oversight

Uranium Mining: Opportunities Exist to Improve Oversight of Financial Assurances

Published by the Government Accountability Office on 2012-05-17.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

             United States Government Accountability Office

GAO          Report to the Ranking Member,
             Committee on Natural Resources,
             House of Representatives


May 2012
             URANIUM MINING

             Opportunities Exist to
             Improve Oversight of
             Financial Assurances




GAO-12-544
                                            May 2012

                                            URANIUM MINING
                                            Opportunities Exist to Improve Oversight of
                                            Financial Assurances
Highlights of GAO-12-544, a report to the
Ranking Member, Committee on Natural
Resources, House of Representatives




Why GAO Did This Study                      What GAO Found
From 2005 through 2007, uranium             The Bureau of Land Management (BLM), the Forest Service, and the
prices increased from about $20 a           Department of Energy (DOE) are the key agencies that oversee uranium
pound to over $140 a pound, leading to      exploration and extraction on federal land, but GAO identified three areas where
renewed interest in uranium mining on       their oversight processes differ. First, these agencies have different processes
federal land. This interest has raised      for notification of uranium exploration or extraction activities on federal land.
concerns about the potential impacts        Second, the agencies require operators to have in place financial assurances to
that more uranium operations could          cover the full estimated cost of reclaiming a uranium operation, but they differ in
have on the environment. GAO was            who estimates the value of the financial assurance and the frequency of their
asked to (1) compare key agencies’
                                            reviews of the assurances. Third, under existing authorities, DOE can collect
oversight of uranium exploration and
                                            royalties or rents for uranium extraction, but BLM and the Forest Service cannot.
extraction operations on federal land,
(2) determine the number and status of
                                            DOE has collected about $64 million in rents and royalties from its leasing
uranium operations on federal land,         program since the 1940s.
(3) identify the coverage and amounts       As of January 2012, a total of 221 uranium operations were on federally
of financial assurances for reclaiming      managed land, but only 7 were actively extracting uranium and all of these were
current uranium operations on federal       on BLM land. An additional 29 uranium operations were awaiting federal
land, and (4) examine what is known         approval. Of the 202 operations on BLM land, the majority were engaged in
about the number and location of            either reclamation or exploration activities, according to BLM field officials. In
abandoned uranium mine sites on
                                            addition, 3 uranium operations were on Forest Service land, and 16 operations
federal land and their potential cleanup
                                            were on lease tracts that DOE manages, none of which were actively extracting
costs. GAO reviewed agency reports
and regulations, surveyed relevant          uranium.
agency field staff on the status of these   As of January 2012, BLM, the Forest Service, and DOE reported having $249.1
operations, and examined federal data       million in financial assurances, and these assurances were generally adequate to
on uranium operations, financial            cover the estimated reclamation costs for uranium operations on federal land.
assurances, and abandoned uranium           Nearly all of these assurances ($247.6 million) were for authorized uranium
mine sites.                                 operations on BLM-managed land, with the remaining $1.5 million for authorized
What GAO Recommends                         operations on Forest Service land and for DOE’s lease tracts. BLM and the
                                            Nuclear Regulatory Commission (NRC), which is responsible for overseeing
GAO recommends, among other                 some aspects of uranium operations on federal land, do not coordinate efforts to
things, that federal agencies better        establish and review financial assurances for in situ recovery operations, which
coordinate their efforts when               use a series of wells to extract uranium. Such operations account for a large
establishing financial assurances and       percentage of the total financial assurances held by the agencies.
develop a consistent definition for
abandoned mine sites. The                   Federal agencies do not have reliable data on the number and location of
Departments of the Interior,                abandoned uranium mine sites on federal land or a definitive cost for their
Agriculture, and Energy, along with         cleanup. There are likely thousands of abandoned uranium mine sites on federal
NRC and the Environmental Protection        land, but GAO identified significant limitations in agencies’ data that make their
Agency (EPA), concurred with these          databases generally unreliable. For example, these databases do not have
recommendations. In addition, Interior      complete data and do not use a consistent definition of an abandoned mine site.
and EPA provided technical                  Agencies do not know how many sites will need cleanup, and they do not have
comments, which GAO incorporated as         information on the total cost to clean up these sites. Based on agencies’
appropriate.                                experiences with cleanup at some sites, cleanup costs could vary significantly
                                            from thousands to hundreds of millions of dollars, depending on site-specific
                                            conditions and the amount and type of work required at each site.

View GAO-12-544. For more information,
contact Anu K.Mittal, (202) 512-3841,
mittala@gao.gov

                                                                                     United States Government Accountability Office
Contents


Letter                                                                                 1
               Background                                                              5
               Agencies Differ in Their Oversight of Uranium Operations on
                 Federal Land                                                        13
               Over 200 Uranium Operations Are on Federal Land, but Few Are
                 Actively Extracting Uranium                                         20
               Agency Data Indicate That Financial Assurances Adequately Cover
                 Nearly All Operations, but BLM and NRC Do Not Coordinate in
                 Establishing Some Assurances                                        25
               Federal Agencies Do Not Have Reliable Data on the Number and
                 Location of Abandoned Uranium Mines or Their Associated
                 Cleanup Costs                                                       30
               Conclusions                                                           39
               Recommendations for Executive Action                                  40
               Agency Comments                                                       41

Appendix I     Objectives, Scope, and Methodology                                    43



Appendix II    Information on In Situ Recovery Operations on BLM Land That Are
               Extracting Uranium, on Standby, or Awaiting Federal Authorization     49



Appendix III   Detailed Information on Federal Abandoned Mine Databases              50



Appendix IV    Examples of Cleanup Activities at Abandoned Uranium Mine Sites        52



Appendix V     Comments from the Department of Agriculture                           58



Appendix VI    Comments from the Department of Energy                                59



Appendix VII   Comments from the Department of the Interior                          61




               Page i                                           GAO-12-544 Uranium Mining
Appendix VIII   Comments from the Environmental Protection Agency                       62



Appendix IX     Comments from the Nuclear Regulatory Commission                         64



Appendix X      GAO Contact and Staff Acknowledgments                                   66



Tables
                Table 1: Summary of Notification Requirements for Uranium
                         Operations across Three Agencies                               15
                Table 2: Summary of Financial Assurance Requirements for
                         Uranium Operations across Three Agencies                       16
                Table 3: Results of GAO’s Survey of BLM Field Offices on Status of
                         Uranium Operations                                             22
                Table 4: Summary of Operations That Are Extracting Uranium on
                         BLM Land                                                       23
                Table 5: Limitations with Four Federal Agencies’ Databases on
                         Abandoned Uranium Mines                                        34
                Table 6: Ranges of Costs for Conducting Cleanup Activities at
                         Selected Abandoned Uranium Mine Sites                          37
                Table 7: Information on ISR Operations Located on BLM-Managed
                         Land and Their Associated Financial Assurance                  49
                Table 8: Information on Federal Abandoned Mine Databases and
                         Their Limitations                                              50
                Table 9: Examples of Cleanup Activities at Abandoned Uranium
                         Mine Sites                                                     52


Figures
                Figure 1: Open Pit and Underground Uranium Mining                         7
                Figure 2: ISR Extraction Process for Uranium                              9
                Figure 3: Examples of Cleanup Activities That Could Take Place at
                         Abandoned Uranium Mine Sites                                   36




                Page ii                                            GAO-12-544 Uranium Mining
Abbreviations
AMSCM           Abandoned Mine-Site Cleanup Module
BLM             Bureau of Land Management
CERCLA          Comprehensive Environmental Response, Compensation,
                and Liability Act
DOE             Department of Energy
EIA             Energy Information Administration
EPA             Environmental Protection Agency
ISR             in situ recovery
MRDS            Mineral Resources Data System
NEPA            National Environmental Policy Act
NRC             Nuclear Regulatory Commission
UIC             underground injection control
USGS            U.S. Geological Survey


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Page iii                                                       GAO-12-544 Uranium Mining
United States Government Accountability Office
Washington, DC 20548




                                   May 17, 2012

                                   The Honorable Edward J. Markey
                                   Ranking Member
                                   Committee on Natural Resources
                                   House of Representatives

                                   Dear Mr. Markey:

                                   From 2005 through 2007, uranium prices increased from about $20 a
                                   pound to over $140 a pound, which led to renewed interest in uranium
                                   mining—both exploration and extraction—on federal land in the United
                                   States. In early April 2012, prices were about $50 per pound, but
                                   thousands of claims have been filed to explore for and potentially extract
                                   uranium on federal land. This increase in claims filed—the first step in a
                                   potentially lengthy process to explore and extract uranium—has raised
                                   concerns about the potential impacts that an increased level of uranium
                                   exploration and extraction could have on the environment. For example,
                                   during uranium extraction, the waste rock piles that are formed can
                                   introduce radionuclides (such as radium) and heavy metals (such as
                                   selenium and arsenic) into the environment. Before the mid-1970s, many
                                   mines on federal land, including uranium mines, were abandoned without
                                   any reclamation, leaving a costly legacy of abandoned mines that pose
                                   potential health, safety, and environmental hazards. Some of these
                                   hazards include open or concealed mine openings, unstable mine
                                   structures, and toxic or radioactive materials. In 2008, we reported that
                                   from fiscal years 1998 to 2007, the federal government had spent billions
                                   to reclaim abandoned hardrock mines, which include uranium mines. 1

                                   To mitigate these potential health, safety, and environmental hazards,
                                   mining operators are responsible for addressing safety hazards and
                                   reclaiming the site after their operations have ceased. 2 Activities that


                                   1
                                    GAO, Hardrock Mining: Information on Abandoned Mines and Value and Coverage of
                                   Financial Assurances on BLM Land, GAO-08-574T (Washington, D.C.: Mar. 12, 2008).
                                   2
                                    Under the Federal Land Policy Management Act of 1976, the Bureau of Land
                                   Management (BLM) issued regulations, effective in 1981, that required all mining
                                   operators to reclaim BLM land disturbed by hardrock mining. In 2001, BLM regulations
                                   began requiring all mining operators to provide financial assurances before beginning
                                   exploration or mining operations on BLM land. The Forest Service began requiring
                                   reclamation and financial assurances in 1974.




                                   Page 1                                                       GAO-12-544 Uranium Mining
address safety hazards can include installing gates over mine openings.
Reclamation activities can include reapplication of topsoil, and reshaping
and revegetation of disturbed soil areas; measures to control erosion,
landslides, and water runoff; measures to isolate, remove, or control toxic
materials; and rehabilitation of fisheries and wildlife habitat.3 Operators
are required to obtain financial assurances to cover estimated
reclamation costs, and the federal government can use these assurances
to pay for reclamation activities if the operator does not reclaim the site.4
Our past work has raised concern about the adequacy of financial
assurances to cover potential reclamation costs for hardrock mining
operations, including uranium, on federal land.5

A number of federal agencies are involved in the oversight of uranium
mining activities on federal land. The Department of the Interior’s Bureau
of Land Management (BLM) and the Department of Agriculture’s Forest
Service regulate mining on public domain lands under the General Mining
Act of 1872 and other federal land management laws, including the
Federal Land Policy Management Act of 1976. The Department of Energy
(DOE) administers a uranium leasing program on land that has been
withdrawn from the public domain under the Atomic Energy Act of 1954.
In addition, the Nuclear Regulatory Commission (NRC) regulates a newer
form of extraction, known as in situ recovery (ISR), as a form of uranium
milling. The Environmental Protection Agency (EPA) oversees or
participates in the remediation of some abandoned mines and sets




3
See 43 C.F.R. § 3809.420 (2011); 36 C.F.R. § 228.8 (2011).
4
 These financial assurances, also referred to as bonds, include a variety of financial
instruments. For example, a surety bond is a third-party guarantee that an operator
purchases from a private insurance company approved by the Department of the
Treasury. The operator must pay a premium to the surety company to maintain the bond.
These premiums can vary depending on various factors, including the amount of the bond
and the assets and financial resources of the operator, among other factors.
5
 GAO, Hardrock Mining: BLM Needs to Revise Its Systems for Assessing the Adequacy of
Financial Assurances, GAO-12-189R (Washington, D.C.: Dec. 12, 2011); Abandoned
Mines: Information on the Number of Hardrock Mines, Cost of Cleanup, and Value of
Financial Assurances, GAO-11-834T (Washington, D.C.: July 14, 2011); Hardrock Mining:
BLM Needs to Better Manage Financial Assurances to Guarantee Coverage of
Reclamation Costs, GAO-05-377 (Washington, D.C.: June 20, 2005).




Page 2                                                       GAO-12-544 Uranium Mining
environmental standards for certain sites. 6 Federal agencies may also
work with state agencies in overseeing uranium activities. For example,
federal agencies may share responsibilities with states for reviewing
financial assurances.

You asked us to provide information on the status of uranium mining on
federal land. Our objectives were to (1) compare BLM, the Forest Service,
and DOE oversight of uranium exploration and extraction operations on
federal land; (2) determine the number and status of uranium operations
on federal land; (3) examine the coverage and amounts of financial
assurances in place for reclaiming current uranium operations on federal
land; and (4) examine what is known about the number and location of
abandoned uranium mines on federal land and their potential cleanup
costs.

To compare how BLM, the Forest Service, and DOE oversee uranium
exploration and extraction operations on federal land, we reviewed these
agencies’ regulations and associated guidance and spoke with agency
officials about their implementation of these regulations. 7 In addition, we
reviewed NRC and EPA regulations that are relevant to uranium
operations and spoke with officials from those agencies. We also
reviewed memorandums of understanding among the agencies that
delineate their coordination and cooperation in regulating uranium
operations, and we spoke with state mining and environmental quality
officials to discuss their coordination with federal agencies. To determine
the number and status of uranium operations on federal land, we
analyzed data from BLM’s LR2000 database, which is used to collect and


6
 Remediation refers to the containment or treatment of hazardous substances.
Remediation work at a mine site can involve removing contaminated waste rock or soil to
an off-site location. In addition, contaminated surface or underground water may need to
be remediated using a water treatment facility. As described above, reclamation activities
may include measures to isolate, remove, or control toxic materials, work that could also
be characterized as remediation. Environmental remediation could also be required after a
mine is abandoned if reclamation was not properly completed or if new or unforeseen
problems arise after abandonment.
7
 We did not include tribal lands in our review of uranium operations on federal land.
Currently, there are no active uranium mining operations on tribal lands; however, there
are abandoned uranium mines on these lands that will require extensive remediation in
some cases. We have included an example of the anticipated remediation actions needed
at one such site later in our report. In addition, EPA, DOE, NRC, the Bureau of Indian
Affairs, and the Indian Health Service are implementing a 5-year plan to address the
health and environmental impacts of uranium contamination in the Navajo nation.




Page 3                                                        GAO-12-544 Uranium Mining
store information on BLM land and programs, including hardrock mining
operations. In addition, we administered a web-based survey to all BLM
field staff with responsibilities for uranium operations and asked them to
provide the status of these operations. Because the Forest Service and
DOE oversee fewer operations, we did not send them our web-based
survey, but instead reviewed agency documents and interviewed staff
from these agencies to determine the number and status of the
operations that they oversee.

