal sites at
three sites on the Navajo Nation—Tuba City, Mexican Hat, and Shiprock—to ensure they remain protective
of human health and the environment. DOE-LM monitors groundwater and surface water at all four former
milling sites and conducts routine maintenance activities such as repairing signs and fences, managing
vegetation on the disposal cells, and repairing erosion damage that may threaten access to the disposal
cells and property within the long-term care boundary. DOE-LM also performs active remediation of
groundwater at the Shiprock and Tuba City sites,

NRC has regulatory authority at the former mill and
disposal sites on the Navajo Nation that have been
transferred to DOE-LM. NRC reviews and provides
comments on reports developed by DOE-LM
regarding the sites, conducts inspections of the sites
in conjunction with DOE-LM, and provides regulatory
review of DOE-LM implementation of the Long-Term
Surveillance Plan and groundwater Compliance Action
Plan, as appropriate. If DOE-LM revises the Long-Term
Surveillance Plan or Groundwater Compliance Action
Plan for the sites, NRC will review and, as appropriate,
provide comments and accept on the revision before
DOE implements the plan.

In conjunction with NRCs formal regulatory authority,

DOE-LM also engages directly with the Navajo
Nation and the Hopi Tribe, both of whom review and
comment on DOE-LM documents and work plans.

DOE-LM works in consultation with the Navajo Nation

Division of Natural Resources and the HopiTribe, both Locations of the four former uranium-ore-processing mill sites within the Navajo

of whom participate in long-term surveillance and

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monitoring, groundwater compliance, and public participation at the four DOE-LM sites.The Navajo
AML/UMTRA Department engages directly with NNEPA to facilitate in those reviews; however, NNEPA
does not possess regulatory oversight or authority over DOE- LM because that function exists with
NRC. DOE-LM conducts community outreach by organizing open houses and site tours and meeting
regularly with cooperating agencies and Chapter leaders regarding project updates.

DOE-LM remains committed to increasing outreach activities to tribal communities that have been
affected by uranium. This commitment includes funding for a Community Outreach Network Liaison
position and maintaining an office in the Navajo Nation capitol city, Window Rock, AZ.The office
supplies a touch-down space for Network members to work while they are in Window Rock and serves
as a centralized resource for uranium information for the public. Both the Network liaison and office
have been key in raising the awareness of the collaborative efforts of the Network. For a more detailed
list of outreach activities, please see pages 34-37.

Former Mills: Summary of Accomplishments (2008-2019)

/ DOE conducted annual inspections and performed routine maintenance
at the four UMTRCA Title I sites.

/ DOE performed groundwater restoration at two former mill sites:
Shiproek, New Mexico and Tuba City Arizona.

•/ NRC provided regulatory oversight of DOE including inspections at the
former mill sites and reviewing and commenting on DOE reports and
workplans.

/ DOE worked with the Navajo Nation to create and implement an
outreach and communication pian. NRC participated in community
outreach and quarterly DOE/Navajo/Hopi coordination meetings.

REPORT OF FUNDING

Actual costs of activities regarding the four former uranium-
ore-processing mill sites within the Navajo Nation and the
Window Rock Community Outreach Office (not including NRC
oversight costs) were:

2017: $3.9 million 2016: $3.5 million

FORMER MILLS PROGRESS

This section summarizes activities, accomplishments, funding,
and goals pertaining to theTuba City, Monument Valley
Processing Site, Mexican Hat, and Shiproek UMTRCA Title 1
sites.

Tuba City Site

Site Remediation

• 1989: Surface remediation and construction of engineered disposal cell completed.

• 1990-2018: Disposal cell long-term surveillance and monitoring.

• 2002-2014: Operation of the groundwater treatment plant.

• 2014-2018: Treatment of groundwater by extraction and evaporation.

DOE-LM engages with students on a groundwater model

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Public Outreach

\s%

• 2008-2018: Increased community outreach via community open houses and site tours,
information booths at community events, and informational materials.

Technical Work

• 2016-2018: Application of a computer-simulated groundwater flow model to identify potential
groundwater movement,

• 2017-2019: Evaluation of aquifer characteristics and geochemical properties affecting contaminant
migration. Evaluation of enhanced evaporation methods.

Establishment of a Technical Working Group with the Navajo Nation and Hopi Tribe.

Regulatory Compliance

Groundwater monitoring and analysis in accordance with existing monitoring plans, with results
published on public DQE-LM website.

Monument Valley Processing Site

Site Remediation

• 1998-2016: Conducted phytoremediation and groundwater injection pilot studies to develop
potential site groundwater remediation options.

• 1994-2018: Long-term groundwater monitoring and maintenance following surface remediation
at the site.

Public Outreach

• 2008-2018: increased community outreach
via community open houses, door to door
notifications, and outreach coordination with
Navajo AML/UMTRA Program Department at
community events and annual fairs.

Technical Work

• 2009-2010: Completion of Radiological
Assessment of Stained Soils at the Monument
Valley Processing Site.

• 2016: Completion and issuance of final pilot
study titled "Monitored Natural and Enhanced
Attenuation of the Alluvial Aquifer and Subpile
Soils at the Monument Valley, Arizona, Processing
Site: Final Pilot Study Report."

• 2015-2017: Completion with the University of Arizona of pilot study of in situ biosequestration for
remediation of uranium in alluvial groundwater.

Regulatory Compliance

• 1994-Present: Groundwater monitoring and analysis in accordance with existing monitoring plans,
with results published on public DOE-LM website.

Mexican Hat Site

Site Remediation

• 2008-2018: Disposal cell long-term surveillance and monitoring.

• 2008-2018: Visual monitoring of site groundwater seep locations, although groundwater quantity
was not sufficient for sampling.

In 2016, Site Ecologist discusses previous research at the Monument
Valley former processing site during a site visit.

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Public Outreach

• 2008-2018: Increased public outreach via community open houses, door to door notifications, and
community outreach coordination with Navajo AML/UMTRA Department at community events and
annual fairs.

Technical Work

• 2016-2017: Initial Environmental Evaluation of disposal cell with focus on depressions during
March 2016 annual site evaluation; draft report titled "Mexican Hat UMTRCA Disposal Cell Northeast
Slope Cover Depressions Evaluation Report"submitted to Navajo AML/UMTRA Department for
review and comment.

• 2017: Installation of meteorological weatherstation, baseline ground-based Light Detection and
Ranging survey, and acquisition of global positioning system-grade survey data of settlement
plates on top slope of the disposal cell.

