ML20132F918
| ML20132F918 | |
| Person / Time | |
|---|---|
| Issue date: | 07/15/1985 |
| From: | Roberts T NRC COMMISSION (OCM) |
| To: | Udall M HOUSE OF REP., INTERIOR & INSULAR AFFAIRS |
| Shared Package | |
| ML20132F924 | List: |
| References | |
| NUDOCS 8508020438 | |
| Download: ML20132F918 (23) | |
Text
r' UNITED STATES
.y g
NUCLEAR REGULATORY COMMISSION g
E WASHINGTON, D. C. 20555
%.....M CHAIRMAN July 15, 1985 The Honorable Morris K. Udall, Chairman Committee on Interior & Insular Affairs United States House of Representatives Washington, D. C.
20515
Dear Mr. Chairman:
Your letter of June 26, 1985 included questions regarding recently introduced legislation concerning cleanup of active uranium and thorium processing sites.
Responses to those questions are enclosed.
Based on our preliminary review of the bills (H.R. 2236 and S. 1004), we are unsure of the implications of several aspects of the legislation; for example, Section 3(e) regarding the transfer of Agreement State and NRC licenses to the Department of Energy.
We are proceeding to finalize our review of the legislation and will promptly forward our comments to you when
-available.
Sincerely, T omas M.' Roberts Acting Chairman
Enclosure:
As Stated cc:
Rep. Manuel Lujan hROC 850002ggllENCE PDR kbhRESPOND
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QUESTION 1A.
Please provide a list or all active processing sites that would be eligible for cleanup under the provisions of H.R. 2236 or S. 1004, and a list of the appropriate licensees.
B.
Which of these sites are licensed by the Commission? Which are licensed by NRC agreement states?
C.
What is the current status of NRC issued licenses and agreement state issued licenses at these sites?
ANSWER.
Information requested under parts A, B and C of Question I regarding current uranium milling licensees is summarized in the following table. Detailed information on these subjects is in Attachment A to these questions.
(This information was provided by NRC to representatives of the General Accounting Office during a meeting held on June 27,1985.)
TABLE 1 CURRENT STATUS OF LICENSED URANIUM MILLS C0* NM* SD TX* UT WA* WY TOTAL OPERATING MILLS, NO LICENSEE ANN 0UNCED SHUTDOWN PLANS 2
2 OPERATING MILLS, LICENSEE ANNOUNCED SHUTDOWN PLANNED 1
1 MILLS SHUTDOWN, LICENSEE ANNOUNCED RESTART PLANS 1
1 1
3 MILLS SHUTDOWN, RESTART UNCERTAIN 1
5 1
3 2
4 16 MILLS SHUTDOWN, DECOMMISSIONING PLANNED OR UNDERWAY 1
2 2
5 TOTAL 2
5 1
3 4
3 9
27
- Agreement States
QUESTION 10.
What, if any, surety arrangements have been made with regard to licensees' cleanup of the tailings, and what other obligations do licensees have concerning these sites?
ANSWER.
Thirteen NRL '.; censed mills have surety arrangements in place. The fourteenth mill is the TVA Edgemont mill.
TVA is a Federal agency and as a matter of law and government policy is not required to have any financial assurance for its actions.
In virtually all situations these surety arrangements have been consolidated with state agency requirements. The types of arrangements in place are listed below:
Corporate Guarantee 5 mills (1 approved, 4 under review)
Letter of Credit 4 mills Surety Bond 2 mills Escrow Fund 1 mill Cash & Letter of Credit 1 mill With respect to Agreement State-licensed mills, all 13 mills have surety arrangements in place. The types of arrangements are listed below:
Corporate Guarantee 5 mills Letter of Credit 1 mill Surety Bond 6 mills Personal Bond 1 mill Of those NRC regulated mills proposing corporate guarantees, only 1 has been approved by NRC, and the remainder are under review at this time.
Site-specific detail is provided in Attachment A to these questions.
As far as other NRC requirements are concerned, NRC licensees are required to provide NRC with a preliminary decommissioning and reclamation plan. During the active life of milling operations, licensees are required to implement interim stabilization measures to control tailings, to conduct comprehensive environmental monitoring programs and, where warranted, to institute iemedial action programs to control ground-water contamination from tailings impoundments. Prior to undertaking decommissioning and reclamation, the licensee must submit a final decommissioning and reclamation plan for NRC review and approval in the form of a license amendment.
