ML20126A089

Forwards Review Notes of State of Co Dept of Health, Radiation Control Div,Program Review Conducted 910401-10

ML20126A089
Person / Time
Issue date:	04/12/1991
From:	Konwinski G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Doda R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20126A074	List: IA-92-233, Forwards June 1991 Rev to Background Statement on NRC Agreement State Program ML20126A070 ML20126A086 ML20126A089 ML20126A096
References
FOIA-92-233 NUDOCS 9212170226
Download: ML20126A089 (21)

Text

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.g uNTTED STATES e k NUCLEAR REGULATORY COMMISSl3N f nEoioN IV URANIUM RECOV FIELD OmCE

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• p-DENVER. COLORADO SERIE APR 121991 URFO:GRX SIS 6 MEMORANDUM FOR: Robert J. Doda, State Agreement Program Officer Region IV FRON: Gary R. Konwinski, Project Manager Uranium Recovery Field Office, Region IV

SUBJECT:

REVIEW NOTES OF COLORADO DEPARTMENT OF HEALTH, RADIATION CONTROL DIVISION, PROGRAM REVIEW, CONDUCTED APRIL 1 TO 6, AND APRIL 10, 1991

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Attached for your use are my review notes from the program review conducted at the Colorado Department of Health, Radiation Control Division. I hope these are useful in preparing your report.

I feel that an adequate regulatory framework exists to implement appropriate ground-water programs at the Colorado sites. As the review indicates, draft letters have been prepared to inform the licensees of the need for ground-water programs in consideration of Part 18. An interim program review specific to ground water, during the fall of 1991, may be useful. Such a review would verify that the programs are considering necessary elements, as well as meeting regulatory objectives.

The site visits to the Cotter and Uravan sites were extremely helpful in understanding the degree of Part 18 compliance that currently exists. I would suggest that if the fall ground-water review can be scheduled, that site visits to the two heap leach sites also be conducted.

I look forward to once again participating in the State of Texas review or other States where my expertise is of value. Should you have any questions concerning my review and associated notes, please feel free to contact me.

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4 Gary . Konw nski Proje t Manager

Attachment:

As stated l

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' 92121*/0226 920105 PDR FOIA

! DAVIS92-233 PDR 7g

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a TABLE OF CONTENTS 4

P,.agg Materials Reviewed............................................... 1 Previous Review (April 4 to 6, 1989) Findings / Recommendations.... 2 a

Rules and Regulations Pertaining to Radiation Control............ 3 i

! Policy for Detection Monitoring Programs at Urantun, Thorfue, and Related Mill 51tes.......................................... 4

Colorado Department of Health Draft Letters...................... 5 Cetter Corporatien, Canon City Mill, Site Visit.................. 6 Uravan Mill Site Visit........................................... 7

Summary.......................................................... 8 i

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i Program April 1 to review 5, and of Colorado April Department of Health, Radiation Control Division, 10, 1991. Review included applicable ground-water protection programs, licensing issues, and policy guidance on file with the Radiation Control Division.

Recovery Field Office, Denver, Colorado. Review performed by Gary Konwinski, Urani Materials Reviewed:

1.

Policy mill for Detection sites, Monitoring Programs at uranium, thorium, and related dated March 25, 1991.

2.

Part 18, Appendix A, criteria relating to the operation of mills and the disposition of radioactive tailings or wastes.

3. Colorado Department of Health draft letters to:

Hecla Mining Company Cotter Corporation

• Umetco Minerals Corporation Maybell Umetco Minerals Corporation, Uravan 4.

Colorado

• Department of Health Interoffice Communicationi"'

Preliminary facility review of Umetco's Haybell site for Part 18,

• Ground-Water Monitoring Requirements.

Implementation of Part 18, Ground-water Regulations at the Uravan site.

Preliminary facility review of Cotter's Canon City site for Part 18, Ground-Water Monitoring Requirements.

5.

Conceptual Reclamation Plan Durita Site, December 1990.

6.

Site visit on April 3,1991, to Cotter Corporation, Canon City Mill.

7.