Regulatory Compliance

• 2008-2018: Annual site inspections, inspection of groundwater seeps, and completion of a draft
report titled "Seep Monitoring Evaluation Report at the Mexican Hat, Utah, UMTRCA Title I Disposal
Site"—all in accordance with the long-term surveillance and monitoring plan.

Groundwater monitoring and analysis in accordance with existing monitoring plans, with results
published on public DOE-LM website.

Shiprock Site

Site Remediation

• 1994-2018: Disposal cell long-term surveillance and monitoring.

• 2003-2018: Treatment of groundwater by extraction and evaporation.

Public Outreach

• 2008-2018: Increased public outreach via community open houses, door to door notifications,
and community outreach coordination with Navajo AML/UMTRA Department.

Technical Work

• 2003-2013: Evaluation of Sampling Optimization with regards to groundwater sampling, and
completion of a report titled "Optimization of Sampling at the Shiprock, New Mexico, Site."

• 2006-2018: Evaluation of phytoremediation as a potential site remediation activity.

• 2011-2017: Conducted isotopic analysis of groundwater in Many Devils Wash to verify non-mill
signature.

• 2017-2018: Evaluation of Flow Processes in the Shiprock, New Mexico Floodplain with completion
of a report titled "Flow Processes in the Floodplain Alluvial Aquifer at Shiprock, New Mexico,
Disposal Site."

• 2008-2018: Evaluation of remediation system performance, with completion of specific trench
performance reports and annual performance reports.

Regulatory Compliance

• 2002-2018: Guidance of current groundwater remediation via the site's Groundwater Compliance
Action Plan.

• 2002-2018: Continued discussions with the Navajo Nation concerning institutional controls
for applicable sites (water-drilling and grazing restrictions are the only anticipated institutional
controls).

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2002-2018: Groundwater monitoring and analysis in accordance with existing monitoring plans,
with results published on public DOE-LM website.

GOALS FOR THE NEXT 10YEARS

This section describes short-term (3-year), medium-term (5-year), and long-term (10-year) goals of
activities at the Tuba City, Monument Valley Processing Site, and Shiprock sites.

Short Term (3-Year)

Tuba City Site

Continue further evaluations of contaminant source material and evaluate alternative compliance
strategies. Submit a draft Revised Groundwater Compliance Action Plan (GCAP) to stakeholders
for review. After consultation with stakeholders and Tribal agencies, submit the revised draft
GCAP to NRC for review and concurrence. Address all comments, obtain NRC concurrence, finalize,
and implement the revised groundwater compliance strategy. Potential strategies include no
remediation (alternate concentration limits, institutional controls, and long-term monitoring) or
active remediation (water treatment for aquifer restoration, or for plume containment). If land
use or well drilling must be controlled as part of the revised GCAP, negotiate controls with Navajo
Nation agencies. Develop methods for ensuring effectiveness of controls.

Monitor conditions as the revised groundwater compliance strategy is implemented and takes
effect.

Continue community outreach by conducting open houses and site tours, door to door
notifications, and meeting regularly with cooperating agencies and Chapter leaders regarding
project updates.

Continue discussions with the Navajo Nation to secure relevant and appropriate institutional
controls.

Monument Valley Processing Site

Submit draft GCAP to NRC after consultation
with stakeholders and Navajo agencies.

Continue discussions with the Navajo Nation
to secure durable and enforceable institutional
controls.

Mexican Hat Site

Perform targeted cover investigation along the
northeast side slope of the disposal cell.

Understand the cause(s) of depression features
observed along the toe and lower portions of the
northeast side slope.

Assess need for corrective actions at the site to address the depression features along the northeast
side slope.

Continue visual observations of seep during annual site inspections.

Continue community outreach by conducting open houses and site tours, door to door
notifications, and meeting regularly with cooperating agencies and Chapter leaders regarding
project updates.

The Mexican Hat Disposal Cell with the Hat Rock formation in the background
near Mexican Hat and Halchita, Utah.

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Continue discussions with the Navajo Nation to secure relevant and appropriate institutional
controls.

ShiprockSite

Continue suspension of active groundwater remediation and continue the evaluation of
alternatives for the groundwater remediation system evaporation pond iiner.

Evaluate effectiveness of the current groundwater remediation approach and conduct studies to
develop and support future remediation efforts.

Prepare an Environmental Assessment of options for the evaporation pond.

Revise the GCAP for the site.

Conduct site characterization studies to support the drafting of the revised GCAP.

Submit a draft revised GCAP for tribal partners to for review. After consultation with stakeholders
and Tribal agencies, submit the revised draft GCAP to NRC for review and concurrence.

Begin implementation of revisions to the groundwater compliance strategy to the site, including
decommissioning with the existing pond liner and disposal of affected waste material.

Continue community outreach by conducting open houses and site tours, participation in
community events and attendance and Chapter House meetings, and meeting regularly with
cooperating agencies and Chapter leaders regarding project updates.

Continue discussions with the Navajo Nation to secure relevant and appropriate institutional
controls.

Medium Term (5-Year)

Tuba City Site

If the revised compliance strategy is effective and acceptable to stakeholders, and does not include
use of the existing groundwater treatment
system and evaporation pond, decommission the
treatment system and pond.

If the office and shop buildings are no longer
needed to support operation of a groundwater
treatment system, possibly repurpose these
buildings for community outreach, providing
information about site history (mil! operation,
surface remediation, groundwater remediation,
long-term monitoring).

Continually evaluate effectiveness of the revised
groundwater compliance strategy to ensure that
regulatory requirements are met.

Continue community outreach by conducting open houses and site tours, and meeting regularly
with cooperating agencies and Chapter leaders regarding project updates.

Mexican Hat Site

Develop Corrective Action Plan (CAP), if needed.

Obtain Navajo Nation and NRC acceptance on the CAP.

Continue visual observations of seep during annua! site inspections.

The Tuba City Disposal Site East of Tuba City, AZ.

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Continue community outreach by conducting open houses and site tours, and meeting regularly
with cooperating agencies and Chapter leaders regarding project updates.

I/*
LU

Continue discussions with the Navajo Nation to secure relevant and appropriate institutional
controls.

ShiprockSite

Complete construction activities to decommission the evaporation pond liner, pending the results
of the Environmental Assessment and regulatory approval.

Continue to implement any revisions to the groundwater remediation compliance strategy
described in the revised GCAP.

Continue community outreach by conducting open houses and site tours, participation in local
events, attending Chapter House meetings, door to door notifications, and meeting regularly with
cooperating agencies, local stakeholders and Chapter leaders regarding project.

Long Term (10-Year)

Tuba City Site

Continue long-term groundwater monitoring and continue to use the site for community outreach,
if alternate concentration limits and institutional controls compliance strategy continue to be
effective.