To examine the financial assurances in place for uranium operations on
federal land, we analyzed data and available reports from BLM, the
Forest Service, and DOE. We also interviewed officials from these
agencies on the processes in place to review financial assurances. As
part of this analysis, we examined whether the financial assurances in
place were adequate to cover the estimated costs of reclamation; we did
not determine whether the estimated costs of reclamation were sound. To
learn about the number and location of abandoned uranium mines on
federal land, we reviewed data and interviewed officials from BLM, the
Forest Service, EPA, the National Park Service, and DOE, which are all
involved in efforts to clean up abandoned uranium mines. To assess the
reliability of these data, we reviewed documentation from these agencies
on their data and interviewed officials involved in collecting and compiling
these data. We determined that these data were not sufficiently reliable.
Because these data were the only federal data available, we used them
to discuss in general terms the potential number of abandoned mine
sites, and we describe the limitations of these data. To describe the
potential cleanup costs posed by these mines, we identified a series of
key cleanup categories that we and agency officials believe are
representative of the types of actions that may be required at an
abandoned mine. These cleanup categories include actions to (1)
address safety hazards, (2) conduct surface reclamation, and (3)
remediate environmental hazards. 8 Cleaning up an abandoned mine may
involve work that falls across several of these cleanup categories. To
provide a range of potential costs for such cleanup work, we asked
federal officials for information on past work done to clean up abandoned
uranium mines or, if no past work was available, we asked for detailed
estimates. We conducted this performance audit from June 2011 through


8
 For the purposes of describing the work conducted on abandoned uranium mines, we are
using the term “cleanup” to encompass the variety of activities necessary to address
conditions at abandoned mine sites.




Page 4                                                    GAO-12-544 Uranium Mining
             May 2012 in accordance with generally accepted government auditing
             standards. Those standards require that we plan and perform the audit to
             obtain sufficient, appropriate evidence to provide a reasonable basis for
             our findings and conclusions based on our audit objectives. We believe
             that the evidence obtained provides a reasonable basis for our findings
             and conclusions based on our audit objectives. A more detailed
             description of our scope and methodology is presented in appendix I.


             Uranium is a hardrock mineral, and most U.S. uranium deposits are
Background   located in the western half of the United States, specifically in the states
             of Arizona, Colorado, New Mexico, Texas, Utah, and Wyoming. 9 In the
             United States, uranium has been primarily used as a fuel for electric
             power generation and for nuclear weapons. In 2010, U.S. uranium mines
             extracted 4.2 million pounds of uranium, 2 percent more than in 2009,
             according to DOE’s Energy Information Administration (EIA). 10 However,
             domestic production of uranium is not sufficient to meet domestic
             demand, and the United States imports over 90 percent of its uranium
             from countries such as Australia, Canada, and Russia.

             Hardrock mining operations consist of four primary stages—exploration,
             extraction, mineral processing, and reclamation. Several of these stages
             can take place simultaneously, depending on the characteristics of the
             operation. Exploration involves prospecting and other steps, such as
             drilling, to locate mineral deposits. Extraction generally entails developing
             the mining infrastructure (power, buildings, and roads) needed for
             extraction, as well as drilling, blasting, and hauling ore from mining areas
             to processing areas. During processing, operators crush or grind the ore
             and apply chemical treatments to extract the minerals of value. The


             9
              Under U.S. mining laws, minerals are classified as locatable, leasable, or saleable. The
             General Mining Act of 1872 17 Stat. 91 (codified at 30 U.S.C. § 22 et. seq.) allows
             individuals to stake claims for locatable minerals, such as uranium, copper, lead, zinc,
             magnesium, gold, and silver. For the purposes of this report, we use the term “hardrock
             minerals” as a synonym for “locatable minerals.” The Mineral Leasing Act of 1920, 41 Stat.
             437 (codified at 30 U.S.C. § 181) created a leasing system for certain minerals such as
             coal, gas, oil and other fuels, and chemical minerals, which are known as leasable
             minerals. In 1955, the Multiple Use Mining Act of 1955, 69 Stat. 367 (codified at 30 U.S.C.
             § 601) removed common varieties of sand, stone, and gravel from development under the
             Mining Act, and these minerals are known as saleable minerals.
             10
               Production data are for pounds of uranium oxide (U3O8) extracted from federal, state,
             and private land.




             Page 5                                                         GAO-12-544 Uranium Mining
material left after the minerals are extracted—waste rock or tailings (a
combination of fluid and rock particles)—is then disposed of, often in a
nearby pile or tailings pond. As described earlier, reclamation activities
can include reshaping and revegetating disturbed areas; measures to
control erosion; and measures to isolate, remove, or control toxic
materials. While uranium mining operations are similar to other hardrock
mining operations in environmental concerns, the wastes produced
require additional environmental controls. Of particular concern is the
presence of the natural by-products of uranium radioactive decay, most
notably radium and the radioactive gas radon, as well as heavy metals,
such as arsenic. All of these byproducts can pose a serious risk to human
health or the environment, especially if they migrate to surface or ground
water, or enter the environment after transforming into dust.

Uranium is extracted using one of three processes—underground mining,
open pit mining, or ISR. Open pit and underground mining are generally
considered conventional uranium extraction processes. In these
processes, uranium ore is removed from the ground and is sent to an off-
site processing facility, called a mill, where extracted uranium is
concentrated into a product called yellowcake (U3O8). 11 The optimum
extraction process is determined by the size, grade, depth, and geology
of an ore body. Open pit mining is generally used for ore deposits
relatively close to the surface, while underground mining is generally used
for deeper deposits, as shown in figure 1. Open pit mining generally
involves more surface disturbance than underground mining, and the
amount of waste rock removed to reach the mineral is greater. Since the
early 1960s until recently, most uranium has been extracted by using
conventional extraction processes.




11
  At the mill, the mined uranium ore is crushed, ground, and then fed to a leaching system
that uses resin and chemicals to separate uranium from the ore. The resulting yellow
slurry—called yellowcake—is washed, dried, and stored in steel drums. Yellowcake
subsequently undergoes a number of processing steps (conversion, enrichment, and fuel
fabrication) to become fuel for nuclear power plants.




Page 6                                                        GAO-12-544 Uranium Mining
Figure 1: Open Pit and Underground Uranium Mining




                                      Unlike conventional extraction processes, ISR, a mining technique
                                      established in the 1970s and anticipated to become more widely used by
                                      the industry in the future, aims to extract uranium with less surface
                                      disturbance. ISR extracts uranium by injecting oxygenated water and
                                      carbon dioxide or sodium bicarbonate hundreds of feet underground to
                                      dissolve uranium located in a subsurface ore body contained within a
                                      layer of sedimentary rock. Once dissolved, the water and uranium mixture
                                      is pumped to the surface, where the uranium is captured on ion exchange
                                      resins, which are taken to a central facility to be processed into
                                      yellowcake. (See fig. 2.) ISR operations typically involve several
                                      wellfields, which are composed of many injection and production wells,
                                      and these wellfields can spread over hundreds or thousands of acres,
                                      with monitoring wells at periodic intervals above, below, and surrounding



                                      Page 7                                            GAO-12-544 Uranium Mining
the aquifer to monitor for groundwater contamination outside the aquifer.
According to industry and government documents, ISR is gaining favor as
the approach to extract uranium because it is a more cost-efficient
method for recovering uranium ore that causes less surface disturbance
and is safer for worker health. 12 The primary risk associated with ISR
operations is the potential for contamination of nearby groundwater.
When ISR operations cease, the groundwater is restored by removing
and stabilizing hazardous metals, such as arsenic and selenium, which
may have been disturbed by the operations, and all the wells are plugged.
Experts currently do not agree on how long it will take to restore a
wellfield after production ceases, or if full restoration is achievable. In a
2009 report on groundwater restoration efforts for 22 ISR wellfields on
private land in Texas, the U.S. Geological Survey (USGS) found that it
was difficult for these operations to restore groundwater to baseline
values for heavy metals, such as uranium and selenium. 13 Specifically,
USGS reported that measured levels of uranium and selenium increased
following restoration efforts in the majority of the wellfields when
compared with baseline values.




12
  According to EIA, the amount of uranium that can be produced economically at a market
price of $50 a pound using ISR—known as a mineral’s reserves—is greater than the
amount that can be produced through underground and open pit uranium mining. EIA,
U.S. Uranium Reserve Estimates (Washington, D.C.: July 2010). Current market prices
are close to $50 a pound. At a higher market price of $100 a pound for uranium, the
reserves for uranium that can be recovered using underground and open pit uranium
mining exceed the reserves for ISR, according to this EIA report.
13
 Susan Hall, USGS, Groundwater Restoration at Uranium In-Situ Recovery Mines, South
Texas Coastal Plain (Reston, Virginia: 2009).




Page 8                                                      GAO-12-544 Uranium Mining
Figure 2: ISR Extraction Process for Uranium




                                        Three federal agencies play key roles in overseeing uranium operations
                                        on federal land: BLM, the Forest Service, and DOE. In addition, NRC,
                                        EPA, and the states are responsible for some aspects of uranium
                                        operations on federal, state, and private land.

                                        •      BLM. BLM manages more than 260 million acres of public lands
                                               located primarily in the western half of the United States. Under the
                                               General Mining Act of 1872 (Mining Act), an individual or corporation
                                               can establish a claim to any hardrock mineral on public land and may


                                        Page 9                                                GAO-12-544 Uranium Mining
      remove all hardrock minerals from the site. Under the Federal Land
      Policy and Management Act of 1976, BLM has developed and revised
      regulations and issued policies to prevent unnecessary or undue
      degradation of BLM land from hardrock operations. BLM issued
      regulations that took effect in 1981 that classified hardrock operations
      into three categories—casual use, notice-level operations, and plan-
      level operations—and required reclamation of the sites at the earliest
      feasible time. BLM issued revised regulations that took effect in 2001,
      to strengthen financial assurance requirements and modify the
      reclamation requirements, among other things. BLM delegates
      primary responsibility for oversight of hardrock operations to its state
      and local field offices.

•     The Forest Service. The Forest Service manages approximately 193
      million acres of national forests and grasslands throughout the United
      States. Forest Service regulations, promulgated under its Organic Act
      of 1897, among other laws, establish rules and procedures intended
      to ensure that hardrock mining operations minimize adverse
      environmental impacts on National Forest System surface resources.
      Since 1974, the Forest Service has required financial assurances for
      mining operations on National Forest System land. The Forest
      Service manages hardrock operations through its headquarters, 9
      regions, 155 national forests and grasslands, and more than 600
      ranger districts.

•     DOE. DOE manages a uranium leasing program on 31 lease tracts, of
      which 29 are currently leased, under the authority of the Atomic
      Energy Act of 1954 (as amended). 14 These lease tracts cover about
      25,000 acres of land located within the Uravan Mineral Belt in
      southwestern Colorado. These leases generally cover a period of 10
      years, and DOE offers these leases through a competitive public bid
      solicitation, which specifies the lease terms, including the minimum
      annual royalties to be collected. DOE awards these leases to those
      operators who offer to pay the highest royalty rate, who become
      known as lessees. This program began in 1948, when BLM withdrew
      certain uranium-rich land from the public domain, and reserved them
      for the use of DOE’s predecessor agency, the Atomic Energy
      Commission, to secure and develop a supply of domestic uranium for
      the nation’s defense needs. DOE manages mining activities, including



14
    DOE’s regulations are codified in 10 C.F.R. § 760.1 (2012).




Page 10                                                           GAO-12-544 Uranium Mining
     exploration and extraction, associated with uranium and vanadium
     mining on these lands. 15 In 2005, DOE considered an expansion of
     the program in the face of increased demand for uranium, and
     initiated an environmental assessment of the program under the
     National Environmental Policy Act of 1969 (NEPA). DOE
     subsequently issued a finding that the expansion would have no
     significant impact on the environment. Environmental groups
     challenged this finding, and in 2011 a federal court prohibited further
     work on the leases as well as the issuance of new leases pending
     completion of a new environmental analysis. 16 DOE is in the process
     of developing a draft Programmatic Environmental Impact Statement
     that is expected to be released for public comment in late 2012.
     According to DOE documents, the lease program has approximately
     13.5 million pounds of uranium left to mine.

•    NRC. NRC is responsible for overseeing uranium milling operations,
     which produce yellowcake from uranium ore. ISR is considered a
     uranium milling operation by NRC because it produces yellowcake.
     NRC reviews ISR license applications, conducts environmental
     analyses and inspections, reviews decommissioning plans and
     activities, and oversees site reclamation and groundwater treatment.
     NRC can relinquish its regulatory authority to a state if the state and
     NRC determine that the state has a program that is adequate to
     protect public health and safety. NRC licenses and oversees ISR
     operations in Nebraska, New Mexico, and Wyoming, while the other
     states with major uranium deposits—Colorado, Texas, and Utah—
     license and oversee operations in their states.

•    EPA and the states. EPA and the states also have a role in
     overseeing some aspects of uranium operations. Under the Clean
     Water Act, for example, EPA or the states issue permits to control




15
  In the area covered by DOE’s leasing program, mined ore contains both uranium and
vanadium. This ore is delivered to the processing facility as a combined commodity, and
the separate uranium and vanadium minerals are recovered during processing.
16
  On February 27, 2012, the same court ruled that certain reclamation activity, including
actions to address dangers to public health and safety and the environment, could
continue. Colorado Environmental Coalition et al. v. Office of Legacy Management et al.
2012 U.S. Dist. LEXIS 24126 (D. Colo. Feb. 27, 2012).




Page 11                                                        GAO-12-544 Uranium Mining
     pollutants that are discharged into the waters of the United States. 17
     Under the Safe Drinking Water Act, the Underground Injection Control
     (UIC) program is designed to protect underground sources of drinking
     water by prohibiting the injection of fluids beneath the surface without
     a permit. 18 Specifically, ISR operations require a class III UIC permit
     for wells because they inject fluids to dissolve and extract uranium.
     Class III wells must be constructed of appropriate materials to handle
     the fluid being injected and must be monitored during operations.
     When injection activities are complete, the injection wells must be
     plugged. In addition, under the Superfund program, established by the
     Comprehensive Environmental Response, Compensation, and
     Liability Act (CERCLA) of 1980, EPA, or, in some instances, other
     federal agencies if the contamination is on their land, has the authority
     to compel parties responsible for contaminating sites to clean them up
     or to clean the sites up itself and seek reimbursement. EPA places
     some of the most contaminated sites on the National Priority List, and
     resources from a federal trust fund, the Superfund, are available to
     pay for long-term cleanup at these sites. In addition, under the
     Uranium Mill Tailings Radiation Control Act, EPA has established
     standards for control of radioactive contamination to soil, air, and
     groundwater at certain uranium processing sites. 19 NRC regulations
     make EPA’s groundwater protection standards generally applicable to
     uranium milling sites, including ISR operations.

States may play additional roles in regulating uranium operations on
federal land. In general, states may have their own requirements
governing the review of mining plans, environmental performance
standards, reclamation, financial assurances, and inspection. For
example, many states with uranium deposits require that an operator
provide a financial assurance for the full cost of reclamation for a mining




17
  Arizona, Colorado, Utah, and Wyoming have been approved to implement this permit
program, known as the National Pollutant Discharge Elimination System program, at the
state level. Texas has approval for a partial program.
18
  New Mexico, Texas, Utah, and Wyoming, four states with uranium deposits, have been
approved to implement the UIC program at the state level. Colorado implements its UIC
program jointly with EPA.
19
 EPA is currently reviewing its existing groundwater standards under 40 C.F.R. pt. 192.




Page 12                                                      GAO-12-544 Uranium Mining
                             site. 20 Memorandums of understanding among the federal and state
                             agencies aim to encourage coordination between states and federal
                             agencies in overseeing mining operations.

                             Federal agencies must also comply with NEPA. NEPA requires federal
                             agencies to analyze the likely environmental effects of proposed projects,
                             which may include uranium mines, using an environmental assessment
                             or, if the projects would likely significantly affect the environment, a more
                             detailed environmental impact statement evaluating the proposed project
                             and alternatives. An environmental impact statement results in a record of
                             decision that lays out how anticipated environmental impacts will be
                             mitigated.