In addition to NRC requirements, licensees incur additional obligations as a result of state requirements for disturbed land reclamation, maintenance of ground-water resources, etc. Similar obligations are binding upon Agreement State licensees.
c QUESTION 2.
In the event that a site is owned or licensed to a company's subsidiary, what are the liabilities of the parent company with regard to the subsidiary's activities?
ANSWER.
It is the normal practice of the NRC to hold the licensee reponsible for the full and complete performance of all regulatory requirements applicable to its activities. Occasionally a parent company will undertake to support the activities of a subsidiary for carrying out decommissioning and reclamation activities.
In these cases the obligation of the partent company is documented in a legally enforceable form and becomes a condition of the license of the subsidiary.
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QUESTION 3A.
S.1004 and H.R.2236 call for the transfer of processing site licenses to the Department of Energy. What would be the Commisssion's role in regulating a DOE site licensed to the DOE?
ANSWER.
From the wording of Question 3A and the bills, there is some question pertaining to NRC's role under these bills. However, the current NRC reading of the bills is that NRC would be given licensing authority over DOE for the active mill site following transfer to 00E. Assuming this is the intent, it would be useful to place in the bills an exemption for the Commission from the requirement of Section 184 of the Atomic Energy Act that the Commission give its written consent to the transfer after making a finding that the transfer is in accordance with the Act. The Commission's role in regulating a DOE site licensed to the DOE would be to insure that DOE implements the reclamation and decommissioning program to meet applicable regulations of the NRC and EPA, and maintaining the site in a safe manner thereafter. The Commission observes that it already has authority to license and regulate the activities of DOE as custodial agency of reclaimed and closed tailings disposal areas. This authority is granted in Section 104 of the Uranium Mill Tailings Radiation Control Act (UMTRCA) of 1978 as to Title I sites and in Sections 202 and 205 for Title II sites (see Sections 83b(5) and 84 of the Atomic Energy Act of 1954, as amended). The current bills would increase that authority with respect to the performance of reclamation by DOE at Title II sites by transferring the outstanding licenses to 00E.
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QUESTION 38.
What would be the implications of such a transfer in the event the site is licensed by an NRC agreement state?
ANSWER.
The transfer of an Agreement State license to DOE would result in a loss of licensing and regulatory jurisdiction by the Agreement State. Generally all Federal agency activities involving Atomic Energy Act materials (i.e., source, byproduct, and special nuclear material) are subject to regulation by the Nuclear Regulatory Commission (see 10 CFR 150.10). However, because DOE is not a person under the Atomic Energy Act with respect to its nuclear activities, the Atomic Energy Act activities of DOE are exempt from licensing and regulation except where another statute expressly subjects an activity to NRC licensing jurisdiction. Such statutes presently include the Energy Reorganization Act, Uranium Mill Tailings Radiation Control Act and the Nuclear Waste Policy Act. The present proposed legislation would extend NRC's jurisdiction as noted in the answer to Question 3A.
However, the legislation does not address how the Agreement State's authority would be terminated and NRC would assert its authority.
It is assumed in the absences of any specific statutory instruction to the contrary that the transfer of the license itself would effect the change in jurisdiction.
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QUESTION 3C.
How would the NRC make certain that sites are not poorly managed between the time that such legislation is passed and the time that licenses are transferred to the Department and/or the appropriate time to undertake reclamation activities?
ANSWER:
The NRC would continue to enforce the existing licenses.
The NRC would continue to ensure that the licensee comply with requirements of the license and regulations through its program of inspection and enforcement.
1
QUESTION 3D.
What effect, if any, does the NRC believe that Section 83c of the Atomic Energy Act will have in insuring that reclamation standards are ultimately complied with by licensees, assuming the site was regulated b additional legislation (y an agreement state and that nosuch as H.R. 2236 by Congress?
In the event the site is regulated by NRC?
ANSWER.
I Section 83c of the Atomic Energy Act requires the Commission to determine upon the termination of a license to which Section 83 applies that the licensee has complied with all applicable standards and requirements.
This determination applies to both Agreement State and NRC mill licensees.