Continue operation of remediation system, monitor remediation progress, and evaluate
performance. Revise the GCAP, if necessary.

Continue to engage research facilities such as Savannah River National Laboratory for technical
assistance to evaluate DOE-LM's recommendations, not limited to evaluating approaches to
remedial action methods.

Continue community outreach by conducting open houses and site tours, door to door
notifications, participate in local events, and meeting regularly with cooperating agencies and
Chapter meetings.

Monument Valley Processing Site

Continue long-term groundwater monitoring, surveillance, and maintenance activities.

Investigate research technologies pertaining t
groundwater remediation.

Continue community outreach by conducting
open houses and site tours, door to door
notifications, and meeting regularly with
cooperating agencies, local stakeholders, and
Chapter leaders regarding project updates.

Mexican Hat Site

Implement corrective actions along the
northeast side slope, if needed.

Looking East over the Mexican Hat Disposal Cell at sunrise.

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vo

ShiprockSite

Continue long-term groundwater remediation, monitoring, surveillance, and maintenance
activities.

Continue community outreach by conducting open houses and site tours, door to door
notifications, and meeting regularly with cooperating agencies, local stakeholders, and Chapter
leaders regarding project updates.

NRC'S OVERSIGHT OF DOE-LM'S ACTIVITIES AT THE FORMER MILL SITES

NRC's role at the Navajo Nation sites is oversight of DOE-LM as the general licensee. NRC does not
perform specific site management or corrective actions, but ensures that DOE-LM complies with the
long-term management plans and requirements pertaining to the sites. In this role, NRC has reviewed
and provided comments on DOE-LM groundwater and performance reports regarding the Shiprock
and Tuba City sites, and groundwater reports regarding the Monument Valley site. NRC also reviewed
and provided comments on other reports developed by DOE-LM to support DOE-LM's management of
these sites. For example, NRC reviewed and provided comments to DOE-LM on the Shiprock floodplain
model, the Many Devils Wash position paper, and proposed changes to groundwater monitoring at
the Shiprocksite. Regarding the Tuba City site, NRC staff reviewed and commented on the Interim
Treatment Evaluation Plan, draft groundwater flow plan and model, proposed groundwater monitoring
locations, enhanced evaporation system, shutdown of the Tuba City treatment system, and DOE-LM's
analysis of alternate treatment approaches to address groundwater at the site.

NRC will continue to oversee DOE activities at these sites and to review and provide comments on DOE-
LM's groundwater reports regarding the disposal and former mill sites. For example, NRC will review
and, if acceptable, concur on the Tuba City and Monument Valley GCAPs when these are developed,
and will work with DOE-LM to resolve any issues related to the depressions on the Mexican Hat site
cover. NRC will review and, if acceptable, concur on DOE-LM's plans for decommissioning the Shiprock
evaporation pond, and will concur on the revised GCAP for the Shiprocksite if found acceptable.
The NRC will consult with the Navajo Nation, as appropriate, during the reviews of GCAPs and
decommissioning plans.

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%s>

BACKGROUND

Uranium mining or milling waste was used by some residents as building material for their homes. The
homes or other structures may also have been contaminated by mined radioactive materials in dust and
soil brought into homes on shoes and clothing. If such structures are occupied, residents'health may be at
risk from gamma and alpha radiation.

EPA and NNEPA's Contaminated Structures Program evaluates structures on the Navajo Nation that may
have been constructed using abandoned mine materials or built on or near abandoned uranium mines.

CONTAMINATED STRUCTURES:
SUMMARY OF ACCOMPLISHMENTS (2008-2019)

/ Since 2008, the EPA and NNEPA surveyed over 1,200 structures within
one mite of an abandoned uranium mine.

/ EPA remediated over 50 structures that were found to pose a health risk.

/ EPA removed contaminated soil from areas outside 18 homesites.

REPORT OF FUNDING

EPA has spent over $20 million assessing structures and performing cleanup when structures were
found to pose health risks from mining-related materials.This funding has gone to EPA contractors
and to Navajo Nation agencies to support this work. The amount of future funding will depend on the
number of assessments and cleanups that will be needed, which is expected to decline.

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GOALS FOR THE NEXT 10 YEARS

%s>

Conduct radiological assessments at additional structures beyond one mile of an abandoned uranium
mine where residents may have used abandoned uranium mine materials in construction.Target
outreach in the six abandoned uranium mine regions to determine if there is a potential health risk to
residents.

Implement removal actions where contaminated structures and surrounding soils are found to pose a
risk to residents.

By 2021, finalize a program manual that includes field procedures for assessment.

By 2023, the agencies will have a standard data sharing agreement that covers relevant and digital
data for the structures program and gives EPA and NNEPA full and equal access to records.

Work with the Navajo Nation to bolster the capacity of Navajo Nation agencies so that NNEPA can
assess homes for the Contaminated Structures Program by 2023, coordinating with EPA as appropriate.
The following milestones will need to be achieved prior to NNEPA assessing homes:

EPA and NNEPA will need to jointly finish a program manual, including field procedures for
assessment;

EPA and NNEPA staff will need to complete mutual training on technical and program
procedures;

EPA and NNEPA will identify dedicated technical and programmatic leads and will need to have
sufficient staff resources devoted to the structures program; and

NNEPA will need to have access to sufficient contracting support that can implement the field
procedures in the program manual.

Contractors, along with EPA and NNEPA, evaluating a yard with radiation-specific instruments and survey equipment. It takes about three hours to evaluate inside and
outside the home.

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Troriox settlement funds of $3.3 million were used to conduct the Cove Wash Watershed Assessment.
Tronox settlement funds of $2.35 million were used to study the impact ofTronox mines on the San
Mateo Creek Basin groundwater contamination. The U.S./Navajo Phase 2 settlement provided for funds
to conduct two water studies, including one at the Claim 28 mine in the Blue Gap Chapter.

REPORT OF FUNDING

EPA and the Navajo Nation are concerned about the impacts abandoned uranium mines may have on
surface water and groundwater. EPA and the Navajo Nation agreed to assess potential impacts on water
resources at surface mines, underground "dry"mines above groundwater, underground "wet" mines
below groundwater, and "leach" mines where acid was used on site to extract ore.

BACKGROUND

WATER: SUMMARY OF ACCOMPLISHMENTS (2008-2019)

/ EPA determined uranium mining and milling caused groundwater
contamination in the San Mateo Creek Ba Jin. EPA has engaged
potentially responsible parties to investigate the extent of groundwater
contamination. At the same time, EPA continues to work toward
proposing the San Mateo Creek Basin to the Superfund National
Priorities List, or*Superfund list." Formal consultation with the Navajo
Nation on the proposed listing occurred on February 14,2018.