                             BLM, the Forest Service, and DOE all oversee uranium exploration and
Agencies Differ in           extraction operations on the federal land they manage, but we identified
Their Oversight of           three areas where their processes differ: (1) notification of exploration or
                             extraction operations, (2) oversight of financial assurances, and (3)
Uranium Operations           royalties and rents earned.
on Federal Land

BLM, the Forest Service,     BLM, the Forest Service, and DOE require uranium operators to provide
and DOE Have Different       notification of their intent to undertake either uranium exploration or
Processes for Notification   extraction activities on federal land, but their notification processes differ
                             slightly. Under regulations for proposed activities on BLM land, “casual
of Exploration or            use”—generally defined as activities ordinarily resulting in no or negligible
Extraction                   disturbance to the public lands or resources—is allowed without any notice. 21
                             For operations that are greater than casual use but that will disturb 5 acres or
                             less of land, operators are required to file a notice with the local BLM field
                             office 15 days before commencing operations. Under the regulations, BLM
                             has 15 days to review the notice for completeness. To be complete, a notice
                             must contain specified operator information, a sufficient description and
                             schedule of the activity, a reclamation plan, and a reclamation cost estimate,
                             among other information. Once a financial assurance is in place, the



                             20
                               Colorado, New Mexico, Texas, Utah, and Wyoming require financial assurances for the
                             full cost of reclamation, while Arizona does not require financial assurances for the full
                             cost of reclamation.
                             21
                              BLM’s regulations for hardrock mining are in 43 C.F.R. subpt. 3809.




                             Page 13                                                        GAO-12-544 Uranium Mining
operator may begin operations once it hears from BLM that the notice is
complete, or if it receives no word from BLM after 15 days. According to BLM
guidance, the agency does not approve a notice and therefore is not
required to perform an environmental review under NEPA for a notice.

Operations that constitute more than notice-level surface disturbance must
submit a plan of operations to the local BLM field office for review and
approval, according to BLM regulations. A plan of operations must include,
among other information, specific operator information, a description and
schedule of operations, a reclamation plan, a monitoring plan, and a
reclamation cost estimate. BLM will review the plan within 30 days and then
inform the operator that the plan is complete, that more information is
required, or that additional steps must be completed. Upon completion of
BLM’s review of the plan, including analysis under NEPA and public
comment, BLM will notify the operator that it approves the plan, approves
the plan subject to additional changes or conditions, or that it disapproves
or withholds approval of the plan. Since 2001, BLM has been working on a
draft handbook to guide its state and local field offices when reviewing
notices and plans of operations. In the interim, BLM has issued a series of
Instruction Memorandums to its field staff as guidance.

Like BLM, the Forest Service requires operators to provide notification of
uranium operations, but the Forest Service differs in the activities it will
allow under a notice of intent and plan of operations. Under Forest
Service regulations, no notice is required for certain activity, such as
collection of mineral specimens using hand tools, but a notice of intent is
required for operations that might cause significant disturbance of surface
resources, and a plan of operations is required for operations that will
likely cause such a disturbance, such as use of mechanized equipment
like a backhoe. 22 These standards apply regardless of the acreage
involved. Forest Service officials told us that district forest rangers take
the lead in reviewing and approving notice- and plan-level operations on
Forest Service lands. The Forest Service does not perform environmental
analysis under NEPA for projects that are not likely to cause significant
disturbance, such as under a notice of intent. A NEPA environmental
analysis is initiated only for plan-level operations, because they are more
likely to cause significant disturbance.



22
  Forest Service regulations governing the surface use of National Forest System land in
connection with hardrock mining are in 36 C.F.R. Part 228, subpt. A.




Page 14                                                       GAO-12-544 Uranium Mining
                                          DOE’s notification requirements for its lease tracts differ from BLM’s and
                                          the Forest Service’s. DOE officials told us that the majority of its
                                          requirements for uranium operations are contained in its bid solicitation
                                          and in the terms of the lease, which incorporate relevant sections of DOE
                                          regulations. DOE notification requirements for exploration and extraction
                                          on its lease tracts are not contained in federal regulations. Instead, our
                                          review of two DOE lease documents showed that they contained a
                                          section specifying that the operator submit an exploration plan before
                                          beginning any surface disturbance to explore, test, or prospect for
                                          minerals. Furthermore, the leases specify that before developing a mine,
                                          a lessee must submit a separate mining plan to DOE for approval. DOE
                                          officials told us that because they oversee operations through a lease,
                                          they consider their role to be more like that of a landlord than a regulator.
                                          Under a DOE-BLM memorandum of understanding executed in April
                                          2010, DOE has sole authority over the selection of lessees and the
                                          negotiation, issuance, management, and termination of leases. However,
                                          BLM has jurisdictional authority over all other surface and subsurface
                                          uses of the lease tracts and will review and provide comments on lessee
                                          plans as they relate to compliance with BLM regulations. According to
                                          DOE, it assesses specific tracts through the use of an environmental
                                          checklist; however, a more detailed environmental assessment may also
                                          take place. DOE reviews mining plans for consistency with its 2007
                                          programmatic environmental assessment and existing environmental
                                          regulations. 23 Table 1 describes some of the differences in notification
                                          requirements among BLM, the Forest Service, and DOE.

Table 1: Summary of Notification Requirements for Uranium Operations across Three Agencies

Agency           Filing requirement for a notice-level operation                         Filing requirement for a plan of operations
BLM              Exploration-related surface disturbance of 5 acres or                   Exploration that disturbs more than 5 acres or any
                 less                                                                    extraction-related operations
Forest Service   Operations that might cause significant disturbance of                  Operations that are likely to cause significant
                 surface resources                                                       disturbance of surface resources
DOE              Any exploration activity in keeping with terms of lease                 Any extraction activity in keeping with terms of lease
                                          Source: GAO analysis of information from BLM, the Forest Service, and DOE.




                                          23
                                            DOE’s previous environmental assessment was conducted on the uranium leasing
                                          program in 1995.




                                          Page 15                                                                      GAO-12-544 Uranium Mining
BLM, the Forest Service,               BLM, the Forest Service, and DOE require operators to have financial
and DOE Differ in Their                assurances in place to cover the full estimated cost of reclaiming areas
Oversight of Financial                 disturbed by operations; however, the agencies differ in who is
                                       responsible for initial calculation of these assurances, how frequently they
Assurances                             conduct their review, how the review is documented, and how soon
                                       reclamation must begin after operations cease. (See table 2 for a
                                       summary of financial assurance requirements for the three agencies.)
                                       The full estimated cost to reclaim a site is typically defined as the sum
                                       sufficient for a third-party contractor to perform all necessary work,
                                       including measures to save topsoil for later reuse, control erosion,
                                       recontour the area disturbed, and revegetate or reseed the disturbed
                                       land. The estimate may also include agency administrative costs.

Table 2: Summary of Financial Assurance Requirements for Uranium Operations across Three Agencies

                                 Party responsible                                                                  When reclamation must
                  Coverage       for initial       Frequency of                          Documentation              begin following end of
Agency            required       calculation       review                                of review                  operations
BLM               Full cost of   Operator                  24 months for a               Documented in              Promptly for notices; earliest
                  reclamation                              notice; 36 months             LR2000 and                 feasible time for plans of
                                                           for plan of                   summarized annually        operations
                                                           operations                    in Bond Review
                                                                                         Report
Forest Service    Full cost of   Forest Service            Annually                      Recorded in case file,     Within 1 year, or longer with
                  reclamation                                                            but no agencywide          Forest Service approval
                                                                                         summary of review
DOE               Full cost of   DOE                       Periodically, or  Recorded in case file,                 Promptly and must be
                  reclamation                              whenever lessee   but no agencywide                      completed within 180 days or
                                                           proposes a change summary of review                      date agreed to by DOE and
                                                           in operations                                            lessee
                                       Source: GAO analysis of information from BLM, the Forest Service, and DOE.



                                       BLM regulations require operators to reclaim land disturbed by uranium
                                       operations. To ensure that this work is performed, since 2001, BLM has
                                       required the operator to provide a financial assurance. Operators must
                                       develop an estimate of the amount of financial assurance needed, which
                                       BLM reviews and adjusts as necessary. BLM does not have a minimum
                                       sum for a financial assurance. BLM uses its Bond Review Report to
                                       determine if the estimated costs of reclamation are adequate for ongoing
                                       operations, to take action to increase or decrease the financial assurance
                                       accordingly, and to certify that financial assurances are adequate to cover
                                       estimated reclamation costs. The Bond Review Report aggregates data
                                       from BLM’s LR2000 database and includes data on the amount of
                                       financial assurances and when they were last reviewed. A BLM
                                       instruction memorandum directs local field offices to review financial


                                       Page 16                                                                         GAO-12-544 Uranium Mining
assurances for adequacy every 2 years for notices and every 3 years for
plans of operations. 24 In addition, by December 1 of each year, state BLM
offices must review the Bond Review Report to determine if reclamation
cost estimates for notices and plans of operations within their states are
adequate and were reviewed within appropriate time frames. If the Bond
Review Report indicates that a financial assurance is not adequate to
cover estimated reclamation costs at a site or has not been reviewed
within the appropriate time frame, then the state director must develop a
corrective action plan to address the deficiencies. Following the end of
operations at a site or when a notice expires, BLM regulations require
reclamation of a notice to begin promptly, and reclamation of a plan of
operations to begin at the earliest feasible time. Because BLM does not
have an official definition for these time frames, BLM officials told us that
local field offices have flexibility in determining whether operators are in
compliance. Before a financial assurance is released back to the
operator, the state agency responsible for mine permitting and the BLM
local field office will inspect the site to verify that reclamation is complete.
In some cases, reclamation can take several years, and a financial
assurance may be reduced periodically before being released fully.
Because many operations may involve a mix of federal, state, county, and
private lands, BLM regulations provide the option of joint bonding with the
state. 25 In these cases, the state holds the financial assurance, but it is
also redeemable by BLM.

The Forest Service also directs operators to provide a financial assurance
for the full cost of reclamation. 26 However, in contrast to BLM, the Forest
Service relies on its technical staff at the district, forest, or regional level,
not the operator, to calculate the estimated reclamation costs. It uses
formal agency guidance issued in 2004 to calculate the estimated
reclamation costs and proposes the amount of the financial assurance to
cover those costs to the operator. The Forest Service does not have a



24
  BLM may review the reclamation cost estimate more frequently if there is cause to
believe the reclamation cost estimate is insufficient. A financial assurance for an operation
may need to be reviewed annually when it covers an operation that will grow over time
according to the timeline submitted in the plan of operations, a practice known as phased
bonding.
25
  BLM does not have an agreement covering joint bonding with Arizona.
26
  Forest Service guidance directs its staff to obtain financial assurances to cover the
estimated reclamation costs for mining operations on National Forest System lands.




Page 17                                                         GAO-12-544 Uranium Mining
required minimum for financial assurances on its lands. According to
Forest Service guidance, an operator’s financial assurances should be
reviewed annually for adequacy, but a Forest Service official told us that
agency staff do not prepare an annual report documenting these reviews.
Forest Service regulations require that site reclamation begin upon
exhaustion of the mineral deposit, at the earliest practicable time during
operations, or within 1 year of the conclusion of operations, unless a
longer time is allowed by the Forest Service. Forest Service and state
officials will inspect a site to ensure that reclamation is complete before
releasing the financial assurance. A financial assurance may also be
released in increments as reclamation progresses. In most cases, the
Forest Service holds the financial assurances for mining operations on its
land, although a Forest Service official told us that the financial assurance
could be jointly held with the state for larger operations.

DOE also directs its personnel to ensure that the financial assurance
provided by an operator is adequate to cover the estimated cost of
reclamation. Sample lease agreements that we reviewed set a minimum
financial assurance amount and state that DOE personnel will take into
account estimated reclamation costs in setting the financial assurance.
Similar to the Forest Service, DOE generally calculates this as the
estimated amount for a third-party contractor to perform the reclamation
work. The current minimum sum for DOE financial assurances is $5,000,
according to DOE officials. Generally, DOE will perform a financial
assurance assessment whenever the lessee puts forth new plans for a
mining operation. The financial assurance review is filed in the case file
as part of the approval package. Upon expiration of the lease, or early
relinquishment or cancellation of the lease, current DOE lease terms
require lessees to return the site to a condition satisfactory to DOE within
180 days, or a term otherwise agreed to by DOE and the lessee. DOE
guidance states that DOE will release the financial assurance once the
lessee’s reclamation effort is deemed acceptable. Financial assurances
are usually held by DOE, except in cases where disturbance to a DOE
lease tract is minimal as part of a larger project undertaken on private or
state lands.




Page 18                                              GAO-12-544 Uranium Mining
Unlike BLM and the Forest   Under existing statutory authorities, BLM and the Forest Service cannot
Service, DOE Earns          collect rents for the use of federal land or charge royalties on hardrock
Royalties and Rents from    minerals, including uranium, extracted from that land. 27 BLM does charge
                            claimants an initial $34 location fee, a $15 processing fee, and an annual
Uranium Operations
                            $140 maintenance fee per claim, and also collects these fees for claims
                            on Forest Service land. In contrast, under the Atomic Energy Act, DOE
                            may collect royalties and rents for uranium extraction operations on its
                            lease tracts. DOE establishes the royalties and terms of payment with the
                            lessee in the lease; typically potential lessees will offer to pay higher
                            production royalties for lease tracts known to contain higher grades of
                            uranium. 28

                            DOE has collected approximately $64 million in royalties since the
                            beginning of the lease program in the 1940s. Specifically:

                            •    From the first round of leasing, 1949 through 1962, the program
                                 generated $5.9 million in royalties to the federal government from 1.2
                                 million pounds of uranium and 6.8 million pounds of vanadium.

                            •    From the second round of leasing, 1974 through 1994, the program
                                 generated $53 million in royalties for the federal government from
                                 production of approximately 6.5 million pounds of uranium and 33.4
                                 million pounds of vanadium.

                            •    From the third round of production, 2003 through 2005, the program
                                 generated $4.77 million in royalties for the federal government from
                                 production of approximately 390,000 pounds of uranium and 1.4
                                 million pounds of vanadium.




                            27
                              Unlike BLM and Forest Service, many states provide for the collection of royalty
                            payments. For example, Arizona, Colorado, New Mexico, Utah, and Wyoming charge a
                            royalty for uranium extraction. In the current Congress, the proposed Uranium Resources
                            Stewardship Act (HR1452, 112th Cong. (2011)) would require a royalty charge of at least
                            12.5 percent on uranium extracted from federal land and rental charges for the land being
                            mined. The money collected would then be used to clean up abandoned uranium mines
                            and mill sites.
                            28
                              The royalty paid differs by lease tract. Leases for tracts held before 2008 require
                            payment of a bid royalty and a base royalty. The bid royalty is a competitive bid made by
                            operators to acquire the lease. The base royalty is set by DOE based on ore production
                            on the lease. Leases rebid on in 2008 require payment of a bid royalty only. The bid
                            royalty is considered the “production royalty” for these lease tracts.




                            Page 19                                                        GAO-12-544 Uranium Mining
                            In addition, current DOE leases require lessees to pay an annual rent.
                            According to the program’s annual status report, five companies
                            collectively paid an annual rent of $387,040 in fiscal year 2010. Each
                            lessee pays an amount according to the size and value of its lease tract.
                            In lieu of paying this rent, DOE also allows lessees to perform reclamation
                            work on previously abandoned mine sites. In fiscal year 2010, three
                            companies negotiated with DOE to perform reclamation work in lieu of
                            paying rent valued at a total of $101,860.