Section 83a requires that licenses contain conditions to assure that the licensee will comply with reclamation standards prescribed by the Commission. Section 274o mandates that an Agreement State require compliance with standards that are equivalent to, to the extent practicable, or more stringent than Commission standards. Thus, Section 83c ought to insure that reclamation standards are met by both Agreement State and NRC licensees.
QUESTION 4 In determining the cost of mill tailings reclamation, what factors would account for variances in cost per cubic foot or cost per pound from site to site?
ANSWER.
The detennination of costs for reclaiming a particular impoundment are very site-specific. Examples of factors responsible for differences in unit cost of reclaiming tailings impoundments are as follows:
a.
Method of reclamation (i.e., stabilization in place or relocation of tails);
b.
Site characteristics affecting reclamation plans (i.e., extent of upstream drainage areas, proximity to natural water courses, severity of climatic conditions,etc.);and c.
Areal extent of tailings, which affects the volume of cover materials required and erosion protection.
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QUESTION 5.
What is the NRC's estimate of how long an industry-funded cleanup of mill tailings sites will take under the current legislative framework?
ANSWER.
The time required for reclamation of a particular tailings disposal site is estimated by NRC to range from 3 to 10 years, depending on characteristics of i
the tailings disposal system.
It is difficult to estimate the time in which an industry-funded cleanup of mill tailings sites under the current legislative framework would be completed because the Comission has no reliable 4
information on when individual mill reclamation efforts might begin.
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QUESTION 6A.
Is it the NRC's view that these active sites will be abandoned without legislation such as what is proposed by H.R. 2236 and S. 1004?
ANSWER.
Abandonment of active sites implies that the licensee is unable to reclaim and is willing to risk civil and criminal penalties under the Atomic Energy Act.
As the response to Question 1 indicates, NRC has taken steps to require that licensees provide financial assurance that decommissioning and reclamation will take place. However, there are uncertainties inherent in any financial assurance mechanism.
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QUESTI0fl68.
If sites are not cleaned up through any other mechanism, is it l
the NRC's view that reclamation can take place under the Superfund program?
ANSWER.
It is the NRC's understanding of the Superfund program that it may be used to prevent or clean up the effects of a release or threatened release of hazardous substances. Radioactive material is a hazardous material generally under Superfund. The only exclusions are uranium mill tailings sites being reclaimed under Title I of UMTRCA and releases from facilities covered by the program under Section 170 of the Atomic Energy Act (AEA) as amended (Price-Anderson).
Accordingly, in theory at least, Superfund is legally available to effect reclamation of uranium mill tailings sites not under the UMTRCA Title I program. Whether or not Superfund would be used for this purpose lies primarily in the discretion of the Environmental Protection Agency (EPA).
EPA has stated that, as a policy matter, it has chosen not to list on the National Priorty List (NPL) those facilities with a source, byproduct, or special nuclear material license issued by the NRC on the grounds that the NRC has full authority to require cleanup of releases from such facilities.
With respect to facilities licensed by a State having an agreement with NRC pursuant to 274b of the AEA, EPA has noted that although the licensing State may be able to ensure cleanup, EPA has decided to list such sites on the NPL to provide potential Federal authorities, if necessary.
Since listing on the NPL does not determine whether actual cleanup action will be taken, EPA will be able to defer to the licensing State whenever EPA determines that State efforts are adequate to address the problem (see 48 FR 40658, September 8,1983).
STATUS OF CONVENTIONAL URANIUM MILLS LICENSED BY NRC Date of Date of Date Mill Mill Initial Last License Operating Tailings Facility License No.
Issuance Renewal Expires Status
- Volumes ****
Parent Company l
American Nuclear SUA-667 1959 00/71 01/76**
IS(04/84) 5.9 (2.1/3.8)
American Nuclear Corp.
Atlas SUA-917 1956 04/79 06/84**
IS( 4/84) 10.2 (6.0/4.2)
Atlas Corp.
Bear Creek SUA-1310 1977 09/84 09/89 OP 4.0 Union Pacific Corp.
j Exxon SUA-1139 1972 12/81 12/86 DR(06/84) 8.0 Exxon Corp.
Minerals Explor.
SUA-1350 1979 02/79 05/84**
IS(11/81) 2.5 Union Oil Co.