/ EPA, NNEPA, and Dine College assessed the Cove Wash Watershed,
which contains 42 abandoned uranium mines.The assessment found
elevated uranium concentrations in surface water and groundwater
around and below the historically mined areas.

J The U.Sj'Navajo Phase 2 Trust Settlement provided for two studies to
investigate potential impacts to surface water and groundwater at two
mines: including one at the Claim 28 priority mine Sn theTachee-Blue
Gap chapter, and the other at the Saytah/George Simpson 1 Incline
mine in the Tolikan chapter.

/ Detailed assessments for over SO mines included sampling any nearby
water sources.

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GOALS FOR THE NEXT 10 YEARS

Detailed mine assessments will continue to include sampling nearby water sources.

EPA will complete two studies to investigate potential impacts to surface water and groundwater
under the U.S./Navajo Phase 2 Trust Settlement: Claim 28 priority mine in theTachee-Blue Gap
chapter and the Saytah/George Simpson 1 Incline mine in theTolikan chapter.

EPA will conduct a study to investigate potential impacts to surface water and groundwater from
underground mines at the Northeast Church Rock/Quivira mining complex.

EPA will coordinate closely with NNEPA to ensure that cleanup options implemented at abandoned
uranium mine sites are protective of surface water and groundwater.

EPA will continue assessing the San Mateo Creek Basin under enforcement agreements with
potentially responsible parties and, as appropriate, these results will be used to inform similar water
studies on the Navajo Nation.

The results of water studies will be used to evaluate if and to what extent surface and groundwater
on the Navajo Nation is impacted by abandoned uranium mines and develop cleanup strategies.
EPA will report on the progress of these studies annually.

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BACKGROUND

Approximately 15 percent of the Navajo Nation population obtains drinking water from unregulated
sources, such as livestock wells, springs, private wells, or watering points. Navajo Nation policy prohibits
the use of these unregulated sources for human consumption. However, some residents in remote
areas on the Navajo Nation drink water from unregulated sources due to lack of access to piped water.
These water sources are susceptible to contamination from bacteria, and may also contain heavy
metals including radionuclides. These contaminants may be naturally occurring or may be the result of
mining. During the first Five-Year Plan, elevated levels of radionuclides were identified in 29 out of 240
unregulated water sources sampled, and residents were warned not to drink from these water sources.

DRINKING WATER:

SUMMARY OF ACCOMPLISHMENTS {2008-2019}

/ During the first Five-Year Plan, elevated levels of radionuclides were
identified in 29 out of the 240 unregulated water sources sampled, and
residents were warned not to drink from these water sources.

/EPA completed a time-critical action in Cove, AZ which included posting
warning signs at contaminated wells.

J 1HS, EPA, and U.S. Department of Housing and Urban Development
completed water infrastructure projects that provided first access to
piped water for 3,809 homes In the abandoned uranium mine regions of
the Navajo Nation.

REPORT OF FUNDING

IMS, EPA, and U.S. Department of Housing
and Urban Development provided almost
$200 million for water infrastructure projects
that provided first access to piped water for
3,809 homes in the abandoned uranium
mine regions of the Navajo Nation.

Workers from Navajo Engineering and Construction Authority construct
this IHS funded water line extension to provide first service of safe
drinking water to 26 homes in Cottonwood.

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GOALS FOR THE NEXT 10 YEARS

IHS and EPA will continue to increase access to safe drinking water in the abandoned uranium mine
regions of the Navajo Nation by funding high-ranking water infrastructure projects with available
funds. Naturally elevated levels of uranium and other metals have been reported in water sources
in these areas.

Sanders Drinking Water

In 2014, EPA awarded a $120,000 Environmental Justice Collaborative Problem-Solving grant
to theTolani Lake Enterprises to assess water sources in the Rio Puerco/Little Colorado River
watershed. At that time,Tolani Lake Enterprises identified exceedances of drinking water
standards for radionuclides at a school, a residential area, and nearby livestock water sources in
Sanders, AZ.

Drinking water wells that were found to be contaminated have been either taken off-line or have
a point of entry filtration system to remove contaminants. In April 2016, the Navajo Tribal Utility
Authority (NTUA) purchased the Arizona Windsong public water system that served a community
in Sanders. Wells of the former Arizona Windsong water system were taken offline and the
residents are now served by the NTUA New Lands water system. In addition, a treatment plant to
remove uranium went on-line in July 2017 at the Sanders Unified Elementary School to treat the
water being served at the school.

These water sources in Sanders, AZ are near the Navajo "New Lands," and approximately 50
miles downstream from the 1979 UNC mill tailings spill—the largest radioactive release in U.S.
history—and mine dewatering discharges in the Eastern Agency. Beginning in 2021, EPA will
conduct a study at the Northeast Church Rock/Quivira mining complex to evaluate if and to what
extent mining activities impacted surface water and groundwater. Results of this study could
lead to efforts to remediate surface water and groundwater if there are impacts related to mining
which pose human health or environmental risks.

Water Infrastructure Projects Funded to Provide
First Access to Safe Drinking Water*

3809L

12500
£2000

2008-2012 2013 2014 2015 2016 2017

"Water infrastructure projects are shown cumulative from the prior years.

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l/>

BACKGROUND

TheTuba City Dump (TCD) is located just off Highway 160, east ofTuba City arid the Upper Village
of Moenkopi in Coconino County, AZ. BIA operated the TCD as an open municipal waste dump from
the 1950s until 1997, It covers about 40 acres and includes about 330,000 cubic yards of material; 95
percent is on Hopi iand, and 5 percent is on Navajo Nation land. Most of the waste in the TCD was
burned before it was buried. Federal law requires that the TCD was to be properly closed by 1997, but it
has been temporarily closed with a veneer soil cover and fence.

Residents of the Tuba City and Moenkopi communities expressed concerns that the TCD may have
received uranium mill wastes from the Rare Metals uranium mill located four miles east of the dump on
Highway 160.

In 2017, BIA, under the Superfund law, completed a remedial investigation/feasibility study (RI/FS) to
investigate both the contents of the TCD as well as whether there could be impacts to groundwater or
drinking water sources from waste in the TCD.

The investigation included scans, analyses and tests from hundreds of soil and waste cores and trenches
within theTCD and surrounding land,sediments, and drainages.The investigation also included
the installation and associated groundwater modeling and analyses of more than 70 groundwater
monitoring wells in both the shallow and deep groundwater.