                            As of January 2012, a total of 221 uranium operations were on federally
Over 200 Uranium            managed land, but only 7 of these operations were actively extracting
Operations Are on           uranium and these were all on BLM land. 29 An additional 29 uranium
Federal Land, but           operations were awaiting federal approval. Most of the operations—202—
                            were on BLM land; another 3 were on Forest Service land, and the
Few Are Actively            remaining 16 were on DOE lease tracts.
Extracting Uranium

Uranium Operations on       Of the 221 uranium operations on federal land, 202, or 91 percent, were
BLM Land Are Generally      on land managed by BLM, according to our analysis of agency data. Of
Engaged in Exploration or   these 202 operations, BLM’s LR2000 database identified 144 as
                            authorized, which means BLM has acknowledged an operator’s notice or
Reclamation                 has approved its plan of operations and has approved a financial
                            assurance. These 144 operations included 111 notices and 33 plans of
                            operations, covering about 13,400 acres, and were primarily located in
                            Arizona, Colorado, Utah, and Wyoming. The remaining 58 operations on
                            BLM land were expired notices—that is, operations have ceased except
                            for reclamation and the financial assurance is held until BLM determines
                            that reclamation is complete. According to our analysis of LR2000 data,
                            we also identified 28 uranium operations (11 notices and 17 plans of
                            operations) that were awaiting BLM’s authorization. Collectively, these




                            29
                               This count does not necessarily represent individual mine sites because multiple plans
                            of operations may cover a single mine, among other reasons. In addition, the data in this
                            section reflect site status as of January 2012, and the number of uranium operations can
                            fluctuate over time.




                            Page 20                                                        GAO-12-544 Uranium Mining
pending operations could involve disturbing up to 24,300 acres of BLM-
managed land. 30

We surveyed BLM staff in 25 field offices across eight states for additional
information on the status of the uranium operations on BLM-managed
land. As shown in table 3, we asked them to provide information on how
many operations were in each of eight possible status categories. (For a
more detailed description of the status categories that we used in our
survey, please see app. I.) Specifically, on the basis of our survey
responses, we determined the following: 31

•    Of the 144 authorized operations, 7 operations are actively extracting
     uranium—3 mines in Utah, 3 in Wyoming, and 1 in Arizona. In
     addition, 60 operations are engaged in exploration, 51 operations are
     engaged in reclamation, and 22 are on standby—that is, they are not
     actively exploring or extracting uranium. 32

•    Of the 58 expired operations, 40 are engaged in reclamation, and
     BLM staff did not know the status for 12 operations, in part because
     several of these operations had last been inspected in 2002. Most of
     the remaining 6 are either in standby or closed status.

•    Of the 28 operations identified in LR2000 as pending, field staff
     reported a status for 12 operations that is inconsistent with BLMs
     definition of “pending.” For example, staff reported 2 pending
     operations in exploration status, 4 pending operations in reclamation
     status, 3 pending operations in standby status, and 3 that were
     closed. Seventeen operations listed as pending in LR2000 were
     reported by field staff to be in a status that is consistent with the
     definition of pending, specifically exploration permitting or extraction
     permitting.




30
  This information on acreage reflects the total amount of the authorized area that can be
disturbed. However, actual disturbance can often be much smaller, according to BLM
officials.
31
  Staff were allowed to select multiple statuses for an operation on our survey. As a result,
the sum of responses will exceed the number of operations.
32
  On our survey, we used the terms “mine permitting” and “production.” For the purposes
of using consistent terms in this report, we are substituting the terms “extraction
permitting” and “extraction.”




Page 21                                                         GAO-12-544 Uranium Mining
Table 3: Results of GAO’s Survey of BLM Field Offices on Status of Uranium Operations

                        Exploration              Extraction                                                                                Don’t
Type of operation        permitting Exploration permittinga Extractiona Standby Reclamation Closed                             Other       know
Authorized operations
Authorized notices                1             55                   0                    0    7              45          5         2              0
Authorized plans of               1               5                  2                    7   15               6          0         1              0
operations
Subtotal-authorized               2             60                   2                    7   22              51          5         3              0
Expired operations
Expired notices                   0               0                  0                    0    1              40          2         3         12
Pending operations
Pending notices                   2               1                  0                    0    1               4          2         2              0
Pending plans of                  2               1                13                     0    2               0          1         1              0
operations
Subtotal-pending                  4              2b                13                     0   3b              4b          3b        3              0
Total                             6             62                 15                     7   26              95         10         9         12
                                        Source: GAO analysis of BLM field office responses.

                                        Notes: Because an operation could have more than one status, field offices were allowed to select
                                        multiple status categories on our survey. As a result, the sum of the responses will exceed the total
                                        number of operations. Of the 230 operations, 9 were described by field staff using multiple statuses.
                                        a
                                         On our survey, we used the terms “mine permitting” and “production.” For the purposes of using
                                        consistent terms in this report, we are substituting the terms “extraction permitting” and “extraction.”
                                        b
                                         The status reported for these pending operations is inconsistent with BLM’s definition of a pending
                                        operation.


                                        In addition, our review of documents for 110 of these operations
                                        confirmed that some of the reported status levels in LR2000 were
                                        inaccurate. For example, we found one notice that was denied in March
                                        2007 that was still listed as pending in LR2000 as of January 2012. In
                                        another instance, a notice was authorized in October 2011 but was still
                                        listed in LR2000 as pending. There were other instances where the
                                        documentation that staff provided to us, such as inspection reports, had
                                        not been entered into LR2000. BLM guidance requires that field staff
                                        update LR2000 within 5 working days of a change in the status of the
                                        operation. Such delays in entering information affect the ability of LR2000
                                        to serve as an effective management tool to track operations. According
                                        to the standards for internal control in the federal government, agencies




                                        Page 22                                                                    GAO-12-544 Uranium Mining
                             are to promptly record transactions and events to maintain their relevance
                             to management in controlling operations and making decisions. 33

                             Of the 7 operations actively extracting uranium on BLM-managed land, 4
                             are underground mines and 3 are ISR operations. See table 4 for more
                             information on these operations. BLM officials told us the agency did not
                             have data on how much uranium these operations were extracting
                             because it is not authorized to collect this information on uranium or other
                             hardrock minerals.

                             Table 4: Summary of Operations That Are Extracting Uranium on BLM Land

                                 Operation name                Operator                      State                         Type of mine
                                 Arizona 1                     Denison                       Arizona                       Underground
                                 Daneros                       Utah Energy                   Utah                          Underground
                                           a
                                 Pandora                       Denison                       Utah                          Underground
                                       a
                                 La Sal                        Denison                       Utah                          Underground
                                 Highlandb                     Cameco                        Wyoming                       ISR
                                               b
                                 Smith Ranch                   Cameco                        Wyoming                       ISR
                                 Willow Creek                  Uranium One                   Wyoming                       ISR
                             Source: GAO analysis of BLM data, survey responses, and relevant BLM and company documents.


                             a
                              Both the La Sal and Pandora mines are part of the La Sal Mine complex. We list them separately
                             because they each have separate plans of operations with BLM. The plan of operations for the La Sal
                             mine also includes the Beaver Shaft and Snowball mines. The Pandora mine includes some surface
                             disturbance on Forest Service land resulting from the installation of a few vent holes for the mine;
                             according to Forest Service officials, BLM is the primary federal agency involved in regulating this
                             mine.
                             b
                              The Smith Ranch and Highland operations are adjacent to each other and share a uranium
                             processing facility. We list them separately because they have separate plans of operations with
                             BLM.




Three Uranium Operations     We identified three uranium operations on land managed by the Forest
Are on Forest Service Land   Service in the Manti La Sal National Forest in Utah. Two of these
                             operations involve uranium exploration, while the third involves the
                             installation of vent holes for the Pandora underground mine, whose
                             entrance is located on BLM-managed land. Collectively, these operations
                             have been authorized to disturb up to 7 acres of land. However, the


                             33
                               GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1
                             (Washington, D.C.: November 1999).




                             Page 23                                                                              GAO-12-544 Uranium Mining
                             Forest Service is currently reviewing a plan to authorize the Canyon Mine
                             in the Kaibab National Forest in Arizona. This mine’s plan of operations
                             was initially approved in the mid-1980s and the Forest Service is
                             determining whether additional, more current environmental analysis
                             must be undertaken to authorize this operation.


All 9 Mines on DOE’s Lease   As part of is uranium leasing program, DOE oversees 31 lease tracts,
Tracts Are on Standby        which are in a variety of statuses.

                             •    Eight tracts have a total of 9 uranium mines on them, all of which are
                                  on standby—that is, they are not actively extracting uranium. 34 These
                                  lease tracts cover about 6,900 acres, but the operations have
                                  disturbed only about 260 acres of land.

                             •    Seven lease tracts have approved exploration plans, but no
                                  exploration work is ongoing.

                             •    DOE has not approved any exploration or extraction plans for 14
                                  lease tracts.

                             •    The remaining 2 lease tracts have not been leased out.

                             According to DOE officials, no extraction activity has taken place on its
                             lease tracts since 2006 for two reasons. 35 First, DOE officials reported that
                             there has been limited incentive to explore or extract uranium on their lease
                             tracts because there are no uranium processing mills in Colorado near the
                             lease tracts. 36 Second, in October 2011, a federal district court ordered that
                             no additional surface disturbance could take place on any DOE lease tracts
                             until DOE completes an appropriate environmental analysis pursuant to




                             34
                               One of these lease tracts has 2 mines on it. Of the 9 total mines, 1 is an open pit mine
                             and the other 8 are underground mines.
                             35
                               DOE officials also reported that no exploration activity has taken place on the lease
                             tracts since 2010.
                             36
                               The capacity to process uranium in mills is currently limited, with only one operating
                             uranium mill in the United States, in Blanding, Utah. In Colorado, a uranium mill known as
                             the Piñon Ridge mill is currently in the process of obtaining the necessary permits before it
                             can begin construction.




                             Page 24                                                         GAO-12-544 Uranium Mining
                         NEPA. 37 DOE officials told us that a programmatic environmental impact
                         statement is due to be released for public comment in late 2012.


                         As of January 2012, BLM, the Forest Service, and DOE reported $249.1
Agency Data Indicate     million in financial assurances, and these assurances appear to be
That Financial           generally adequate to cover the estimated reclamation costs for uranium
                         operations on federal land, according to our analysis of agency data. 38
Assurances               Agency data indicate that nearly all of these assurances ($247.6 million of
Adequately Cover         the $249.1 million) are for operations that are at least partially on BLM-
Nearly All Operations,   managed land. 39 Although almost all of these financial assurances were
                         adequate to cover the estimated cost of reclamation, we identified some
but BLM and NRC Do       issues in how BLM oversees these assurances. We also found the value
Not Coordinate in        of financial assurances for two ISR operations had increased significantly,
                         but that BLM and NRC did not coordinate their efforts to establish and
Establishing Some        review financial assurances for these operations. The remaining $1.5
Assurances               million in financial assurances is for authorized operations on land
                         managed by the Forest Service and for DOE lease tracts. According to
                         our analysis of agency data, these financial assurances are adequate to
                         cover the current estimated cost of reclamation for the operations that the
                         two agencies oversee.




                         37
                           In February 2012, the court modified the injunction to allow certain surface-disturbing
                         activities, including those that are absolutely necessary to conduct the environmental
                         analysis.
                         38
                           The data in this section reflect the financial assurances in place as of January 2012, and
                         the value of financial assurances for uranium operations can fluctuate over time.
                         39
                           For operations that involve a combination of BLM and state or private land, BLM’s Bond
                         Review Report generally reports the financial assurance for the entire operation, not just
                         the portion on BLM-managed land, and that is what we are reporting. However, BLM does
                         not report information on financial assurances for the portions of mining operations in
                         Arizona that are not on BLM-managed land because the agency does not have a joint
                         bonding agreement with Arizona.




                         Page 25                                                         GAO-12-544 Uranium Mining
BLM Had Financial            As of January 2012, BLM had financial assurances of about $245.5
Assurances to Cover          million for 144 authorized uranium operations, according to our review of
Reclamation Costs for        BLM’s Bond Review Report, and the financial assurances were adequate
                             for all but 2 of the operations. Specifically, we found 1 operation where
Nearly All Operations, but   BLM field staff reported that the assurance in place was likely inadequate
Some Issues Exist            to reclaim an acid pit lake that had formed at an older, inactive open pit
Regarding Agency             uranium mine in Wyoming. The operation has in place a financial
Oversight                    assurance in the amount of $126,000, but the operator is in the process
                             of developing a new reclamation estimate for BLM to review. In addition,
                             we found 1 operation for which the financial assurance for a plan of
                             operations in Utah was $16,000 less than the estimated reclamation
                             costs. 40 In general, we found that most of the financial assurances for
                             operations on BLM land are for less than $100,000.

                             During our review of BLM’s data, we identified two issues related to
                             BLM’s Bond Review Report for overseeing financial assurance of uranium
                             operations. First, we found inaccuracies in the information included in the
                             report. Specifically, the Bond Review Report indicated that reviews of the
                             financial assurances for 5 notice-level operations had not taken place in
                             over 36 months, which is a year past the frequency that BLM guidance
                             requires. According to BLM officials, these 5 operations had been
                             reviewed within the correct time frames, but staff had entered an incorrect
                             action code into LR2000. We also found other instances during the
                             course of our review where BLM staff had entered incorrect action codes
                             into this system. LR2000 accepts hundreds of action codes, yet the
                             agency does not have comprehensive guidance on all the action codes
                             that can be used in LR2000.

                             Second, the Bond Review Report does not include financial assurances
                             that are in place for expired operations. According to our review of agency
                             data, there are 58 expired uranium operations on BLM land. One reason
                             BLM officials offered for why the Bond Review Report does not include
                             information on expired operations was because the financial assurances
                             for these operations are smaller. However, the information we reviewed
                             shows that 43 expired uranium operations had about $2 million in
                             financial assurances and that some of these expired operations had
                             assurances that were well above $100,000. In addition, we found the



                             40
                               According to BLM officials, the agency has contacted the new owner of this operation
                             about the need to increase the financial assurance amount.




                             Page 26                                                      GAO-12-544 Uranium Mining
                           remaining 15 expired operations did not have any financial assurances in
                           place. According to BLM officials, because these 15 operations were
                           established prior to BLM’s 2001 regulations that required financial
                           assurances for all mining operations, it is reasonable that these
                           operations do not have financial assurances. Nonetheless, these 15
                           operations do need to be reclaimed and, according to BLM staff, these
                           operations may not be receiving the required oversight, which is
                           evidenced by the fact that several of these operations were last inspected
                           about a decade ago. The fact that these 15 operations have not been
                           reclaimed or inspected in almost a decade suggests that oversight of
                           expired operations could be improved.


BLM and NRC Do Not         We found that two ISR operations—the Smith Ranch and Highland
Coordinate when            operations in Wyoming—account for $213 million in financial assurances,
Establishing and           or 86 percent of the total financial assurances held for uranium operations
                           on land managed by BLM. According to BLM officials, a portion of the
Reviewing Assurances for   financial assurances for these two operations also covers activities on
ISR Operations             land that is not managed by BLM, such as state or private land. 41 The
                           required financial assurances for ISR operations on the Smith Ranch and
                           Highland operations have increased from June 2011 through December
                           2011—from about $80 million to about $120 million for the Smith Ranch,
                           and from about $80 million to about $93 million for Highland, although the
                           size and disturbance of the operations at these two sites has not
                           significantly changed. According to BLM, NRC, and Wyoming state
                           officials, this increase is due to a variety of factors, including new
                           estimates of the additional work necessary to restore the groundwater at
                           these sites. For example, the estimated number of cycles during which
                           this groundwater is extracted and treated before being reinjected—known
                           as a pore volume—has been increased from six to nine. The cost to
                           restore groundwater at these sites has also increased because the
                           operator had previously removed equipment necessary to restore the
                           groundwater so the equipment could be used in other operating wellfields,
                           and this equipment must now be either returned to these sites or replaced
                           with other groundwater restoration equipment, according to NRC officials.
                           In March 2008, the state of Wyoming issued a notice of violation to the
                           operator for Smith Ranch and Highland that stated that the operator was



                           41
                             According to BLM officials, the financial assurances held for uranium operations are not
                           broken out by the entity that manages the surface.