]
Pathfinder SUA-672 1958 09/84
. 09/89 SS(04/85) 9.5(2.7/6.8)
Cogema (French' company) i (Gas Hills) j Pathfinder SUA-442 1971 09/84 09/90 OP 5.8 Cogena (French company) l (Shirley Basin)
{
Patrotonics SUA-551 1962 10/84 09/90 DR(05/85) 5.5 (0.7/4.8)_
Texaco (Getty Oil)
Plateau Resources SUA-1371 1979 09/79 12/84**
IS(08/82) 1.0 Consumers Power Co.
Rio Algon SUA-1119 1972 09/84 09/89 OP 2.0 Rio Algom Ltd. (Canada)
Silver King Mines SUA-1356 1979 09/84 09/89 NB Tennessee Valley Auth.
DR(04/83) 2.0(1.6/0.4)
Tennessee Valley Auth.
[
TVA (Edgemont)
SUA-816 04/83 j
Umetco (Gas Hills) SUA-648 1960 01/81 01/86 IS(11/84) 7.3 (2.1/5.2)
Union Carbide Corp.
j Umetco (EFN)
SUA-1358 1979 08/79 01/85**
IS 1.0 Union Carbide Corp.
niestern Nuclear SUA-56 1957 12/80 12/85 IS(06/81) 7.7 (3.4/4.3)
Phelps Dodge Corp.
IS - Indefinite Shutdown DR - Decommissioning Reclamation r
j OP - Operating NB - Never Buist i
SS - Short-term Shutdown Under timely renewal r
Licenseiseffectgveuntildecommissioningandreclamationiscompleted.
- Volumes are in 10 metric tons - Total (AEC/ Private) i.
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FINANCIAL ASSURANCE ARRANGEMENTS FOR HILLS LICENSED BY NRC NRC Review Actions Still Facility Type Amount *** Issued To Date Pu rpose* ***
Outstanding Atlas Minerals Self*
5,553,700 Utah 9/1984 Decommissioning NRC approved bond Moab, Utah Bond and Reclamation amounts only.
Bear Creek Self*
3,469,600 Wyoming 7/1984 Decommissioning NRC approved bond Uranium Co.
Bond (43,652,000) and Reclamation amounts only.
Ccnverse County, Wyoming Umetco Co rpo-4,235,830 NRC 12/1984 Decommissioning NRC approved for 1 yr.
Blanding, Utah rate Reclamation arJ only.
Guarantee and long term care Exxon Minerals Letter 10,900,000 Wyoming 11/1983 Decommissioning Reviewed annually Converse County, of (18,000,000) 2/1985 and Reclamation Wyoming Credit American Nuclear CD**
99,727 Wyoming Decommissioning Gas Hills, Wyoming LC 500,000 and Reclamation TB 3,481,688 Minerals Self*
3,500,000 Wyoming 6/1985 Decommissioning NRC approved bond Expluration Bond (23,763,000) and Reclamation amounts only.
Sweetwater County, Wyoming Pathfinder Mines Self*
21,725,200 Wyoming Reclaim mine, Gas Hills, Wyoming Bond Decommissioning and Reclamation Letter 7,393,850 NRC 12/1984 Decommissioning of Credit and Reclamation State has approved the self bond but still pending with NRC CD - Certificate of Deposit LC - Letter of Credit TB - Treasury Bill Amounts in parentheses are total financial surety amounts. Amount estimates do not include the time value of money.
- All of the financial arrangments exclude ground-water restoration.
1 FINANCIAL ASSURANCE ARRANGEMENTS FOR MILLS LICENSED BY NRC (cont'd)
NRC Review Actions Still Facility TZ2e Amount *** Issued To Date Purpose ****
Outstanding Pathfinder Mines Self*
52,000,000 Wyoming Decommissioning Shirley Basin, Bond and Reclamation Wyoming (including the mine)
Letter 5,518,300 NRC 12/1984 Decommissioning of Credit and Reclamation Petrotomics Co.
Self*
1,928,859 Myoming 2/1982 Decommissioning Shirley ?asin, Bond (51,980,157) and Reclamation Wyoming Plateau Resources Letter 1,827,601 NRC 1/1985 Tailings reclamation Completed Shootaring Canyon, of and mill decommissioning Utah Credit Rio Algom Escrow 535,874 Utah 1/1982 Mine, mill and La Sal, Utah account tailings decommission-ing Silver King Mines No bond in effect due to no facilities being built.