TheTCD is primarily composed of soil, ash, glass, brick, and burned municipal debris. Leachate from the
TCD causes naturally occurring uranium and strontium in theTCD to dissolve into shallow groundwater

TUBA CITY DUMP:

SUMMARY OF ACCOMPLISHMENTS (2008-2019)

/ In 2009, BIA completed interim action studies and the Interim Action
Included:

• Studies of the waste in theTCD including surface and downhole
radioactivity surveys, borings, core samples arid analyses, and test pits,

¦ Analysis of the movement of groundwater, and potential threats to the
Moenkopi drinking water supply wells and springs.

¦ Groundwater sampling and aquifer testing to evaluate groundwater flow
direction and water quality.

/ In 2009, BIA completed fencing the perimeter of the TCD.

/ (i) 2010, BJA completed the RI/FS Work Plan.

/ In 2017, BIA completed RI/FS.

/ BIA conducted periodic ground water monitoring.

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Tuba City Dump and surrounding areas.

more than they would without the TCD. Uranium and strontium in the shallow groundwater decrease
to background levels in the immediate vicinity of theTCD, Groundwater studies show that shallow
groundwater contaminated by theTCD has not and will not migrate beyond Pasture Canyon to the
Moenkopi drinking water wells.

As a result of these studies, (1) no evidence of uranium above background levels or radioactivity in the
TCD was identified and (2) drinking water from the Moenkopi Springs is safe and cannot be affected by
the TCD. The Hopi Tribe and Navajo Nation were, and continue to be, actively involved in the remedial
investigation and assessment of cleanup options. EPA and BIA continue to coordinate efforts to select
and implement a cleanup option.

While theTCD was found not to contain the uranium waste that was originally feared, it remains an
illegal open dump with burned waste and needs to be closed in accordance with federal law.

SUMMARY OF FUNDING

BIA's expenditures to assess theTCD included $3.0 million to conduct interim action studies and
complete the Interim Action Report and RI/FS work plan, and $4.8 million to implement the RI/FS.

GOALS FOR THE NEXT 10 YEARS

In 2020, BIA and EPA will complete formal consultation with the Hopi Tribe and Navajo Nation.

By 2021, EPA and BIA will enter into an Administrative Order on Consent under the Resource
Conservation and Recovery Act to implement the final cleanup and closure of theTCD.

By 2021, subject to Hopi Tribal approval to use Hopi land for a new repository for solid waste from
theTCD, BIA and EPA will reach consensus with the Hopi Tribe and Navajo Nation with the cleanup
option.

By 2023, subject to Hopi Tribal and Navajo Nation consensus with the cleanup option, BIA will
complete the design plans to implement the cleanup option.

By 2024, subject to Congressional funding and Hopi Tribal and Navajo Nation consensus with the
cleanup option, BIA will begin waste removal at theTCD, implementing the cleanup option which
currently involves the removal of theTCD waste to a newly constructed repository. The repository
will be lined and covered. The TCD area will be restored such that the land will be available for
future use/development.

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BACKGROUND

ATSDR's involvement in the Health Section of the 2014 Five-Year Plan included the Navajo Birth Cohort
Study (NBCS), training for community health representatives (CHR), and provision of community
education materials per the "Health Studies Section" goals outlined in the 2014 Five-Year Plan,

HEALTH PROGRESS:

SUMMARY OF ACCOMPLISHMENTS (2014-2019)

/ Navajo Birth Cohort Study funded to better understand the palent'dl
relationship between exposure to uranium and other erivirorirrterttdl
contaminants and reproductive health outcomes

¦HI / 1 raining was delivered to 90 Community Health Representatives from
the Navajo Nation Department ot Health.

/ ATSDfl participated in five outreach events and developed and
distributed educational health handouts and porters.

Birth Cohort Study

ATSDR provided funding to the University of New Mexico (UNM), the Navajo Nation Department of
Health, and the Navajo Area IHS to continue the NBCS.The NBCS is the first prospective epidemiologic
study of pregnancy and neonatal outcomes in a uranium-exposed population (Goal id in the 2014 Five-
Year Plan).

From 2013 through 2017, 781 pregnant Navajo women were enrolled in the study, along with 230
fathers. Subsequently, 98 mothers withdrew from the study. A total of 740 infants were born and had
follow-up assessments through the first year of life.

Maternal surveys included an enrollment survey, food frequency survey, and post-partum survey,
and fathers were administered an enrollment survey. Infant surveys included ages and stages
questionnaires at 2,6,9, and 12 months.

Biological samples, including blood and urine, were collected from the mother at time of enrollment
in the study and at time of delivery. At delivery, infant urine and cord blood samples were collected;

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additionally, infant urine samples were collected between 2-6 months and at 12 months, CDC's
Environmental Health Laboratory analyzed the samples for 36 metals/metal compounds.

Home Environmental Assessments were conducted for enrolled participants.The assessments included
gamma radiation measurement, indoor air sampling for radon, and dust and drinking water analysis for
specific metals.

Report-back letters were provided to all study participants.The letters included individual
biomonitoring results, home environmental assessment results, and frequently asked questions (Goal
a.i in the 2014 Five-Year Plan).

From 2013 to 2016,2,500 community members, physicians, and researchers were educated about the
study and preliminary results via 15 community outreach activities. Additionally, 21 videos were created
and are available at https://voutu.be/kcJebbN4e I (Goal d.iii in the 2014 Five-Year Plan).

Enrollment of pregnant Navajo women ended in July 2017. All infants graduated from the program by
July 2018. The Navajo Birth Cohort Study is continuing through National Institutes of Health funding
to monitor and access the health of Navajo mothers and children via the Environmental Influences on
Child Health Outcomes (ECHO) program.

Health Care Staff Training

Outreach, training, and networking for health professionals has occurred—in person and via
teleconference leadership calls with NBCS stakeholders, including technical assistance and training on
medical record abstraction.

Staff moderated and presented a symposium at the 2015 International Society for Exposure Science
In 2015, staff delivered a presentation to the National Indian Health Board, and the Journal of
Environmental Health published a blog article titled "CDC Your Health, Your Environment."

CHR Training

In December 2014, ATSDR, EPA, and IHS delivered a training to 90 NNDOH CHRs at Window Rock, AZ.
The trainees then delivered the Uranium Awareness Posters (see below) to 110 Navajo Chapter houses.
ATSDR coordinated a refresher training for 90 CHRs presented by ATSDR, EPA, and IHS in December
2015 at Farmington, NM (Goal in the 2014 Five-Year Plan).

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Provision of Community Education Materials, Handouts, and Resources

ATSDR participated in five outreach events. ATSDR brought the Uranium Awareness Fact Sheets and the
Resource list, discussed uranium exposure pathways and ways to reduce exposure, and learned from
Navajo people about their experiences with uranium. Events included the following:

April 2016- Monument Valley community (UT) Open House with Five-Year Plan agencies.