Site visit on April 10, 1991, to Umetco's Uravan Mill.

8.

Guidance for Construction of Ground-Water Monitoring Wells by Water Quality Division, Ground Water Unit, July 1987.

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i j Previous Review (April 4 to 6,1989) Findings / Recommendations:

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4 Colorado Department of Health must be certain that appropriate hazardous constituents are monitored. They must meet the following:

j - The constituent is reasonably expected to be in or derived from the

byproduct material.

- The constituent is detected in the uppermost aquifer.

! - The constituent is in Criterion 13 list of hazardous constituents.

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For compliance with 40 CFR 192 or 10 CFR Appendix A or the Colorado 4

Department of Health ground-water regulations to be' appropriate, compliance points need to be established in the uppersost aquifer at the downgradient edge of the disposal area.

1 i For the NRC to concur on a closure plan, from a ground-water viewpoint, i'

compliance with appropriate ground-water protection standards must be shown. These standards are one of the following: background, the i drinking water standard as published in Appendix VIII (EPA), or an l

' alternate concentration limit. Remediating the ground water for a predetermined number of years cannot be~ considered as s'cks'ure sta'ridard] "

• l regardless of commitments made in the consent-decrees.

The agricultural standards that have beari agreed to as concentration i

limits which will allow termination of ground-water remediation may indeed represent appropriate limits; however, an alternate concentration limit proposal needs to be submitted by the licensee and reviewed by the j Department, as outlined in the draft NRC guidance dated June 1988.

! At sites where leakage is suspected or known to exist, but indicator

! parameters are not elevated, the Department should establish ground-water -

! protection standards for those hazardous constituents reaf 9nably expected i

to be in or derived from the byproduct material and related processing.

This may be the case at the Maybell site.  ;

1 Although several specific findings / recommendations were made on the Cotter l

Corporation and Uravan Consent Decrees, the general program components are l

' discussed in the comments.noted above. Following the program review, a  !

September 21,'1989, meeting was held in NRC, Region IV office that discussed l State Program Review findings. Major points that were discussed included the  !

need to close sites in consideration of ground-water standards, corrective action programs, and utilization of the ALARA concept. In addition, URF0 offered technical assistance to the Health Department to aid in implementation of the regulations.

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Rules and Regulations Pertaining to Radiation Control:

Part 18, Appendix A, criteria relating to the operation of allis and the disposition of radioactive tailings or wastes, represents the Colorado Department of Health, Radiation Control Division (CDH/ RCD) conforming  !

regulations relative to 10 CFR 40, Appendix A. Part 18, Appendix A, is dated December 30, 1990. It is basically a duplication of 10 CFR 40. Appendix A.

Because the regulations are in effect, there now is a _18-month deadline to implement fully operational corrective action programs at those sites which have levels of hazardous constituents elevated above background at the points  !

of compliance. This. situation will certainly apply to the Uravan and Cotter l 4 sites. Sufficient information is not available to make a similar finding at l l the Maybell and Durita heap leach sites.  :

Part 18, Appendix A, was reviewed briefly relative to major program components detection and compliance monitoring programs, hazardous constituents, concentration limits, and so on. All criteria were in order. It was noted ,

that the maximum concentration of 0.1 mg/l for Methoxychlor (1,1,1 -

Trichloro - 2, 2 - bis, p-methoxyphenylethane) was deleted from Criterion SC.

This probably represents a compilation oversight. Because this hazardous j

constituent.is not known to be present in or derived from tailings ~ solutions,' a revision is not an immediate need.

Tne remainder of Appendix A appears to have incorporated all relevant portions from 10 CFR 40, Appendix A. These regulations will supply sufficient guidance to the licensees to allow implementation of appropriate ground-water programs.

Similarly, the regulations clearly give the State authority to implement

! ground-water management programs that are compatible with those in effect at NRC licensed facilities.

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1 Policy for Detection Monitoring Procrams at Uranium, Thorium, and Related Mill -

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The CDH/ RCD has prepared a guidance document to aid licensees in preparing ground-water monitoring and corrective action programs at uranium, thorium, and related mill sites. The guidance in this paper discusses eight. elements that

are designed to aid the licensee in submitting an acceptable ground water

, program.