                           Page 27                                                        GAO-12-544 Uranium Mining
not adhering to the schedule for restoring groundwater and that its
estimate of the number of pore volumes and resources needed to restore
the groundwater were too low. As a result, the state concluded that the
total financial assurances in place at the time for the Smith Ranch and
Highland operations—$38.4 million—should be increased immediately to
$80 million to protect the public and that a more realistic estimate of the
cost to reclaim the sites would be close to a total of $150 million. 42
According to Wyoming state officials we spoke with, this notice of
violation was part of the process of requiring greater financial assurances
for the Smith Ranch and Highland operations that has resulted in these
operations now having a combined $212.7 million in financial assurances.

In examining the efforts to increase financial assurances for these two
sites, we found that BLM and NRC did not coordinate their efforts with
each other. According to Wyoming state officials, BLM field office staff
generally provide comments and concurrence on the proposed financial
assurances that operators submit annually. In contrast, NRC generally
conducts its own independent review of the financial assurances it
believes should be in place. In 2009, NRC and BLM enacted a
memorandum of understanding intended to improve interagency
cooperation in environmental assessments; facilitate the sharing of
special expertise and information; and coordinate the preparation of
studies, reports, and documents. However, this memorandum does not
cover interagency coordination of the review of financial assurances.

Even though the financial assurances for the Smith Ranch and the
Highland operations have increased significantly, the lack of federal
coordination when establishing these financial assurances raises
concerns about the adequacy of these financial assurances and the
financial assurances associated with any future ISR operations that may
be authorized. (For more information on active and pending ISR
operations, see app. II.) According to our review, it appears that both BLM
and NRC have expertise in different areas of the work needed to reclaim
an ISR operation, and better coordination among these agencies would
help ensure that all necessary factors have been considered. Specifically,
BLM primarily has expertise in estimating the cost of reclaiming surface
disturbances at a mining site, and NRC primarily has expertise in



42
 Wyoming Department of Environmental Quality, “In Situ Uranium Permits 603 and 633,
Notice of Violation, Docket No. 4231-08” (Cheyenne, Wyoming, 2008).




Page 28                                                   GAO-12-544 Uranium Mining
                          estimating the cost of restoring groundwater contaminated by radioactive
                          material. NRC officials reported that some of this expertise was
                          developed through overseeing reclamation activities at uranium
                          processing mills where groundwater must be restored, buildings
                          demolished, and monitoring wells plugged. However, NRC officials
                          acknowledged that the scale of disturbance at an ISR site is much greater
                          than at a mill, because of the thousands of wells that must be plugged
                          and the surrounding surface reclaimed. In addition, restoring the
                          underground water at these mining sites is a complex process because it
                          must be restored to the background concentration, a maximum
                          concentration that incorporates standards set by EPA, or alternate
                          concentration limits as approved by NRC. 43 According to Wyoming state
                          officials we spoke with, enhanced coordination between the federal
                          agencies and also with the state could help to leverage each agency’s
                          particular expertise in reviewing financial assurances for ISR sites. These
                          state officials told us that this coordination is even more important
                          because ISR operators have had little experience with restoring
                          groundwater at ISR wellfields to date in Wyoming. Specifically, at the
                          Smith Ranch and Highland ISR sites, the state and NRC have approved
                          groundwater restoration efforts at only 1 of the 19 wellfields according to
                          Wyoming state and NRC officials.


The Forest Service and    The Forest Service and DOE have financial assurances for uranium
DOE Have Adequate         operations that are adequate to cover the current estimated cost of
Financial Assurances to   reclamation for the sites they oversee, according to our analysis of
                          agency data. Specifically, the Forest Service reported having about
Cover Reclamation Costs   $42,000 in financial assurances for the three operations on its land, one
for Uranium Activity      of which consists of installing vent holes for a mine on adjacent BLM land,
                          and the other two were for operations currently conducting exploration.
                          The Forest Service handbook requires that all active financial assurances
                          be reviewed annually, and our review found that all had been reviewed
                          within appropriate time frames.

                          DOE reported about $1.5 million in financial assurances for its 29 tracts
                          that have been leased out, with about $1.2 million of this total for a single
                          lease tract with an inactive open pit uranium mine. Our review of DOE


                          43
                            Alternate concentration limits can be set if groundwater cannot be restored to
                          background levels, and these limits are based on site-specific conditions at a location. See
                          10 C.F.R. pt. 40 app. A (2012).




                          Page 29                                                        GAO-12-544 Uranium Mining
                       data indicates that these assurances were adequate as of the last time
                       they had been reviewed—from 1996 through 2005 for 9 lease tracts and
                       in 2008 or later for the remaining 22 tracts. 44 DOE officials told us they
                       had not reviewed some of these financial assurances more recently
                       because there has been little new activity on the lease tracts in recent
                       years. DOE officials told us that they generally review financial
                       assurances when a lessee makes a change to an exploration or mining
                       plan on a lease tract.


                       Federal agencies do not have reliable data on the number and location of
Federal Agencies Do    abandoned uranium mine sites on federal lands and the potential cleanup
Not Have Reliable      costs associated with these sites, according to our review of agencies’
                       databases and discussions with agency staff. We found that agency
Data on the Number     databases generally lack complete data and a common definition of an
and Location of        abandoned mine site, and contain information that has not been verified
                       through field inspections. In addition, federal agencies do not have
Abandoned Uranium      estimates of the potential total cleanup cost for abandoned uranium mine
Mines or Their         sites on the land they manage. According to agency officials, the cost to
Associated Cleanup     clean up these sites varies according to site-specific conditions, including
                       the amount and type of work required at each site, and the total number
Costs                  of sites needing cleanup.


Federal Data on        There are likely thousands of abandoned uranium mine sites on federal
Abandoned Uranium      land where either exploration or extraction may have taken place, but the
Mines Are Unreliable   available federal data on these sites are generally unreliable. In particular,
                       we found the following limitations with these data. 45

                       Agencies’ databases are incomplete. Three agency databases only
                       partially track the commodity extracted, and one of them omitted sites
                       with incorrect geographic coordinates. For example, according to BLM’s
                       database, there are an estimated 1,189 abandoned uranium mine sites


                       44
                         According to DOE, the financial assurances for the 2 lease tracts that were not leased
                       out were last reviewed in June 2008.
                       45
                         DOE also maintains information on abandoned uranium mine sites in a centralized
                       database that also tracks other information related to its uranium leasing program.
                       However, we did not include this database in this analysis, since, according to DOE
                       officials, DOE cleaned up all of its 190 abandoned uranium mine sites from 1996 to 2011
                       on its lease tracts.




                       Page 30                                                       GAO-12-544 Uranium Mining
on BLM-managed land. However, these data are based primarily on
information from three states (Colorado, Utah, and Wyoming) because
the BLM state offices in these states require their local field offices to
enter the commodity that had been previously extracted from these
abandoned mines. 46 Similarly, in the National Park Service’s abandoned
mine database, the commodity field is optional for agency staff to enter. 47
On the other hand, EPA’s database, which estimates that there are 8,124
abandoned uranium mine sites on federal land, does not include some
sites because they do not have specific geographic coordinates,
according to agency officials. In addition, some of the databases have not
been updated in years and do not track the extent to which extraction
took place at each site, which would help indicate the type of cleanup
work that might be required. For example, the Forest Service database
lists an estimated 1,097 abandoned uranium mine sites; however, the
status of many of these sites has not been updated since they were first
entered in the database in the 1980s. In addition, the Forest Service and
EPA databases do not track which abandoned mine sites have already
been cleaned up. As a result, it is not possible to determine from the
agency data how many sites remain to be cleaned up.

Agencies do not have a consistent definition of an abandoned mine site.
We found agencies do not share a consistent definition of an abandoned
mine site, and even within an agency the definition may not be consistently
applied by various field offices or staff. These inconsistencies pose a
problem when trying to combine multiple databases or to compare data
across multiple agencies. For example, because of a lack of a consistent
site definition, EPA officials told us that the agency faced a challenge in
trying to combine data from multiple sources in order to provide more




46
  According to a BLM official, the board in charge of managing the BLM database on
abandoned mines has recently decided to eliminate the commodity field from the
database.
47
   New hardrock mining claims may not be located on land managed by the National Park
Service, and none of the legacy claims currently in the system are for uranium. Therefore,
it is highly unlikely that there will be any active uranium operations on National Park
Service land. The agency is, however, involved in overseeing efforts to clean up
abandoned uranium mines on its land.




Page 31                                                       GAO-12-544 Uranium Mining
complete information on abandoned uranium mine sites.48 In addition, even
within a single agency, staff may use different definitions of an abandoned
mine site when entering data into a database. For example, a BLM official
told us that field staff may enter each abandoned mine feature, such as a
waste rock pile or a mine opening, as a separate site, instead of grouping
these features into one entry. According to a 2007 EPA report on its efforts
to develop a database on abandoned uranium mine sites, the lack of a
consistent definition leads to problems with determining how many sites
exist, since even a single agency’s database may contain mines meeting a
variety of definitions.49 In March 2008, we highlighted the lack of a
consistent definition for abandoned hardrock mine sites and the way in
which this inconsistency contributes to a wide variation in estimates of the
number of abandoned mines.50 At that time, we developed a consistent
definition of an abandoned hardrock mine site, and used it to develop a
more robust estimate of abandoned mines by applying it across multiple
databases. According to EPA officials we interviewed, federal agencies
involved with abandoned mines have used a regular interagency forum,
called the Federal Mining Dialogue, to discuss the issue of a lack of a
common definition of a mine site but have not yet reached agreement on
how to address this issue.51

Agency databases contain sites that have not been verified through field
inspections. According to agency officials, field inspection is the best
way to determine an abandoned mine’s location and features, such as


48
  In 2006, EPA combined data from 19 different databases into one single database. This
database primarily includes data from state agencies and BLM’s state offices in Arizona,
Colorado, New Mexico, Utah, and Wyoming; data from the USGS; as well as some
databases with limited number of records from a few states outside these areas, such as
California, Montana, South Dakota, and Texas.
49
 EPA, Technical Report on Technologically Enhanced Naturally Occurring Radioactive
Materials from Uranium Mining, Volume 2 (Washington, D.C.: August 2007).
50
  GAO, Hardrock Mining: Information on Abandoned Mines and Value and Coverage of
Financial Assurances on BLM Land, GAO-08-574T (Washington, D.C.: Mar. 12, 2008). In
this report, we defined an abandoned hardrock mine site as all associated facilities,
structures, improvements, and disturbances at a distinct location associated with activities
to support a past operation of minerals locatable under the general mining laws.
51
  The Federal Mining Dialogue, established in 1995, is a forum for discussing and
coordinating abandoned mine-related issues among federal agencies. EPA serves as the
lead agency. Regular participating agencies include BLM, EPA, the Forest Service,
National Park Service, and USGS. Other agencies, such as the Department of Justice or
the U.S. Army Corps of Engineers, participate when issues of interest arise.




Page 32                                                         GAO-12-544 Uranium Mining
posing physical safety and environmental hazards, to discover new
abandoned mine sites, and to figure out what cleanup may be required
at an abandoned mine site. However, field inspections also require more
resources because agency staff must try to cover large areas of land,
sometimes in risky or inaccessible conditions, such as mountainous or
rocky areas. Currently, the National Park Service and BLM are in the
process of verifying the condition of abandoned mine sites on their land.
According to National Park Service officials, the agency received $3.3
million over 3 years to verify how many abandoned mine sites, including
uranium mines, it has on the land it manages, and to verify cleanup
needs at these sites, a process the agency hopes to complete by
September 30, 2012. On the basis of preliminary results from this field
inspection, National Park Service officials told us that of the 46
abandoned uranium mine sites on their land, 25 remain to be cleaned
up. Since 2009, some inventory efforts of abandoned mines on BLM
land have been under way in Arizona, New Mexico, and Wyoming, but
not all BLM offices in these states require their staff to track the
commodity that was extracted at abandoned mine sites. 52 Table 5 and
appendix III provide more specific information on the limitations of each
agency’s database on abandoned uranium mines.




52
   According to BLM officials, BLM was directed to stop any inventory efforts from 1999 to
2009 to focus on cleaning up the already identified abandoned mines because of funding
limitations.




Page 33                                                        GAO-12-544 Uranium Mining
Table 5: Limitations with Four Federal Agencies’ Databases on Abandoned Uranium Mines

                                                                               Limitations with these databases
                                                                                                                                                Some sites in
                                                                 Does not track                                                                  the database
                                                                   the extent to Does not track                                                 have not been
                                        Partially tracks              which       which sites        Used an                                        verified
                                        the commodity            extraction took  have been       inconsistent                                   through field
Agency          Database namea             extracted              place at a site cleaned up    definition of a site                              inspection
 BLM            Abandoned Mine/Site             X                          X                                                     X                    X
                Cleanup Module
The Forest      Forest Service                  X                          X                         X                           X                    X
Service         Abandoned Mineral
                Lands Database
National Park   Servicewide                     X
Service         Abandoned Mineral
                Lands Database
EPA             Technologically                                            X                         X                           X                    X
                Enhanced Naturally
                Occurring Radioactive
                Materials Uranium
                Location Database
                                         Source: GAO analysis of information from BLM, the Forest Service, the National Park Service, and EPA
                                         a
                                          The BLM, Forest Service, and National Park Service databases refer to abandoned uranium mine
                                         sites on the land they manage. The EPA database refers to sites on all federal land.


                                         BLM, EPA, and Forest Service officials told us that their agencies do not
                                         have an accurate number of abandoned mine sites and their location
                                         because no laws or regulations require the agencies to track abandoned
                                         mines and that the agencies do not have sufficient resources to collect
                                         this information. Specifically, officials from BLM and EPA explained that
                                         any tracking of sites is done voluntarily to help with their mission. In
                                         addition, BLM and Forest Service officials told us that they have not had
                                         sufficient funds to conduct field inspection verification on all their known
                                         abandoned mine sites on the lands they manage and that to do so would
                                         be costly, requiring additional financial and staff resources. At current
                                         funding levels, according to a May 2011 draft feasibility study, it will take
                                         BLM 13 years and $39 million to finish inspecting all known abandoned
                                         mine sites on its land, including the ongoing inventory work in Arizona,
                                         New Mexico, and Wyoming.53



                                         53
                                           BLM, Draft Feasibility Study for AML Inventory Validation and Physical Safety Closures
                                         (Washington, D.C.: May 2011).




                                         Page 34                                                                                     GAO-12-544 Uranium Mining
Cleanup Costs for            In addition to not knowing how many abandoned uranium mines are on
Abandoned Uranium            federal land, BLM, the Forest Service, EPA, and the National Park
Mines Vary Greatly,          Service do not have information on the total cost of cleaning up
                             abandoned uranium mines. Officials noted that cleanup costs are
Depending on Site-Specific   determined not only by the total number of mines that need cleanup, but
Conditions                   also by site-specific conditions, including the amount and type of work
                             required at each site. Agency officials explained that each abandoned
                             mine site has distinctive characteristics and requires a unique cleanup
                             plan based on, among other things, its size, accessibility, the need for
                             heavy equipment, and the level of contamination.

                             Agency officials we spoke with generally agreed that cleanup costs at
                             individual sites could range from several thousand dollars to hundreds of
                             millions of dollars. These officials also agreed that most of the work is
                             likely to fall within one of the following three cleanup categories:
                             addressing safety hazards, conducting surface reclamation, and
                             conducting environmental remediation. 54 However, officials cautioned that
                             sometimes cleanup at a site requires work across two or all of these
                             categories. Figure 3 illustrates some of the activities that can take place in
                             these cleanup categories.