October 2016 - Tuba City community and Hopi Tribe (AZ) Open House with Five-Year Plan agencies
and site tour with DOE of the rare metals site.

January 2017 - Community Outreach Network Open House in Window Rock, AZ. ATSDR staffed a tabie
to talk with Tribal Council members, and distributed binders of materials.

March 2017 - Shiprock community (NM) Open House with Five-Year Plan agencies.

September 2017 - Navajo Nation Fair, Window Rock, AZ; Community Health Outreach and Education,
and the Five-Year Plan agencies shared a table at the fair (Goal a.iii in the 2014 Five-Year Plan).

REPORT OF FUNDING

In September 2013, the second cooperative agreement was awarded to UNM for continuation of the
NBCS; the study was completed in August 31,2018. The birth cohort has transitioned to a new study
funded as part of the National Institutes of Health's Environmental Influences on Child Health Outcomes
(ECHO) Program.

GOALS FOR THE NEXT 10YEARS

IHS Provision of Community-Based Services

Provision of opportunities for community feedback.

Provision of specific health education to the community.

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Provision of information to the community concerning the ten-year plan and findings from the
last phase of the five-year plan.

Provision of medical screening evaluations to non-occupationally exposed individuals.

Provision of follow-up for those already screened.

Continued assurance that all information is available in the individual's home health record .
Assurance of continuity of care for affected individuals.

Uranium screening performed at all IHS healthcare facilities will become part of the permanent
patient record with the ICD-10 codes for exposure to uranium.

Health promotions/disease prevention program will launch a new community education
program to include uranium exposure in the medical history during healthcare visits.

Community based cancer screening to improve eariy detection of cancer.

IHS Provision of Radiation Exposure Screening and Education Program (RESEP) services

Continuation of IHS services to those with potentially compensable health conditions.

IHS Collaboration with NNDOH Epidemiology Program

Continued evaluation of cancer cases by geographic location of cancer patient's residence and
known radiation exposure sources.

Evaluation of health status of descendants of uranium miners/mill workers.

Design and establishment of a longitudinal human health impact study.

ATSDR and IHS Health Care Staff Training

Coordination between ATSDR and IHS to provide training to clinicians and other health care
providers on health effects of non-occupational exposure to uranium, and documentation of an
exposure history.

Coordination with NNDOH to develop materials and provide training to CHRs.Training topics
to include health effects of non-occupational exposure to uranium and other tools for effective
health education and outreach.

IHS provision of orientation and continuing education to providers in Navajo Area IHS.

IHS provision of orientation and continuing education to community-based staff in the Navajo

area.

Reduce Your Contact with Uranium and
Radiation

Steps to keep yourself safe:

Stay away from abandoned mines and mills
Find out if your home is a contaminated structure
Use regulated water for human needs

Never use unregulated water for human needs - even if it looks ok

Use good water hauling practices to keep your water clean

Get regular cancer screenings including mammograms and
colonoscopies

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COMMUNITY INVOLVEMENT:
SUMMARY OF ACCOMPLISHMENTS (2014-2019)

/ Over 20 outreach events organized or attended by the Interagency
Community Outreach Network.

J Increased agency coordination and communication by selecting a
Community Network Liaison, participating In monthly calls .in annual
meetings, developing and distributing educational outreach material.

~ Expanded educational outreach through the development and
implementation of "Uranium 101" workshops, participation In
STEM events at local schools, and training 90 Community Health
Representatives.

J Opened and staffed the Community Outreach Network Office in
Window Rock.

Dine' Uranium Remediation Advisory Commission meeting at Tachee-Blue Gap chapter house to hear comments from community members.

BACKGROUND

Community involvement is an important part of the work to address the legacy of uranium
contamination on the Navajo Nation, Each federal agency involves communities in the specific work
it does, providing updates and ensuring that community members can help shape decisions affecting
their community. The Community Outreach Network (Network) was formed in 2015 by the federal
and Navajo Nation agencies working on abandoned uranium mine issues: ATSDR, BIA, DOE, EPA, IHS,
NRC, NNEPA, NNAML, and NNDOH. The Network plans and coordinates outreach events to enhance
community understanding of the work agencies are doing to address uranium contamination on
the Navajo Nation. Together, these activities have resulted in an unprecedented level of outreach to
communities.

Primarily, the Network:

Shares information about abandoned uranium mines and former uranium mills and how
communities can be engaged,

Increases general understanding of uranium issues, and

Communicates how each agency addresses and provides services regarding uranium issues.

The Network ensures broad information sharing and partnership building with Navajo communities.
All agencies strive to deliver outreach that is culturally sensitive, considerate of Navajo community
preferences and culture, and presented appropriately to each specific audience. The Network conducts
outreach by attending and providing information at local Chapter meetings and community events,
conducting presentations, distributing informative materials, and communicating with tribal legislative
committees and executive leadership.

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COMMUNITY INVOLVEMENT PROGRESS

The following highlight some of the ways that the various Network agencies worked together to

achieve the goal of coordinating outreach and education.

• Community Outreach Liaison: In 2015, a Community Outreach Liaison was hired to connect
tribal community members and leaders with the Network agencies.The liaison also facilitates
communication among the agencies and coordinates participation in local events on behalf of
the network. A public affairs specialist and an administrative assistant assist the liaison.

• Community Outreach Office and Visitors Center: In June 2016, a community outreach office
and visitor center opened in Window Rock, AZ.The office is a resource for the Network and
participating agencies and programs, and provides community members information on uranium
issues and cleanup work. In 2018, the Network hosted a media event to increase awareness about
the office and invite the public to visit.

• Uranium Awareness Posters and Graphics: In 2014-2015, ATSDR led interagency activities to
create an awareness poster, three fact sheets, and training to accompany these materials. EPA
and IHS were supporting agencies. Capacity building training included a presentation to 90
Community Health Representatives of NNDOH.The trainees delivered posters to 110 Navajo
Chapter houses.The posters include site maps, hydrological information, and health and safety
information. The fact sheets are widely distributed by multiple agencies, and appear on the EPA
website.

• Website: A website with relevant information regarding uranium issues and links to resources has
been developed: https://www.epa.gov/navajo-nation-uranium-cleanup/five-year-plan-address-
impacts-uranium-contamination.