Converse County, Wyoming Tennessee Valley None. Government agency - TVA has committed to decommissioning and reclamation. They are Authority currently decommissioning the mill.
- Edgemont, South Dakota Umetco Surety 5,929,000 1983 Decommissioning Gas Hills, Wyoming Bond (10,239,500)
Reclamation Western Nuclear Surety (10,586,000) Wyoming 6/1982 Decommissioning Inc.
Bond 19,244,975) and Reclamation Jeffrey City, Ryoming
STATUS OF CONVENTIONAL URANIUM MILLS LICENSED BY STATE OF COLORADO Date of Date of Date Mill Mill Initial Last License Operating Tailings Frcility License No.
Issuance Renewal Expires Status
- Volumes ***
Parent Company C0-369-01S 1958 08/79 08/84**
IS(02/85) 2.5(0.3/2.2)
Commonwealth Edison CstterCorp).
(Canon City Umetco Minerals SUA-673 1948 06/70 06/75**
IS(11/83) 10.5(5.7/4.8)
Union Carbide Corp.
(Uravan Mill)
-IS - Indefinite Shutdown Under timely renegal
- Volumes are in 10 metric tons - Total (AEC/ Private)
FINANCIAL ASSURANCE ARRANGEMENTS FOR MILLS-LICENSED BY STATE OF COLORADO Review Actions Still Facility Type Amount
- Issued To Date Purpose **
Outstanding Cotter Corp.
Perfor-10,500,000 -State 8/1979 Reclamation, Completed-(Canon City) mance Bond Decommissioning, and long-term Security 68,000' State care Assessment Money 329,383 State Escrow Umetco Minerals Finan-31,686,000 State 9/1981~
Reclamation.
(Uravan Mill) cial and decommissioning-Assurance Test Amount estimates do not include the time value of money.
All the financial arrangements exclude ground-water restoration.
STATUS OF CONVENTIONAL URANIUM MILLS LICENSED BY STATE OF NEW MEXICO Date of Date of Date Mill Mill Initial Last License Operating Tailings Facility License No.
Issuance Renewal Expires Status
- Volumes ***
Parent Company Anaconda SUA-647 1959 1971 1976**
1S(00/83) 24.0(8.8/15.8) Atlantic Richfield (Bluewater)
Homestake Mining SUA-708 1958 1971 1976**
1S(03/85) 22.0(11.4/10.6) Homestake Mining Co.
K nnecott Minerals NM-50H-ML-1R-03 1974 1982 1987 IS(00/82) 3.3 SOHIO Reserve (L-Bar)
SUA-616 1958 1971 1976**
IS(02/85) 33.0(10./23.0)
Kerr McGee Corp.
Quivira Mining)
(Ambrosia Lake Bokum Resoures NB B:kum Resources NM-BRC-ML-00 1981 Corp. (Marquez) 1982**
IS(08/79) 3.6 United Nuclear Corp.
United Nuclear NM-UNC-ML-18 1977 Corp.
(Church Rock)
Gulf Minerals NB Gulf Minerals NM-GUL-ML-00 1981 IS - Indefinite Shutdown NB - Never Built Under timely renegal
- Volumes are in 10 metric tons - Total (AEC/ Private) i
FINANCIAL ASSURANCE ARRANGEMENTS FOR MILLS LICENSED BY STATE OF NEW MEXICO Review Actions Still
])r )t Amount
- Issued To Date Purpose **
Outstanding Facility jj Anaconda Bond 8,625,000 State 1/1982 Reclamation-(Bluewater)
Escrow 1,000,000 State Long term care Homestake Mining Finan-4,252,750 State 4/1982 Reclamation cial Test Escrow 1,000,000 State Long term care Kennecott Bond 10,950,000 State 7/1983 Reclamation Completed Minerals (L-Bar)
Escrow 246,390 State Long terra care Quivira Finan-8,200,000 State 1/1982 Reclamation (Ambrosia Lake) cial Test Escrow 1,000,000 State Long term care Bokum Resources NONE (mill was never operated)
In order to operate, Corp. (Marquez) they will have to j
obtain a surety.