1 Element I discusses hazardous constituents that the NRC has identified to be

, present in mill tailings impoundments as well as " basic constituents,"

representing common anions and. cations that should be monitored. Additionally, a

more mobile hazardous constituents are discussed as indicator species.

Appropriate discussions of detection monitoring and compliance monitoring j programs are included.

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More complete guidance could be supplied to the licensees if CDH/ RCD noted the mobility of nickle and identified it as an indicator species. Similarly, the guidance may rely too much on hazardous constituent data collected by the NRC.

The licensee should be directed to review process additives.and, ore j composition. This would allow them to~make a statement that'the'"other" i 350 hazardous constituents, listed in Criterion 10, are not present in the

! byproduct material solution.

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Elements 2, 3, and 4, discussing the point of compliance, background determination, and well construction, respectively, supply useful guidance to the licensees. A similar situation exists for elements 6 and 8, discussing 1,

sampling frequency and statistical significance, respectively. All eight of the elements demonstrate an adequate flexibility to resolve the-issues. There could be more guidance given in elements 5 and 7, discussing lower limits of

' detection and ground water flow reporting, respectively, i

Lower limits of detection (LLD) that are 10 percent of the Criterion SC values

are adequate. This could be stated in the guidance. Similarly, a list of LLDs i

for constituents identified in element I would aid in establishing a credible.

! program (see February 25,1991, interoffice communication,-Gregory Brand to Ken Weaver). The State has compiled LLDs that their. laboratory can achieve.

Appropriate sections of this information should be incorporated into the guidance documents.

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! The ground water flow discussion noted in element.7 should be expanded to

include seepage collection rates as well as the mass of hazardous constituents that have been recovered as a result of the corrective action program. . This 1 - data will be necessary to demonstrate the amount of hazardous constituents that

, have been isolated, for the long-tera.. in the disposal area. This overall-discussion will be needed to support an ALARA determination. Similarly, the

' NRC is-implementing a " stability" monitoring period to verify corrective action program results. This concept should be- forwarded to the-licensees in the guidance document.

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i. 5 Colorado Department of Health Draft Letters The CDH/ RCD has prepared four draft letters which they are about to issue to the licensees that are required to implement ground-water programs under Part 18 of Rules and Regulations Pertaining to Radiation Control. Each of the letters is specific to the site and discusses criteria that is in need of attention in order to comply with Part 18.

Each of the letters will include '

the " Policy Mill Sites." for Detection Monitoring Programs at Uranium, Thorium, and Related Each of these letters is an abbreviated compilation of an interoffice preliminary facility review of the sites' ground water programs. It appears that each site has been given an adequate review with the COH/ RCD utilizing a temporary employee in this capacity.

letter; however, other issues may needRelevant issues are raised in each to be discusscd.

The current issues that are discussed involve detection and compliance monitoring.

Each letter, by design, does not discuss the need for corrective action or ALARA considerations. Adequate data exists to verify that hazardous constituents at the Cotter and Uravan sites have exceeded back 0 round _ __, , 4; concentrations of hazardous constituents. At' these' sites', it may be '

appropriate to inform the licensees that corrective action programs meeting the definition in Criterion SD of Part 18, are needed within 18 months of the effective date of the regulations, which is December 1990. There is no ability to be flexible on the 18 month deadline. Due to this, the State should require the implementation of corrective action programs at the earliest possible date.

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6 Cotter Corporation. Canon City Mill. Site Visit The visit to the Cotter site indicated that as discussed in the Consent Decree, a ground-water remediation program was being implemented. The program involves recovery of ground water, partial treatment, and discharge to synthetically lined ponds in the area between the SCS das and the old tailings site. This area, which has a series of remedial action components, recovers water at roughly 25 gallons per minute. This recovery meets the definition of a corrective action program, but needs to have its components described:

background and point of compliance wells,' rate and direction of ground-water flow, and define appropriate hazardous constituent concentrations, as well as implement a corrective action monitoring program.