                             54
                               As discussed earlier, reclamation activities, broadly speaking, may also include
                             environmental remediation. In this section, we distinguish between “surface reclamation,”
                             which includes activities such as recontouring and revegetating the land, and
                             “environmental remediation,” which involves the containment and treatment of hazardous
                             substances or other toxic materials.




                             Page 35                                                       GAO-12-544 Uranium Mining
Figure 3: Examples of Cleanup Activities That Could Take Place at Abandoned Uranium Mine Sites




                                        Note: This figure is illustrative and does not include all possible activities that may take place based
                                        on site-specific conditions.




                                        Page 36                                                                  GAO-12-544 Uranium Mining
The agencies also provided us with examples of costs that have been
incurred at 18 abandoned uranium mine sites. Table 6 provides a range
of costs associated with cleanup efforts depending on the type of work
conducted at each site. It is important to note that these cost ranges are
not exhaustive and that some cleanup costs for other abandoned uranium
mine sites could fall outside these cost ranges.

Table 6: Ranges of Costs for Conducting Cleanup Activities at Selected Abandoned
Uranium Mine Sites

                                                 Number of abandoned
    Primary cleanup work                                uranium sites                                          Range of cost
    conducted at a site                                     examined                                        (in 2011 dollars)
    Address physical safety                                                       6                         $1,800–$33,000
    Conduct surface reclamation                                                   6                         $2,500–$98,000
    Conduct environmental                                                         6           $203,000–$193,000,000a
    remediation
Source: GAO analysis of information received from DOE, the Forest Service, and the National Park Service.
a
 Four of the six examples provided by agencies for this category are based on estimates and not on
actual cleanup costs.


Some examples of the factors that can contribute to the variability in the
costs for cleanup at abandoned uranium mine sites include the following.

•      Number of safety hazards that need to be addressed: BLM and
       National Park Service officials told us that most of the work they have
       conducted to date on abandoned uranium mines is designed to
       mitigate safety hazards. Costs for this type of work have ranged from
       $1,800 to close 2 mine openings in Arches National Park in Utah to
       $33,000 to backfill 11 mine openings with waste rock at the
       Canyonlands National Park in Utah. 55 A BLM official cautioned that
       future costs to address sites with physical safety hazards can be
       higher because BLM has generally addressed safety hazards that are
       the least costly to clean up because of limited available funding. 56




55
     The cleanup costs provided in this section are in 2011 dollars.
56
  According to a BLM draft feasibility study, if current funding levels are maintained in the
future, it will cost BLM $362.7 million to clean up all of the known abandoned mines,
including uranium mines, with physical safety hazards, requiring 77 years.




Page 37                                                                                    GAO-12-544 Uranium Mining
•     Extent to which surface reclamation needs to be conducted: The
      primary purpose of activities under this category is to return the land
      to as near its previous appearance as possible through recontouring
      and revegetating disturbed land. According to DOE documents, the
      costs to reclaim the surface ranged from about $2,500 for closing 2
      mine openings, recontouring 70 cubic yards of dirt, and revegetating 1
      acre of disturbed land at the Nine Mile Hill Mines on BLM-managed
      land in Colorado to nearly $98,000 for more extensive reclamation
      work at the Hawk Mine Complex on lands managed by BLM in
      Colorado. 57 The work at this site primarily focused on the installation
      of multiple gates over mine openings, backfilling 500 cubic yards of
      surface pits with waste materials, recontouring 6,800 cubic yards of
      waste rock materials from 8 waste rock piles, and revegetating 4
      acres of disturbed area.

•     Extent to which environmental remediation must be undertaken: Most
      of the activities in this category are designed to mitigate significant
      environmental hazards. Officials from BLM, the Forest Service,
      National Park Service, DOE, and EPA told us that few abandoned
      uranium mine sites have undergone remediation, but cited two
      instances in which this work has occurred or is ongoing and proved to
      be costly and the costs varied significantly. 58 For example, according
      to our review of agency documents, the Pryor Mountain Mine, located
      on land managed by the Forest Service in Montana, cost about
      $200,000 to clean up, and involved environmental remediation to
      remove contaminated soil and waste rock that posed a human health
      risk. The site, located close to an Indian reservation and near hiking
      trails and campsites, initially presented levels of radioactive
      contamination that were up to 369 times higher than normal
      background levels. At another site—the 320-acre open pit Midnite
      Mine site in Washington state—costs are estimated to be as high at
      $193 million by the time remediation is complete, according to EPA
      documents. 59 Most of this cost is for treating acid rock drainage in two



57
    BLM contracted with DOE to conduct this reclamation work on its land.
58
    Both of these examples are from EPA’s Superfund program.
59
  This site is located partially on BLM-managed land and tribal lands within the Spokane
Indian Reservation. The federal government reached a settlement agreement with mining
companies responsible for the site, under which these companies agree to conduct
cleanup work and reimburse certain response costs of the federal government. The
government agreed to contribute approximately 20 percent of the expected cleanup costs.




Page 38                                                        GAO-12-544 Uranium Mining
                  large open pits that contain millions of gallons of water and then filling
                  these pits with 33 million tons of waste materials. Some mine sites
                  that require environmental remediation also require long-term—
                  defined as longer than 5 years—maintenance and monitoring,
                  especially if contaminated water requires treatment. For example, one
                  of the largest costs (approximately $32 million) associated with
                  environmental remediation at the Midnite Mine site is for monitoring
                  and treating surface and underground water. EPA estimates that this
                  water will need to be treated in perpetuity.

              Additional information on these and other abandoned uranium mine sites
              is presented in appendix IV.


              Having adequate financial assurances to pay for reclamation costs for
Conclusions   federal land disturbed by uranium operations is critical to ensuring that
              the land is returned to its original state if operators fail to complete the
              reclamation as required. BLM, the Forest Service, DOE, and NRC play
              key roles in establishing and reviewing these financial assurances for
              uranium operations on federal land. We found that nearly all of the
              uranium operations on federal land had adequate financial assurances,
              according to our analysis of agency data. However, we found some
              limitations in agencies’ oversight of uranium operations’ financial
              assurances, which raise some concerns about these financial
              assurances. In particular, ISR operations account for a large proportion of
              financial assurances in place for uranium operations on federal land and
              have recently been increasing for some operations, yet there is little
              coordination between BLM and NRC when establishing and reviewing
              these assurances. This lack of coordination raises concerns about the
              adequacy of the financial assurances in place for existing ISR operations
              and for those ISR operations that are awaiting approval. Both BLM and
              NRC have specific expertise in assessing certain aspects of the
              reclamation activities that are required at ISR sites, but have no process
              in place to share this information and leverage their expertise. Without
              such coordination, the agencies cannot be confident that the assurances
              they establish for ISR operations will be adequate to cover the costs of
              reclamation.

              BLM relies on its LR2000 database and Bond Review Report to provide
              information that supports its oversight of financial assurances. However,
              data entered into LR2000 are sometimes inaccurate and not always
              updated in a timely manner in keeping with BLM’s requirements.
              Moreover, the Bond Review Report does not examine expired operations,



              Page 39                                               GAO-12-544 Uranium Mining
                      yet we found that some of these operations have large financial
                      assurances in place or have not been inspected in 10 years. Without
                      complete, timely, and accurate information in LR2000 and the Bond
                      Review Report, the usefulness of these management tools to BLM may
                      be diminished and may limit effective oversight of uranium operations.

                      Finally, identifying the number, location, and cost of cleanup of
                      abandoned mines is a challenging task for federal agencies. However,
                      this process has been made more difficult because the agencies have not
                      been able to reach agreement on a consistent definition for what
                      constitutes an abandoned mine site. Without a consistent definition, data
                      collection efforts are hampered and agency databases cannot be
                      combined to provide a more complete picture of abandoned mines on
                      federal land.


                      To help better ensure that financial assurances are adequate for uranium
Recommendations for   mining operations on federal land, we are recommending the following
Executive Action      three actions.

                         The Secretary of the Interior and the Chairman of the Nuclear
                          Regulatory Commission should enhance their coordination on
                          financial assurances for ISR operations through the development of a
                          memorandum of understanding that defines roles and promotes
                          information sharing.

                         The Secretary of the Interior should direct the Director of the Bureau
                          of Land Management to take the following actions to improve
                          oversight of financial assurances:

                               include information on expired mine operations in the annual Bond
                                Review Report process, and

                               develop guidance to ensure accurate and prompt data entry in
                                LR2000.

                      To enhance data collection efforts on abandoned mines, we recommend
                      that the Secretaries of the Interior and of Agriculture and the
                      Administrator of the Environmental Protection Agency work to develop a
                      consistent definition of abandoned mine sites for use in data-gathering
                      efforts.




                      Page 40                                             GAO-12-544 Uranium Mining
                  We provided a draft of this report to the Department of Agriculture, the
Agency Comments   Department of Energy, the Department of the Interior, the Environmental
                  Protection Agency, and the Nuclear Regulatory Commission for review
                  and comment. All of these agencies concurred with our
                  recommendations. In particular, NRC recognized that development of a
                  memorandum of understanding on financial assurance reviews could be
                  beneficial to NRC and BLM, and plans to pursue such an agreement with
                  BLM. NRC noted that development of a memorandum of understanding
                  that adequately addresses both agencies’ regulatory oversight may be
                  challenging and stated that the agency may pursue other, less formal
                  methods of coordination with BLM if a memorandum of understanding
                  cannot be developed. In addition, DOE stated that a national database for
                  uranium mining activities would be useful, and the agency agreed there is
                  a need for federal agencies with uranium mines on their land to have
                  common definitions and to use these definitions when gathering
                  information that could be used to determine reclamation needs. Similarly,
                  EPA agreed that a consistent definition of abandoned mine sites would be
                  useful, and will work with other relevant agencies to develop a definition,
                  if possible. Furthermore, EPA commented that our report lacked
                  specificity with regard to our use of the terms “reclamation” and
                  “remediation.” We have modified our report to include more specific
                  definitions of each of these terms and clarified what each of these terms
                  means in the context of the report. EPA and the Department of the
                  Interior also provided us with technical comments, which we have
                  incorporated as appropriate. See appendixes V, VI, VII, VIII, and IX for
                  agency comment letters from the Department of Agriculture, DOE, the
                  Department of the Interior, EPA, and NRC, respectively.




                  Page 41                                             GAO-12-544 Uranium Mining
As agreed with your office, unless you publicly announce the contents of
this report earlier, we plan no further distribution until 30 days from the
report date. At that time, we will send copies of this report to the
appropriate congressional committees, the Secretary of Agriculture, the
Secretary of Energy, the Secretary of the Interior, the Environmental
Protection Agency Administrator, the Chairman of the Nuclear Regulatory
Commission, and other interested parties. In addition, the report will be
available at no charge on the GAO website at http://www.gao.gov.

If you or your staff members have any questions about this report, please
contact us at (202) 512-3841 or mittala@gao.gov. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on
the last page of this report. GAO staff who made major contributions to
this report are listed in appendix X.

Sincerely yours,




Anu K. Mittal
Director,
Natural Resources and Environment




Page 42                                             GAO-12-544 Uranium Mining
Appendix I: Objectives, Scope, and
              Appendix I: Objectives, Scope, and
              Methodology



Methodology

              Our objectives were to (1) compare Bureau of Land Management (BLM),
              Forest Service, and Department of Energy (DOE) oversight of uranium
              exploration and extraction operations on federal land; (2) determine the
              number and status of uranium operations on federal land; (3) examine the
              coverage and amounts of financial assurances in place for reclaiming
              current uranium operations on federal land; and (4) examine what is
              known about the number and location of abandoned uranium mines on
              federal land and their potential cleanup costs.

              To compare BLM, Forest Service, and DOE oversight of uranium
              exploration and extraction on federal land, we reviewed federal laws,
              regulations, and guidance, as well as prior GAO reports and other studies
              on hardrock mining operations. 1 We also spoke with BLM, Forest Service,
              and DOE officials in headquarters and field offices, and BLM state offices
              in Arizona, Colorado, New Mexico, Utah, and Wyoming—five states with
              large uranium deposits. We also reviewed DOE lease contracts. To
              understand the interagency relationship among BLM, the Forest Service,
              and DOE, as well as the these agencies’ relationship with the states, we
              reviewed memorandums of understanding among these parties. We also
              spoke with state representatives of mining and environmental agencies in
              Arizona, Colorado, New Mexico, Texas, Utah, and Wyoming to discuss
              how they coordinate with federal agencies while reviewing uranium
              operations and their financial assurances. We discussed relevant issues
              for hardrock operations and financial assurances with representatives
              from the mining industry, state geological services, and an environmental
              group. We also examined relevant regulations from EPA and NRC and
              spoke with officials from these agencies.

              To determine the number and status of uranium operations on federal
              land, we gathered information from BLM, the Forest Service, and DOE.
              To identify uranium operations on BLM land, we requested that BLM
              provide an extract from its LR2000 database for operations—both notices
              and plans of operations—that were in an authorized, expired, or pending


              1
               We did not include tribal lands in our review of uranium operations on federal land.
              Currently, there are no active uranium mining operations on tribal lands; however, there
              are abandoned uranium mines on these lands that will require extensive remediation in
              some cases. We have included an example of the anticipated remediation actions needed
              at one such site in our report. In addition, the Environmental Protection Agency (EPA),
              DOE, the Nuclear Regulatory Commission (NRC), the Bureau of Indian Affairs, and the
              Indian Health Service are implementing a 5-year plan to address the health and
              environmental impacts of uranium contamination in the Navajo nation.




              Page 43                                                      GAO-12-544 Uranium Mining
Appendix I: Objectives, Scope, and
Methodology




status and listed “uranium” or “uranium and other minerals” as the
commodity that was being targeted. To determine the reliability of these
data, we spoke with a BLM information technology official responsible for
administering the system; BLM state and field office staff who enter
information into the system; and BLM managers at the agency’s
Washington, D.C., headquarters office who use information from the
system. We also reviewed database documentation, and we determined
the LR2000 data were sufficiently reliable for our purposes. We used
these data to administer a web-based survey to BLM field staff
responsible for overseeing uranium operations in 25 field offices across
eight states—Arizona, Colorado, Nevada, New Mexico, Oregon, South
Dakota, Utah, and Wyoming. We asked these staff to provide the status
of these operations based on the most recent information available using
the following eight status levels and definitions, which we developed in
consultation with BLM staff:

•   exploration permitting (e.g., operator is in the process of obtaining
    permits to conduct exploration at the site),

•   exploration (e.g., operator is preparing the site for exploration or
    conducting exploration work at the site; concurrent reclamation may
    also be taking place),

•   extraction permitting (e.g., operator is in the process of obtaining
    permits to extract uranium at the site), 2

•   extraction (e.g., operator is preparing the site for extraction or actively
    extracting uranium at the site; concurrent reclamation may also be
    taking place),

•   standby (e.g. operator is authorized to explore or extract, but is not
    doing so),

•   reclamation (e.g., reclamation is taking place at the site following the
    end of exploration or extraction activities),




2
 On our survey, we used the terms “mine permitting” and “production.” For the purposes
of using consistent terms in this report, we are substituting the terms “extraction
permitting” and “extraction.”




Page 44                                                      GAO-12-544 Uranium Mining
Appendix I: Objectives, Scope, and
Methodology




•   closed (e.g., reclamation is complete and financial assurance has
    been released), and

•   other.

As part of this survey, we asked BLM staff to provide copies of the
documentation they consulted when determining the status of the
operation, such as inspection reports or correspondence with operators,
and we used these documents to verify the reported status. For field
offices overseeing a large number of operations, we requested they
provide documents for 10 operations they oversaw, which we selected
randomly. We also asked BLM staff if there had been any uranium
extracted at the operation in the last 5 years. Prior to sending out this
survey, we pretested it with officials from 3 BLM field offices and revised
some of the survey questions based on their input. We received
responses to our survey from all 25 field offices, and we sent follow-up
questions based on their survey responses to clarify certain responses or
to ask for additional information.