United Nuclear Finan-2,500,000 State 1/1982 Reclamation Corp.
cial Test (Church Rock)
Escrow 703,797 State Long term care Gulf Minerals NONE (mill was never built)
Amount estimates do not include the time value of money.
All of the financial arrangments exclude ground-water restoration.
STATUS OF CONVENTIONAL URANIUM MILLS LICENSED 8Y STATE OF TEXAS Date of Date of Date Mill Mill Initial Last License Operating Tailings Facility License No.
Issuance Renewal Expires Status
- Volumes ***
Parent Company NB Atlantic Richfield Anaconda Minerals 8-3304 1982 (Rhode Ranch) 09/80**
IS(06/86) 4.2 Standard Oil of Cal.
Chevron Resources 9-2402 1977 (Panna Maria Mill)
Conoco-Pioneer 9-1634 19/1 05/78 09/80**
DR(00/83) 8.7 Dupont Nuclear (Conquista Mill)
Exxon Minerals Co.
8-1431 1970 09/73 09/82**
DR(00/80) 0.5 Exxon Corp.
(Exxon Felder)
OP - Operating o
i NB - Never Built IS - Indefinite Shutdown DR - Decommissioning Reclamation Under timely renegal o*
o** Volumes are in 10 metric tons.
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s FINANCIAL ASSURANCE ARRANGEMENTS FOR MILLS LICENSED BY STATE OF TEXAS Review Actions Still Facility-Type Amount *
-Issued To Date Purpose **
Outstanding Anaconda Minerals Under Negotiation (Rhode Ranch)
Chevron Corporate 3,289,900 State 4/1982 Reclamation and Currently requesting R: sources Guarantee (BRH) perpetual care updates.
(Panna Maria Mill)
Conoco, Inc.
Perform-8,050,000 State 7/1982 Reclamation and Currently requesting (Conquista Mill) ance (BRH) perpetual care updates.
Bond Exxon Minerals Corporate 3,000,000 State 4/1982 Reclamation and Currently requesting (Exxon Felder)
Guarantee (BRH) perpetual care updates.
Amount estimates do not include the time value of money.
All of the financial arrangments exclude ground-water restoration.
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STATUS OF CONVENTIONAL URANIUM MILLS LICENSED BY STATE OF WASHINGTON Date of Date of Date Mill Mill Initial Last License Operating Tailings Facility License No.
Issuance Renewal Expires Status
- Volumes ***
Parent Company Dawn Mining WN-1043-2 1957 07/74 07/79**
IS(12/83) 2.9 (1.1/1.8)
Newmont Mining Corp.
(Ford Mill)
Midnight Mines, Inc.
06/85 LS(06/85) 0.003 Joy Mining Co.
Joy Mining Co.
WN-10220-1 1983 04/80**
IS(07/84) 2.3 Phelps Dodge Corp.
Western Nuclear, WN-10133-1 1978 Inc. (Sherwood) o IS - Indefinite Shutdown LS - License Suspended Under timely renegal C*
o** Volumes are in 10 metric tons _ Total (AEC/Frivate)
FINANCIAL ASSURANCE ARRANGEMENTS FOR MILLS LICENSED BY STATE OF WASHINGTON Review Actions Still Facility Type Amount *
' Issued To Date Purpose **
Outstanding Dawn Mining Co.
Letter 1,000,000 State 11/5/82 Decommissioning Surety on an interim (Ford Mill) of (D.S.H.S.)
and Reclamation basis for tailing Credit (1,500,000) under review impoundment 4.
To be reevaluated at time of renewal to cover canmercial tailings pond 3 and 4.
Joy Mining Co.
Perfor-93,000 State 8/24/83 Mill decommis-State is in the process (Flodelle Creek mance (D.S.H.S.)
sioning return of of terminating the Project)
Bond tailings to mine license due to licensee site failure to pay licensing and inspection fees.
25,000 State 8/24/83 Reclamation of (D.N.R.)
of other mine areas Western Nuclear, Perfor-6,000,000 Bureau of 4/24/78 Reclamation Surety is tied into Inc. (Sherwood) mance Indian Affairs lease of the Indian Bond (U.S.D.0.I.)
lands.
Amount estimates do not include the time value of money.
All of the financial arrangments exclude ground-water restoration.
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