The " dam to ditch" flush system could not be considered a corrective action program under Part 18, Criterion 50. The dam to ditch system is designed to dilute the concentrations of molybdenum and uranium with the addition of clean water. Due to this, it does not remove or treat in place the hazardous constituents. For this system to be consistent with Part 18, some form of hazardous constituent treatment such as seepage collection is necessary. The seepcge could then be returned to the lined evaporation ponds where the hazardous constituents would be concentrated by way of solution ~10ss'to the '

atmosphere.

Site closure must demonstrate that levels of hazardous constituents have been reduced to levels t!.at are as low-as reasonably achievable (ALARA).- The mechanism and monitoring are minimally in place to demonstrate ALARA between the dam and the old tailings site. However, this is not the case in the dam to ditch flush system. Additional monitoring points as well as data on the amounts of hazardous constituents that are being recovered must be collected to verify the success or failure of the program.

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Umeteo Minerals Corporation, Uravan Mill Site Visit The Umetco site has numerous remediation features that are required by the

consent decree. During the site visit, five areas were reviewed to determine if the remedial actions at these areas meet the requirements of Appendix A to Part 18.

g The ground-water remediation that is taking place at the Umetco site is removing hazardous constituents from the ground water. The recovered ground water and the constituents it contains are pumped to the Club Ranch pond numbers 7 and 8. These are synthetically-lined ponds which have been recently

, completed. They receive recovered ground water from the toe drains, mill area runoff, and hillside seepage.

Club Ranch ponds 1 through 6 are in the process of being constructed. These ponds will be utilized to evaporate recovered ground water from the river alluvium area. Currently, this water has a total dissolved solids i

' concentration in excess of 200,000 ppm. The remedial action plan has defined the cleanup period to end when agricultural water standards are reached or if no change. takes place in the ground water or pumping for's prsdetermine~d" number"" "'

of years. These termination criteria are not consistent with Part 18, and as such could not be utilized to support site closure.

The river ponds, Atkinson Creek crystal area, and the Burbank Pit were also visited. Both the river ponds and the Atkinson Creek crystal area have either had the byproduct materials removed or are in the process of having this done.

Sufficient data on soil radium concentrations needs to be collected and documented to allow unrestricted release of these areas. Currently, such data

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is not available for these areas. Furthermore, the documented radium-226 soil concentrations in the river ponds as well as in the Club Ranch ponds area exceed Part 18 stendards. These areas could not be released for unrestricted l use without further byproduct material remnval and verification that "5/15" standard has been achieved.

l The Burbank Pit area as well as the byproduct material disposal- areas, and i former crystal areas need to have background and point of compliance wells

established. Following this, hazardous constituent data needs to be gathered l to support the establishment of ground-water protection standards. Existing l consent decree agreements of pumping for a predetermined number of years or meeting agricultural standards are not compatible with Part 18 requirements.

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Summary

1 The CDH/ RCD issued the Rules and Regulations Pertaining to Radiation Control as of December 30, 1990.- These regulations, specifically Part 18, clearly give i

the State the authority to establish points of compliance, require corrective action programs, and implement various monitoring programs. In consideration of this, the following are recommendations:

3 Issue the currently prepared-draft letters, in final form, to the two 4

conventional mills and two heap leaches requirin detection and/or compliance monitoring programs.g implementation.of

• ' a-Inform Cotter Corporation and Umetco Minerals that a fully-operational i corrective action program is required within 18 months of either

December 30, 1990, the date of the regulations or the date of the final j letter.

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• It should be clearly stated that f.he court-ordered remedial action may or '

may not be acceptable as a Part 18 corrective action program.

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Inform each licensee that data collection onithe' mass"eif ^reativTdTndo -

isolated hazardous constituents is essential to defend an ALARA j determination.

l Inform Umetco Minerals Corporation that byproduct material areas must be cleaned up to the Part 18 radium standard if they are to be released for j unrestricted use.