Because the Forest Service and DOE oversee fewer uranium operations
than BLM, we did not use our survey to collect information on the status
of these operations; instead, we gathered this information through
interviews with agency officials and agency documents. The Forest
Service compiled information on its uranium operations by contacting
Forest Service officials who were located in National Forests where
uranium operations are located. The Forest Service also provided
documentation on these operations that we used to verify the information
it provided. DOE provided information on its lease tracts that it maintains
as part of its program. We used DOE’s annual status report on its lease
tracts to help to verify the reported status levels along with conversations
with DOE officials. For both the Forest Service and DOE, we used
interviews with officials along with relevant documentation to determine
the reliability of these data, and we determined they were sufficiently
reliable for our purposes.

To examine the financial assurances in place for uranium mining on BLM
land, we reviewed information in BLM’s Bond Review Report, which
aggregates data on financial assurances from BLM’s LR2000 database,
including the required amount of the financial assurance for an operation,
the amount of the financial assurance in place, and when it was last
reviewed. As part of this analysis, we examined whether the financial
assurances in place were adequate to cover the estimated costs of
reclamation; we did not determine whether the estimated costs for


Page 45                                              GAO-12-544 Uranium Mining
Appendix I: Objectives, Scope, and
Methodology




reclamation were sound because that was outside the scope of our
review. Since the Bond Review Report relies on LR2000 data, we used
our data reliability assessment of LR2000 detailed above to help
determine whether the data in the report were reliable. In addition, we
obtained a copy of the specifications that were used to create the Bond
Review Report and examined the report to identify outliers in the data or
incomplete fields and used BLM documents or discussions with BLM staff
to clarify any issues we identified. We determined that BLM’s financial
assurance data in its Bond Review Report were sufficiently reliable for the
purposes of our review. Because BLM’s Bond Review Report contains
only information on authorized operations, we gathered information on
financial assurances from LR2000 for the expired operations.

To examine the financial assurances in place for uranium operations on
Forest Service land and DOE’s lease tracts, we examined data provided
by these agencies. Specifically, we compared the financial assurance
amounts that were required with the amounts that were in place. As we
did for our analysis of BLM’s data, we examined whether the financial
assurances in place were adequate to cover the estimated costs of
reclamation; we did not determine whether the estimated costs for
reclamation were sound because that was outside the scope of our
review. To determine the reliability of the data from the Forest Service
and DOE, we interviewed agency staff who gathered these data, and we
used supporting documentation to corroborate the information that was
reported. We determined that these data were sufficiently reliable for our
purposes.

To learn about the number and location of abandoned uranium mines on
federal land, we reviewed data from BLM, the Forest Service, EPA, the
National Park Service, and DOE, which are all involved in efforts to track
and clean up abandoned uranium mines. We received and analyzed data
from databases these agencies maintain on abandoned uranium mines.
We also reviewed pertinent documents that accompanied some of these
databases and other agency documentation, such as studies or reports
that describe the status of abandoned uranium mines on lands managed
or leased by these agencies. We conducted two sets of semistructured
interviews with officials in charge of abandoned mine programs at all of
these agencies—before and after we reviewed the data and
documentation—to gather more information about these databases,
including identifying limitations and determining the reliability of the data
in the databases. We also conducted interviews with officials from the
U.S. Geological Survey, which maintains the data used by the Forest
Service. We also interviewed staff from BLM field offices and state


Page 46                                              GAO-12-544 Uranium Mining
Appendix I: Objectives, Scope, and
Methodology




agencies in the states where most uranium deposits are located to get
more information on the number and location of abandoned uranium
mines and to hear their perspectives on the federal databases. As a result
of our efforts, we determined that these data were not sufficiently reliable
to establish a definite number of abandoned uranium mines. However,
because these were the only federal data available, we have used them
in the report only to discuss in general terms the number of potential
abandoned uranium mine sites that may exist on federal lands, and we
have described the limitations associated with these data.

To describe the potential cleanup costs posed by abandoned uranium
mines, we reviewed relevant literature and conducted semistructured
interviews with officials from the federal agencies in charge of abandoned
mines. 3 On the basis of this information, we identified three distinct
cleanup categories that we and agency officials believe are most
representative of the types of actions that take place at abandoned
uranium mine sites. In developing these categories, we consulted with
officials from all five agencies in charge of cleaning up abandoned
uranium mine sites, and they agreed with our approach and our
categories. These categories are not mutually exclusive, and cleanup
work at a site could fall within multiple categories, especially at larger or
more contaminated sites. These cleanup categories included actions
taken to

•   address safety hazards, which means that most cleanup activities at
    the site are intended to mitigate safety hazards;

•   conduct surface reclamation, which means that most cleanup
    activities at the site are intended to return the land to its appearance
    before mining activities took place; and

•   conduct environmental remediation, which means that most cleanup
    activities at the site are intended to deal with removing land and water
    contamination that poses a threat to the environment and human
    health. These activities can also include long-term—defined as longer
    than 5 years—maintenance and monitoring.




3
 For the purposes of describing the work conducted on abandoned uranium mines, we are
using the term “cleanup” to encompass a variety of activities necessary to address these
abandoned mine sites.




Page 47                                                      GAO-12-544 Uranium Mining
Appendix I: Objectives, Scope, and
Methodology




We also asked officials from these five agencies to provide us with
examples that are illustrative of the range of costs associated with
performing such cleanup work. We asked for examples of sites that have
already been cleaned up and have definitive costs, or information on sites
that have detailed cost estimates. We received 18 examples from the
agencies, which are divided equally across the three cleanup categories.
Fourteen examples are for past work and contain actual cleanup costs; 4
examples, all in the environmental remediation category, are for work that
is still to be completed and are based on estimated costs. For better
comparison purposes, we reported these cost numbers in 2011 dollars.
For each example, we asked for and received documentation that
describes in detail the work performed at each site. For the sites that
have not been cleaned up yet, we received pertinent documentation, such
as records of decision or consent decrees.

To get a better understanding of uranium mining in general, we
conducted site visits to Colorado and Wyoming to examine uranium
operations. We visited these states because they have a variety of
uranium operations involving several federal agencies. In Colorado, we
spoke with BLM, DOE, and state officials involved in overseeing uranium
operations. We also spoke with representatives of a uranium company
and toured some uranium operations including some underground mines
that were on standby on land managed by BLM and a few abandoned
mine sites. In addition, we toured two DOE lease tracts and examined
reclamation work that had been performed on these tracts. In Wyoming,
we met with BLM and state officials involved in overseeing uranium
operations and spoke with representatives of some uranium companies.
In addition, we toured an in situ recovery operation and examined the
various components of this operation.

We conducted this performance audit from June 2011 through May 2012
in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that
the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.




Page 48                                            GAO-12-544 Uranium Mining
Appendix II: Information on In Situ Recovery
                                         Appendix II: Information on In Situ Recovery
                                         Operations on BLM Land That Are Extracting
                                         Uranium, on Standby, or Awaiting Federal
Operations on BLM Land That Are Extracting Uranium,
                                         Authorization


on Standby, or Awaiting Federal Authorization

                                         This appendix provides information on in situ recovery (ISR) operations
                                         on land managed by BLM. Some of these operations are not entirely on
                                         federal land, but rather include state and private land. The Forest Service
                                         and Department of Energy officials reported that they do not have any
                                         ISR operations on land they manage.

Table 7: Information on ISR Operations Located on BLM-Managed Land and Their Associated Financial Assurance

                                                      Financial assurance amount
Name                Location    Operator                       (dollars in millions)               Status
Highland            Wyoming     Cameco                                                 $92.73      Extracting uranium.
Smith Ranch         Wyoming     Cameco                                                 120.04      Extracting uranium.
Willow Creek        Wyoming     Uranium One                                                 16.3   Extracting uranium.
Gas Hills           Wyoming     Cameco                                                      3.47   Waiting for BLM authorization. Authorized
                                                                                                   by the Nuclear Regulatory Commission
                                                                                                   (NRC).
Hank and Nichols    Wyoming     Uranerz                                                      6.8   Waiting for BLM authorization.
                                                                                                   Authorized by NRC.
Lost Creek          Wyoming     UR Energy                                                   2.09   Waiting for BLM authorization. Authorized
                                                                                                   by NRC.
Reynolds Ranch      Wyoming     Cameco                            Smith Ranch financial            Authorized by BLM and NRC but not
                                                                  assurance covers this            extracting uranium.
                                                                             operation.
Ross                Wyoming     Strata                         No decision on financial            Waiting for BLM and NRC authorization.
                                                                        assurance yet.
Ruth                Wyoming     Cameco                                                  $0.18      BLM has not yet received a plan of
                                                                                                   operations for this operation. Authorized by
                                                                                                   NRC.
Dewey Burdock       South       Powertech                      No decision on financial            Waiting for BLM and NRC authorization.
                    Dakota                                              assurance yet.
                                         Source: GAO analysis of BLM and NRC information.




                                         Page 49                                                                    GAO-12-544 Uranium Mining
Appendix III: Detailed Information on
                                       Appendix III: Detailed Information on Federal
                                       Abandoned Mine Databases



Federal Abandoned Mine Databases

                                       This appendix provides information on federal databases that contain
                                       information on abandoned uranium mines, and the limitations that we
                                       identified for each database.

Table 8: Information on Federal Abandoned Mine Databases and Their Limitations

                                      Number of                            Number of
                                     abandoned                            abandoned
                                        uranium           Mines       uranium mines
                                     mines listed cleaned up to      in the database
                                           in the date listed in       that remain to
Agency          Database name          databasea the databasea        be cleaned upa      Limitations with the data
BLM             Abandoned Mine-            3,038            1,849               1,189   •    Entering the mined commodity in
                Site Cleanup                                                                 this database is optional. Only three
                Module (AMSCM)b                                                              BLM state offices (Colorado, Utah,
                                                                                             and Wyoming) require BLM staff to
                                                                                             enter information on the mined
                                                                                             commodity.
                                                                                        •    The database does not provide
                                                                                             information on the extent to which
                                                                                             extraction took place at a site.
                                                                                        •    BLM officials from various field
                                                                                             offices who enter information in the
                                                                                             database use their own definition of
                                                                                             a “site.”
                                                                                        •    Some sites have not been verified
                                                                                             through field inspection.
The Forest      Forest Service             1,097        Unknown             Unknown     •    MRDS has not been updated since
Service         Abandoned                                                                    1995. Also, it does not include
                Mineral Lands                                                                information on the major commodity
                Database, which                                                              mined for over 22,000 of its records.
                relies entirely on                                                      •    The database does not provide
                the U.S.                                                                     updated information on the extent to
                Geological                                                                   which extraction took place at a site.
                Survey’s (USGS)
                                                                                        •    The definition used by the Forest
                Mineral Resources
                                                                                             Service for a site is different than
                Data System
                                                                                             the definition used by the USGS for
                (MRDS)c
                                                                                             its MRDS database.
                                                                                        •    Few sites have been verified
                                                                                             through field inspection.
                                                                                        •    MRDS does not identify whether a
                                                                                             site has already been cleaned up or
                                                                                             not.
                                                                                        •    MRDS database contains many
                                                                                             duplicates.
National Park   Servicewide                   46                21                 25   •   Entering the commodity field is
Service         Abandoned                                                                   optional for National Park Service
                Mineral Lands                                                               staff.
                Database




                                       Page 50                                                         GAO-12-544 Uranium Mining
                                 Appendix III: Detailed Information on Federal
                                 Abandoned Mine Databases




                                Number of                                       Number of
                               abandoned                                       abandoned
                                  uranium           Mines                  uranium mines
                               mines listed cleaned up to                 in the database
                                     in the date listed in                  that remain to
Agency   Database name           databasea the databasea                   be cleaned upa                Limitations with the data
EPA      Technologically               8,124             Unknown                    Unknown                Some data were not included in the
         Enhanced                                                                                           database because they did not have
         Naturally Occurring                                                                                adequate geographic coordinates.
         Radioactive                                                                                       The database does not track the
         Materials Uranium                                                                                  extent to which extraction took place
         Location Database                                                                                  at a site.
                                                                                                           The database does not track which
                                                                                                            mines have already been cleaned
                                                                                                            up.
                                                                                                           The definition of a mine used by the
                                                                                                            different databases from which the
                                                                                                            Uranium Location Database was
                                                                                                            compiled leads to problems with
                                                                                                            determining how many mine sites
                                                                                                            exist.
                                                                                                           Some data have not been verified
                                                                                                            through field inspection.
                                                                                                           An unknown number of duplicate
                                                                                                            entries remain in the database.
                                 Source: GAO analysis of information from BLM, the Forest Service, National Park Service, and EPA.
                                 a
                                  The BLM, Forest Service, and National Park Service databases refer to abandoned uranium mine
                                 sites on the lands they manage. The EPA database refers to sites on all federal land.
                                 b
                                 According to a BLM official, AMSCM is a stand-alone internal database housed at the National
                                 Operations Center in Denver, Colorado, which is separate from BLM’s larger LR2000 data system.
                                 c
                                  According to a Forest Service official, the Forest Service is in the process of starting work on its own
                                 database on abandoned mines. The new database will also keep track of which sites have been
                                 cleaned up to date.




                                 Page 51                                                                                   GAO-12-544 Uranium Mining
Appendix IV: Examples of Cleanup Activities
                                            Appendix IV: Examples of Cleanup Activities at
                                            Abandoned Uranium Mine Sites



at Abandoned Uranium Mine Sites

                                            This appendix provides information on cleanup activities at 18 abandoned
                                            uranium mine sites. Fourteen sites have been cleaned up and have
                                            actual cleanup costs, while 4 examples provided by agencies are based
                                            on estimates and not on actual cleanup costs.