• Resource List: The Network created a resource list for communities with points of contacts for
common uranium issues, such as the Radiation Exposure Compensation Act, safe drinking water,
home radiation scans, and abandoned uranium mine areas.The list has become a valuable tooi
for the community, and has been distributed widely since its original release.The resource list

is distributed at all outreach events to include Chapter house meetings, Health Fairs, Navajo
Nation Fairs, public meetings, and the Community Outreach Network office. The resource list is
maintained by the Community Outreach Liaison and can be found online at: https://www.epa.
gov/navajo-nation-uranium-cleanup/five-year-plan-documents.

In September 2018, the Network organized a float for the parade during the Navajo Nation Fair and held an educational booth
regarding uranium issues.

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• Uranium 101 workshop: The Network created a Uranium 101 workshop curriculum to be provided
upon request to Chapters affected by past uranium mining and milling. The goal of the workshop

is to provide basic facts on uranium and radioactivity, ways to protect public health by limiting
exposure to uranium, and information about health effects resulting from exposure to uranium.

Knowledge enhancement through courseware sharing: In 2018, the Network worked with
Navajo Technical University to pilot an offering of'Fundamental Health Physics"for students. This
courseware sharing provides opportunity for Navajo Nation colleges and universities to share online
course materials used at the NRC and enhance their capacity to train students in topics related to
remediation efforts.

• Community Open Houses, Site Tours, and Community Events: The Network continues to host
open houses, site tours, and participate in a variety of community events. The Network participates
annually at Navajo Nation fairs in Crownpoint, Shiprock,Tuba City, and Window Rock.

• Network Agency Coordination: For more effective coordination and communication about
uranium related issues, the Network's federal agencies and tribal departments, programs, and offices
participate in monthly calls. These calls are for coordinating outreach and public information, such
as development of a Uranium 101 community workshop curriculum. Additionally, the Network
holds annual Network meetings that are used to discuss accomplishments, identify outreach
opportunities, and address lessons learned from participating agencies and programs.

Network agencies also created agency specific outreach materials and hosted numerous community
meetings. For example, DOE created the Legacy Management Navajo Nation Sites Fact Sheets, which
provide background on DOE programs, description of clean up and long-term surveillance and
maintenance activities, and contact information for each site. EPA has created fact sheets, participated
in Chapter meetings, and hosted informational meetings in communities throughout the Navajo
Nation where abandoned uranium mines are located.The NRC created a descriptive brochure on the
distinct oversight role of the agency in DOE's long-term surveillance plans and the agency's ongoing
outreach and engagement with the Navajo Nation. In addition, EPA and DOE are creating Community
Involvement Plans that describe how each agency will provide community members with accurate, timely,
and understandable information that is considerate of their communication preferences and culture.
The Community Involvement Plans aiso document how each agency wiil coordinate with community
members and tribal leaders to ensure that community concerns and goals are considered in the decision-
making processes.

In September 2018, NNAML organized a STEM outreach event for youth at the Kirtland High School that Network agencies
participated in.

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GOALS FOR THE NEXT 10 YEARS

Federal and Navajo Nation agencies will conduct the following:

Short Term (3 Years)

Market and support increased community use of the Community Outreach office.

Expand community outreach to include:

» Chapter meetings

» Navajo Nation Council Committee meetings
» Navajo grassroots groups

Host annual Network meetings for federal and tribal agencies, departments, programs, and
offices.

Educate the affected Navajo communities about the federal government's programs and
processes. A clear explanation of the authorities and limitations will help community members
understand the role of the federal government.

Develop a Navajo language glossary to aid in translation of technical and scientific terminologies
related to uranium.

Conduct Uranium 101 workshops for Chapters and other audiences.

Medium Term (5 Years)

Develop Uranium 101 materials for use by community organizations.

Support Navajo Technical University goals for continued curriculum enhancements in radiation
safety, including development of certificate or degree programs as determined and designed by
the NTU faculty.

Continue environmental health coordination and community health outreach.

Ongoing

Improve communications on the radio, social media outlets, and short video spots using the
Navajo language and story boards (posters).

Continue to use qualified Navajo interpreters.

Increase inclusion of Navajo Fundamental Law in work products and planning through
discussions with NNEPA.

Plan and organize outreach events annually at four of the Navajo Nation fairs.

Log community concerns/information needs and past outreach activities by Chapter, Navajo

agency, and date submitted and completed.

Provide consistent and updated information about abandoned uranium mines to the Dine
Uranium Remediation Advisory Commission, the Navajo Nation government, and the Tribal
Council.

In September 2016, the Network held an educational booth regarding uranium issues at the Navajo Nation fair.

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BACKGROUND

EPA is committed to maximizing federal contract authorities to create safe jobs for Navajo workers, and
build capacity for Navajo-owned businesses and institutions to perform this work.These opportunities
will increase as cleanup work at the mines accelerates.

NAVAJO WORKFORCE DEVELOPMENT:
SUMMARY OF ACCOMPLISHMENTS (2008-2019)

Provide Job
Opportunities and
Workforce Development
throughout the Navajo
Communities

/ To date, over 200 jobs were provided to Navajo workers,

/ EPA awarded over $16 million in cooperative agreements to Navajo
Nation agencies and over $7.85 million in contracts to Navajo-owned
businesses.

/ EPA provided funds to eight Navajo businesses.

REPORT OF FUNDING

Since 2008, EPA awarded over $11 million to the NNEPA Superfund Program to support their oversight
of this work and $3.08 million to Community Housing Infrastructure and Development for the
replacement of 12 contaminated structures. And since 2016, EPA awarded $1.37 million to Navajo AML
program for technical assistance and $809,467 to Dine College to determine the impact of abandoned
uranium mines on the Cove watershed. EPA awarded $7.85 million to Navajo-owned businesses for
work related to the abandoned uranium mines.

Dinttahdoo

Una Ba Inc.

Arrow

Cultural

Indian

Resources

Contractors

Management

(DCRM)

Navajo
frtgineeringf.
Construction
Authority

Dine Various Clawson

Construction Havajo | Excavating Inc.
Interpreters

Infrastructure

DoYetuiMnenit

niEwCMfca

Work Provided to Navajo Owned Businesses

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NAVAJO WORKFORCE DEVELOPMENT PROGRESS

2012-2016

EPA's Superfund JobTraining Initiative trained 19 Navajo community members.

NNEPA partnered with the Northern Arizona University Institute for Tribal Environmental
Professionals on an environmental workforce development and job training program funded
by EPA. A class of 36 Navajo community members graduated from a four-week training about
hazardous waste operations, site worker safety standards, radiation hazards, other workplace health
hazards, and cultural response to hazardous environments.