Table 9: Examples of Cleanup Activities at Abandoned Uranium Mine Sites

                                                      Summary of cleanup work performed or planned at the sitea
Mine name,
location / (federal                                                                                Conduct               Total cost
agency managing                                    Address physical        Conduct surface         environmental           (in 2011
the land)             Description of the mine      safety hazards          reclamation             remediation             dollars)
Mines where cleanup focused on physical safety
Salt Valley Wash      Two small underground        Backfilled two shafts   None                    None                      $1,818
Mines, Utah           mines, each with one         by hand with 24 and
(National Park        shaft (vertical mine         63 cubic yards of
Service)              opening) in Arches           adjacent waste
                      National Park, dating from   material
                      the 1940s.
Loma Mines,         Conventional                   Backfilled two mine    None                     None                       2,105
Colorado (Bureau of underground mines              adits (horizontal mine
Land Management) located beneath a bluff 2         opening) with trash
                    miles from an interstate       and wood debris, and
                    highway.                       closed them with
                                                   polyurethane foam
Terry Mine, Utah      Conventional                 Backfilled a shaft with Revegetated the site    None                      10,443
(National Park        underground mine             85 cubic yards and an
Service)              located in the Capitol       adit with 50 cubic      Burned wooden
                      Reef National Park, within   yards of waste          structures
                      one-quarter mile of a        materials
                      main road.
                                                   Erected two fences of
                                                   800 and 960 feet in
                                                   length to exclude
                                                   grazing cattle
                                                   Placed warning signs
                                                   around the site
Whirlwind, Utah       Conventional                 Demolished              Demolished an 800-      None                      11,448
(National Park        underground mine             structures              square-foot steel ore
Service)              located about 400 feet                               bin
                      above the elevation of a     Backfilled adits with
                      lake in Glen Canyon          steel, wood, and
                      National Recreation Area.    other debris
                      The cleanup crew and         Closed a drill hole
                      equipment were flown in      with polyurethane
                      by helicopter.               foam
                                                   Posted four warning
                                                   signs




                                            Page 52                                                        GAO-12-544 Uranium Mining
                                            Appendix IV: Examples of Cleanup Activities at
                                            Abandoned Uranium Mine Sites




                                                      Summary of cleanup work performed or planned at the sitea
Mine name,
location / (federal                                                                                Conduct               Total cost
agency managing                                   Address physical         Conduct surface         environmental           (in 2011
the land)             Description of the mine     safety hazards           reclamation             remediation             dollars)
White Rim, Utah       Four conventional           Installed steel gates    None                    None                      22,499
(National Park        underground mines           over five adits
Service)              located in Glen Canyon
                      National Recreation Area.   Backfilled by hand
                      One site is located about   one adit using 8 cubic
                      1 mile from the park’s      yards of material
                      Visitors Center and
                      another about 1 mile from
                      a campground.
Lathtrop Canyon 1-    Conventional                Closed 11 adits using None                       None                      33,021
8, Utah (National     underground mine            various methods
Park Service)         located in Canyonlands
                      National Park that was      Installed warning
                      developed in the late       signs throughout the
                      1950s. The crew             site
                      accessed the site by foot
                      and the equipment was
                      flown in by helicopter.
Mines where cleanup focused on surface reclamation
Nine Mile Hill Mines, Conventional                Backfilled two small     Recontoured 70 cubic None                          2,524
Colorado (Bureau of underground mines             adits with waste rock    yards of waste rock
Land Management) located above a public           material using an        materials
                      highway.                    excavator
                                                                           Revegetated 1 acre
                                                                           of land
Mesa No. 5,         Conventional                  Closed two small-        Recontoured 10,200      None                      12,963
Colorado (Bureau of underground mine that         diameter ventilation     cubic yards of waste
Land Management) contained a waste rock           shafts with              rock material
                    pile, which affected an       polyurethane foam
                    adjacent, intermittent                                 Covered the
                    stream.                       Backfilled a mine        recontoured area with
                                                  opening with 5,200       topsoil excavated
                                                  cubic yards of waste     from a nearby site
                                                  rock materials and
                                                  trash and debris         Revegetated 4 acres
                                                                           of land


Northern Light        Conventional                Placed wood debris       Recontoured 600         None                      17,121
Mines, Colorado       underground mine.           from demolished          cubic yards of waste
(Bureau of Land                                   structures in mine       rock
Management)                                       openings
                                                                         Covered the
                                                  Installed gates over 3 recontoured area with
                                                  adits                  topsoil
                                                  Backfilled 5 additional Revegetated 2 acres
                                                  shafts with waste rock of land




                                            Page 53                                                        GAO-12-544 Uranium Mining
                                             Appendix IV: Examples of Cleanup Activities at
                                             Abandoned Uranium Mine Sites




                                                       Summary of cleanup work performed or planned at the sitea
Mine name,
location / (federal                                                                                 Conduct               Total cost
agency managing                                     Address physical       Conduct surface          environmental           (in 2011
the land)             Description of the mine       safety hazards         reclamation              remediation             dollars)
Rainy Day, Utah       Conventional                  Placed debris from    Demolished              None                        30,768
(National Park        underground mine              demolished structures structures
Service)              located in the Capital        in mine adits
                      Reef National Park 4                                Corrected areas of
                      miles from the main road.     Backfilled 12 adits   severe erosion and
                      The site was accessible       with earth from the   built drainage controls
                      by foot.                      disturbed slope using
                                                    a backhoe
New Verde Mine,     Single underground large None                          Demolished and         None                        78,524
Colorado (Bureau of mine. This is a historic                               disposed of structures
Land Management) site where parts of the                                   offsite
                    operation were left in
                    place and preserved.                                   Removed trash and
                                                                           debris offsite
                                                                           Recontoured 22,000
                                                                           cubic yards of waste
                                                                           rock materials
                                                                           Covered the
                                                                           recontoured area with
                                                                           topsoil
                                                                           Revegetated 6 acres
                                                                           of land
Hawk Mine             A complex of                  Placed debris from     Backfilled 500 cubic     None                      97,589
Complex, Colorado     underground mines that        eight locations in     yards of surface pits
(Bureau of Land       started operations in         mine openings          with waste rock
Management)           1948, consisting of eight                            materials
                      separate and distinct         Backfilled seven mine
                      mine sites, six mine          openings with waste Recontoured 6,800
                      access ramps, three           rock                   cubic yards of waste
                      adits, and one surface pit.                          rock materials from
                                                    Installed gates at     eight waste rock piles
                                                    three mine openings
                                                                           Covered the
                                                    Closed nine small      recontoured area with
                                                    ventilation shafts and 1,000 cubic yards of
                                                    132 exploration drill  topsoil
                                                    holes using
                                                    polyurethane foam      Revegetated 4 acres
                                                                           of land




                                             Page 54                                                        GAO-12-544 Uranium Mining
                                             Appendix IV: Examples of Cleanup Activities at
                                             Abandoned Uranium Mine Sites




                                                       Summary of cleanup work performed or planned at the sitea
Mine name,
location / (federal                                                                                Conduct                   Total cost
agency managing                                     Address physical         Conduct surface       environmental               (in 2011
the land)              Description of the mine      safety hazards           reclamation           remediation                 dollars)
Mines where cleanup focused on environmental remediation
Pryor Mountain         Two separate mines           Installed gates over   Revegetated all of the Removed human                203,238
Mine, Carbon           developed in the 1950s       three adits            disturbed areas within health risks related to
County, Montana        located in an area where                            the site               the site (no details
(the Forest Service)   hiking and camping take      Backfilled a number                           were available of the
                       place. The site is also      of exploration pits                           actual work
                       used as a sacred ground      Removed 4- to 8- foot                         conducted)
                       by a nearby Indian tribe.    highwalls (edge of the
                       The site was accessible      mine)
                       by four-wheel-drive roads,
                       and large equipment was      Removed one
                       brought in by helicopter.    collapsed structure

Workman Creek          The site, developed in the Plan to:                   Plan to:              Plan to:                    600,000b
Uranium Mines, Gila    1950s, encompasses                                                                                    (estimate)
County, Arizona (the   eight mines on steep       Install warning signs      Backfill the excavated Backfill all 33 mine
Forest Service)        hillsides located near                                areas with clean soil openings with 30,500
                       campgrounds. Waste                                                           cubic yards of waste
                                                                             Recontour some         rock, some of which
                       rock piles contain                                    areas to establish
                       elevated levels of                                                           is contaminated, and
                                                                             stability and prevent  close them with
                       carcinogenic and                                      water runoff
                       radioactive elements, and                                                    polyurethane foam
                       there is concern of these                             Cut off road access to Remove 500 cubic
                       materials getting into                                the site               yards of
                       major water supplies that                                                   contaminated waste
                       serve the Phoenix                                                           rock piles from the
                       metropolitan area.                                                          campgrounds and
                                                                                                   creek side and place
                                                                                                   in a repository on site
San Mateo Uranium The site, which operated          Plan to:                 Plan to:              Plan to:                  3,095,750b
Mine, New Mexico     between 1957 and 1971,                                                                                  (estimate)
(the Forest Service) is located in a remote         Install an 8-foot-high   Recontour and         Consolidate and
                     location with limited public   chain-link fence to      revegetate            cover 180,000 cubic
                     access. The waste rock         enclose                  approximately 35      yards of
                     pile is toxic and              approximately 17         acres to further      contaminated waste
                     radioactively                  acres necessary to       reduce windblown      rock pile
                     contaminated, and storm        exclude wildlife and     transport of any
                                                    livestock from           residual              Conduct ongoing
                     water runoff from this pile                                                   maintenance to repair
                     flows into a nearby creek.     destroying the           contamination
                                                    vegetation                                     erosion of the cap
                                                                                                   material and of the
                                                                                                   drainage channels
                                                                                                   after heavy rainfall
                                                                                                   events




                                             Page 55                                                          GAO-12-544 Uranium Mining
                                              Appendix IV: Examples of Cleanup Activities at
                                              Abandoned Uranium Mine Sites




                                                        Summary of cleanup work performed or planned at the sitea
Mine name,
location / (federal                                                                                     Conduct                    Total cost
agency managing                                       Address physical         Conduct surface          environmental                (in 2011
the land)             Description of the mine         safety hazards           reclamation              remediation                  dollars)
White King Lucky      This site consists of two       Installed three-strand   Regraded, replaced       Removed                    5,939,087
Lass, Oregon (the     conventional open pit           barbed wire fencing      topsoil, capped with a   contaminated soil from
Forest Service)       mines for a combined 140        around wetlands and      dry cover system, and    the stockpiles
                      acres of disturbed land. It     reclaimed waste          revegetated the
                      operated between 1955           stockpiles               waste rock piles         Relocated the flow of
                      and 1965. The site had                                                            the creek into historic
                      three large waste rock piles                             Restored and             channels and
                      of approximately 1.26                                    revegetated other        constructed three
                      million cubic yards and two                              disturbed areas          wetland areas to
                      large pits that cover                                                             prevent runoff into the
                      approximately 5 and 14                                                            creek
                      acres, which are full with                                                        Installed 10 wells for
                      millions of gallons of water.                                                     groundwater
                      Carcinogenic and                                                                  monitoring
                      radioactive contaminants
                      were found at the site and                                                        Plan to perform long-
                      a creek runs next to the                                                          term monitoring and
                      mine and received                                                                 regular neutralization
                      discharge from this                                                               of the pit water to
                      contaminated pit. This site                                                       prevent any acidic
                      was added to EPA’s                                                                water from reaching
                      National Priority List in                                                         the creek
                      1995.
Riley Pass Mine,      This site, which operated in None                        Plan to:                 Plan to:                  74,733,520b
Harding County,       the 1950s and 1960s,                                                                                         (estimate)
South Dakota (the     involves 12 mine groups                                  Reshape the              Establish a series of
Forest Service)       and spreads over                                         highwalls                sediment control
                      approximately 1,000 acres.                                                        measures, such as
                                                                               Fill or reshape the      sediment ponds, to
                      The site consists of                                     erosion gullies
                      numerous open pits, waste                                                         control runoff
                      rock piles, and five                                     Stabilize the fragile    Excavate and place
                      sediment ponds. The area                                 soils and revegetate     contaminated
                      is prone to erosion, and the                             the area                 material in designed
                      site poses safety concerns                                                        repositories, or cap
                      from unstable highwalls.                                                          the contaminated
                      The site also poses health                                                        material in place
                      and environmental risks
                      from heavy metals and                                                             The Forest Service
                      radiation. Two mines have                                                         estimates that a long-
                      already been cleaned up                                                           term maintenance
                      and cleanup at a third is                                                         effort will be needed
                      ongoing. The U.S.                                                                 for at least 100 years
                      government is currently                                                           because of the fragile
                      involved in a bankruptcy                                                          soil and climate
                      proceeding with potentially                                                       conditions
                      responsible parties to
                      recover costs for the
                      remaining cleanup.




                                              Page 56                                                              GAO-12-544 Uranium Mining
                                            Appendix IV: Examples of Cleanup Activities at
                                            Abandoned Uranium Mine Sites




                                                       Summary of cleanup work performed or planned at the sitea
Mine name,
location / (federal                                                                                                    Conduct                                Total cost
agency managing                                    Address physical                  Conduct surface                   environmental                            (in 2011
the land)             Description of the mine      safety hazards                    reclamation                       remediation                              dollars)
Midnite Mine,         This is a more than 320-     Plan to:                          Plan to:                          Plan to:                           193,000,000b
Stevens County,       acre open pit mine that                                                                                                               (estimate)
Washington (Bureau    operated from 1954 to        Build a fence around              Cover the four pits               Empty out the two
of Land               1981. Approximately 33       the site and boulder              that were backfilled              pits full with acid
Management)           million tons of waste        barriers around the               with a thick dry cover,           water and treat this
                      material was dug up from     contaminated waste                clean soil, and                   water at a water
                      six large pits, two of       piles                             vegetation                        treatment plant on
                      which have not been                                                                              site
                                                                                     Grade and cover
                      backfilled and are full of                                     waste piles and areas             Cover the bottom of
                      water. Numerous piles of                                       cleaned of waste                  these pits with a thick
                      waste materials are also                                       throughout the site               drainage layer where
                      located throughout the                                         with fresh soil and               water can collect and
                      site. High levels of toxic                                     vegetation                        install a water
                      and radioactive chemicals                                                                        removal system along
                      are at the site. Acidic                                        Conduct long-term                 with filling the pits
                      water drains into a nearby                                     maintenance and                   with waste rock and
                      creek. Some cleanup                                            monitoring of the dry             covering the pits with
                      work at the site has                                           cover systems and                 a thick vegetated
                      already been conducted.                                        the vegetation to                 cover
                      This site was added to                                         mitigate acid rock
                      EPA’s National Priority                                        drainage                          Build a new water
                      List in 2000.                                                                                    treatment plant to
                                                                                                                       treat millions of
                                                                                                                       gallons of acidic
                                                                                                                       groundwater and
                                                                                                                       dispose of sludge
                                                                                                                       Build sediment
                                                                                                                       barriers to prevent
                                                                                                                       sediment migration
                                                                                                                       from the mine
                                                                                                                       drainages into the
                                                                                                                       creek
                                                                                                                       Conduct ongoing
                                                                                                                       maintenance and
                                                                                                                       monitoring of water
                                                                                                                       treatment and remove
                                                                                                                       sludge for at least
                                                                                                                       140 years

                                            Sources: GAO analysis based on information provided by DOE, the Forest Service , and the National Park Service.
                                            a
                                             It is important to note that we summarized some of the key activities performed at the site; other
                                            activities may also have taken place at the site.
                                            b
                                             This amount is an estimate, since cleanup has not yet been completed or has not started at the site.




                                            Page 57                                                                                   GAO-12-544 Uranium Mining
Appendix V: Comments from the Department
             Appendix V: Comments from the Department
             of Agriculture



of Agriculture




             Page 58                                    GAO-12-544 Uranium Mining
Appendix VI: Comments from the
             Appendix VI: Comments from the Department
             of Energy



Department of Energy




             Page 59                                     GAO-12-544 Uranium Mining
Appendix VI: Comments from the Department
of Energy




Page 60                                     GAO-12-544 Uranium Mining
Appendix VII: Comments from the
             Appendix VII: Comments from the Department
             of the Interior



Department of the Interior




             Page 61                                      GAO-12-544 Uranium Mining
Appendix VIII: Comments from the
             Appendix VIII: Comments from the
             Environmental Protection Agency



Environmental Protection Agency




             Page 62                            GAO-12-544 Uranium Mining
Appendix VIII: Comments from the
Environmental Protection Agency




Page 63                            GAO-12-544 Uranium Mining
Appendix IX: Comments from the Nuclear
             Appendix IX: Comments from the Nuclear
             Regulatory Commission



Regulatory Commission




             Page 64                                  GAO-12-544 Uranium Mining
Appendix IX: Comments from the Nuclear
Regulatory Commission




Page 65                                  GAO-12-544 Uranium Mining
Appendix X: GAO Contact and Staff
                  Appendix X: GAO Contact and Staff
                  Acknowledgments



Acknowledgments

                  Anu K. Mittal, (202) 512-3841 or mittala@gao.gov
GAO Contact
                  In addition to the individual named above, Andrea Brown and Elizabeth
Staff             Erdmann (Assistant Directors), Antoinette Capaccio, Julia Coulter, Maria
Acknowledgments   Gaona, Scott Heacock, Cristian Ion, Rebecca Shea, Carol Herrnstadt
                  Shulman, and Jena Sinkfield made key contributions to this report.




(361296)
                  Page 66                                            GAO-12-544 Uranium Mining
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