2017

EPA awarded Arrow Indian Contractors, a Navajo-owned company, a $3.85 million contract to clean
up portions of the Quivira Mines. The mines are in the Coyote Canyon and Standing Rock Chapters
on Navajo Nation in McKinley County, NM.The work included excavating contaminated soil and
rebuilding the Red Water Pond Road bridge to accommodate heavy equipment. Arrow Indian
Contractors also built and repaired roads and culverts as needed.

EPA awarded Tetra Tech, Inc. (TetraTech) the Response, Assessment, and Evaluation Services
contract, worth up to $85 million over 5 years.This is the first known contract solicitation that
included evaluation criteria explicitly developed to encourage Navajo employment and training
opportunities, Tetra Tech will initially assess uranium contamination at 30 abandoned uranium
mines in and around the Navajo Nation. Tetra Tech will also partner with Navajo Technical University
and local businesses to train Navajo members in professional positions related to assessment and
cleanup work. In addition, Tetra Tech has committed to procure services and supplies, whenever
possible, from Navajo-owned businesses, helping boost the local economy and create jobs. Under
the contract, Tetra Tech will regularly report assessment, training, and purchasing results to the
agency and the public.

2018

EPA awarded Clawson Excavating, Inc., a Navajo-owned company, a contract for $1,127,000 to
construct a road in Cove to access abandoned uranium mines.

2019

EPA awarded Clawson Excavating, Inc. a contract for $1,000,000 for a time-critical removal action in
Cove entailing implementation of erosion control measures at Mesa II.

EPA released a Request for Proposal for the Navajo Area Abandoned Mines response and
Construction Services contract.The contract, worth an estimated $220 million, is open for proposals
exclusively from small businesses.

In 2019, EPA 9 Regional Administrator Mike Stoker met in Window Rock, AZ with Navajo Nation President Jonathan Nez and
Navajo Nation Vice President Myron Lizerand co-regulators NNEPA to discuss mutual environmental priorities on workforce
development with the abandoned uranium mine work.

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GOALS FOR THE NEXT 10 YEARS

Build capacity and hire Navajo individuals and companies

» Use contract evaluation criteria and outreach tools to maximizes employment opportunities
for Navajo people while building capacity with local business and institutions to perform the
work.

Promote jobs and business opportunities with support of the Navajo Nation

» Encourage EPA and potentially responsible party contractors to advertise jobs on the Navajo
Nation via different methods—radio, newspaper, or a centralized location where Navajo
opportunities are published.

» Conduct"lndustry Days"job fair for all major contract opportunities related to this program.

» Continue to attend and support outreach events with other career development agencies.

The Quivira mine waste pile and the repaired bridge completed in 2018 by Arrow Indian Contractors, a Navajo-owned company.

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CO
LU

AGENCY AUTHORITIES/
ROLES

FEDERAL AGENCIES

EPA

EPA addresses issues related to contaminated abandoned uranium mines and
contaminated structures. EPA conducts this work under CERCLA. EPA also approves
BIA's work atTuba City Dump under a settlement agreement entered into pursuant to
CERCLA, and will select the remedy at this site. In addition, EPA funds construction of
drinking water infrastructure projects under the Safe Drinking Water Act.

BIA

BIA serviced Tuba City Dump (near the Navajo town of Tuba City and the Hopi Villages
of Moenkopi), which was used by the surrounding communities for 50 years until its
administrative closure in 1997. BIA is a potentially responsible party at the site.

DOE

Under UMTRCA, the DOE-LM is conducting long-term surveillance and maintenance
at the four former uranium mill processing sites within the Navajo Nation. DOE-LM
operates groundwater remediation systems at the Tuba City, Mexican Hat, and Shiprock
sites. UMTRCA amended the Atomic Energy Act of 1954 to authorize NRC to oversee
DOE under a general license at covered uranium milling disposal sites, including these
four sites.

NRC

NRC regulates and oversees DOE-LM's activities under UMTRCA at all four of the former
uranium mill processing sites on the Navajo reservation that contain disposal cells,
and oversees DOE-LM monitoring and maintenance activities at all four of the former
processing sites.

Navajo Area IHS

The Navajo Area IHS provides health care to eligible American Indians through
a network of hospitals and health centers. IHS also funds and develops water
infrastructure projects to serve Navajo homes.

ATSDR

ATSDR protects communities from harmful health effects related to exposure to natural
and man-made hazardous substances. We do this by responding to environmental
health emergencies; investigating emerging environmental health threats; conducting
research on the health impacts of hazardous waste sites; and building capabilities of and
providing actionable guidance to state and local health partners.

¦
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NAVAJO NATION PARTNERS

NNEPA is a co-regulator, implementing the Navajo CERCLA law, Navajo Water Quality Standards, and
the Navajo Safe Drinking Water Act.

NNEPA

NNEPA implements the Contaminated Structures Program and oversees the abandoned uranium
mine cleanup process. Since 2008, EPA has provided $10 million to the Navajo Superfund Program for
this work, and NNEPA has direct access to oversight funds for work at 140 mines. Additionally, NNEPA
received $45 million from theTronox settlement. For more information visit www.navaioepa.org.

NNAML

The NNAML provides technical assistance and expertise during the mine reclamation process. Since
2017, EPA provided over $1M to NNAML for this work.

NNUMTRA

The NNUMTRA Program oversees, monitors, and reviews remedial action work at the four uranium mill
sites managed by DOE-LM. Since 2013, DOE-LM has provided $22.5M to the NNUMTRA Program for this
Work.

NND0H

NNDOH participates in health studies and conducts medical screenings related to uranium exposures.

Navajo Nation Engineering and Construction Authority

The Navajo Nation Engineering and Construction Authority builds water infrastructure projects, Navajo
Tribal Utility Authority operates and maintains those systems, and NNEPA regulates them.

Dine Uranium Remediation Advisory Commission

The Dine Uranium Remediation Advisory Commission is an advisory commission in the Executive
Branch of the Navajo Nation Government that was established to study and reach conclusions
about the impacts of uranium mining and uranium processing on the Navajo Nation and to make
recommendations to the Navajo Nation President and Navajo Nation Council for policies, laws and
regulations to address those impacts.

Other Partners

Other partners include Dine College, Navajo
Technical University, and iina ba, a local Navajo
firm. EPA awarded over $800,000 to Dine College
to help determine the impact of the mines in
the Cove watershed and to conduct community
outreach. EPA's Response, Assessment, and
Evaluation Services contractor,Tetra Tech, will
partner with the Navajo Technical University to
provide trainings to build the capacity of Navajo
people to support the mine cleanup work.

They will also work with iina ba for engineering
assessment, environmental consulting and
translation services.

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For More Information, visit:
www.epa.gov/navajo-nation-uranium-cleanup

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