Other COH/ RCD guidance in the form of " Policy for Detection Monitoring Programs at Uranium, Thorium, and Related Mill Sites" and " Guidance:for Construction of l-Ground-Water Monitoring Wells" indicate the State's efforts to explain the program to the licensee as well as guide its implementation. There are several recommendations relative to this and related guidance:

l Lower limits of detection for all hazardous constituents likely to be found in tailings solutions should be included in the policy, i

A data collection technique discussing the mass and volume of_ recovered hazardous constituants should be stressed. This will aid future closure l plans related to the ALARA concept.

A similar document should be prepared that discusses corrective action program objectives.

i Although CDH/ RCD has adopted rules and implemented guidance, no detection or compliance monitoring programs that meet Part 18 requirements currently exist.

Similarly,_no approved corrective action programs exist. The draft letters that were reviewed indicate that the State is prepared to issue; letters L

requiring the~ licensees to implement the appropriate programs. 'The licensee's l responses must be critically reviewed to determine if they meet the intent of Part 18.

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APPENDIX F e

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i 8 April 1, 1991

$ URANIUM AND SPECIAL PROJECTS UNIT 4

Short-Form Name License Lono-Form Name 5

Arvada North Table Mountain Plant Arvada WTP ARV-00 CNES Ra 770-01 Chem-Nuclear Radium Transfer Site i CDH OJ 000-03 CDH Grand Junction Inactive Site l

1 CDR Gunnison 000-ON CDM Gunnison Inactive Site CDH Rifle 000-04 CDM Rifle Inactive Site CSMRI 617-01 Co School of Mines Cotter CC 369-01 Cotter Canon City Mill cotter WW 369-02 Cotter Whitewater Buying Station .

Cotter SW 369-03 Cotter Schwartzwalder ore Sorter n . ~ ++,,, -,..

i Cyprus Ra 565-01 . Cyprus Radium Site Cyprus Nat 319-02 Cyprus Naturita Inactive Site Cyprus New 565-03 Cyprus Newmire Site

. Den Ra OUs 000-RA Denver Radium Site Residuals DWD WTP DEN-00 Denver Water Department Foothills Plant Hecla Durango 317-03 Hecla Durango Inactive Site Facia Naturita 317-02 Hecla Naturita Site Homestake Pitch 150-01 Homestake Pitch Radium Removal.

Molycorp 500-03 Molycorp Louviers Rare Earth Plant

[ PSC D&D 32-DD PSC FSV Decommissioning PSC ISFSI 32-$F PSC FSV Spent Fuel Storage f SM Quarry SMQ-00 Sheep Mountain Quarry Shumway GJ 293-01 Sand Extraction GJ Inactive Site Sweeney 149-01 Sweeney ore Sorter Tusco TUS-00 Tusco Boulder Inactive Site Umeteo Uravan 660-02 Umetco Uravan Mill Umeteo Maybell Heaps 660-01 Umetco Maybell Leach Heap Sito Umeteo Maybell old 660-05 Umeteo Maybe11 Inactive Sito Umstco SR 660-04 Umetco Slick Rock Inactive Site Umatco EBS 660-06 Umeteo Uravan East Bench Site e

, ' r e s ca - kd -

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i i FAA DATA $REET 03-31-91 LLear.ma

Licensees cetter corporation site: Whitewater, ore sorter & ore suying station I License No 369-02 Expiration June 30, 1991 4 status: Not-operating j Dtn

' Current 5 Amount: $771,266.00

ype

sond, ces1000145ss sea, Aetna casualty & surety cc pany Istablished September 8, 1978

criginal $ Amount

$250,000 Renewal Dates Increased November 12, 1990 Expiration Dates automatic renewal

Location: state Treasurer's office McD Reviews .s/90 review requested increase to 171,246: red 11/12/90 LTc current $ Amount: None required I original $ Amount:

Established:

Carrent Renewal Expiration Oate:

Location:

i RCD Reviews d

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FAA DATA SSERT i 03-31-91 i

- *iconse Licensees Cotter Corporation sites Schwartswalder, Cro Sorter and Water Treatment Plant License No 349-03 Expiration December 31, 1987; under renewal statues Not-operating i

j con 4

Current $ Amount $1,384,199 j Type: Ferformance Scad

, totablished: increased October 22, 1990; criginal ir, place :ece 'cer *,

1982

. Original $ A ount: $663.879 Renewal Date --

- Ixpiration Dates Locations,. a State Treasury y. - . s _ 3 s g, ._ ,_, s ,

RCD Reviews 8/90 review request incresse to $1,384,199; red 10/22/90

ic Carrent 5 A cunt

None needed

Criginal $ Amount j Tend Oypes i Istablished

, Current Renewals Expiration Dates

. Locations l RCD Review 4

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0 FAA DATA SMEET 03-31-91

' License Licensee Hecla Mining Company site: Durite, Uranium heap leach License No: 317-02 Expiration 1940, under renewal

statues shutdown-awaiting reclamation DDR .__

1 i Current 5 Amount: 5120,454 "ypes 2 Forformance Bonde, 815100465141 and 2 BCA; , etna ::asualty

& surety Established

March 10, 1988

! Criginal $ Amount $120,454 I Renewai Cates --

Expiration Date

Locations.- , ' ^ .* state Treasurer's office .

RC Reviews ~Bondcurrently' inadequate,awaidink# revision" Eia 'reneOal"' *" '

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Current S Amount: 5105,000 1 , original 5 Amount 5105,000 2 bonds: Cuquesne Power and

• ight Company and El Paso Twnd Types Electric company Istablished: 8/78 l Current Renewal --

( Expiratien Date:

l Location: State Treasurst's office i RCD Reviews Revision pending renewal; currently inadequate l

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l FAA DATA SHEET 03-31-91 i Licensees Monestake Mining Company site: Sargents Fitch Hine Radium Treatment Plant 4 License No 150-01 Expiration: June 30, 1994 Status Operating (Mine shut down)

DDR Current 5 Amount $249,009 (current reclamation eatin. ate at $155,000)

Types $2,263,000 letter of credit held by MLRD and USTS, #122375 Bank of A:terica Istablished: April 27, 1989 (revision) origiaal $ Amount $249,C09

Renewal Dates Automatic renewal Expiration cases none Locations . state, Treasurer's office _ .

., ,, _,, , w., , ,<

d RCD Reviews August 22, 1990s acceptable, no change needed

'TC current 5 A:nount: None needed i original S Amount:

Funds Istablished:

Current Renewais Expiration Dates Locations

! RCD Reviews i

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I FAA DATA SREET 03-31-91 tieanse Licensee: sweeney Mining and Hilling company site Marion millaite (thoriurn bearing tailings)

License No 149-01 Expiration December 31, 1992 j Status Interies stabilisation DDR current 8 Amount: 575 i

Type: Cash Account

! Established: March 28, 1988 i

Criginal $ M ount $ to accrue to $$8,790

, Renewal Dates None Expiration Dates None Location State Treasurer's office RCD Reviews 1990 ,.

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Current 5 Mount 0 i

original S Arnount: To accrue to 19,000

, Types cash Established: March 28, 1988 current Renewal: -- ,

i Expiration Dates

Location State Treasurer's i RCD Review

1990 i

NOTEst cash account to accumulate with precious metale processing l

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9 FAA DATA SERET 03-31-91 Licenne Licensee Umeteo Minerals Corporation site Uravan Uranium Mill I License No 660-02

Expiration 12/31/91 Status: In cleanup and reclamation nos t

Current 5 Amount $12,4ss,900(sond) +s17,323,541.61 (Construction rund) =

, $29,812,441.61 ype: letter of credit, #50018743; Texas corr.T.orce Bank + Court j (RAP) ordered construction fund Istablished: April 6, 1989 Criginal S Mount: 523,692,000 Renewal Date: April 10, 1990, revised annually for next year's work l Expiration cates Automatic renewal- ,.

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I Location: State Treasurer's office

• 4 RCD Reviews CSC & AG via RAP, RCD staff

• e Current $ Mount

  $494,000 Criginal $ Amounts --

Fund Types cash in construction fund Istablished: July 30, 1991 Current Renewal --

Expiration Date --

Locations --

RCD Reviews --

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I FAA DATA $5EET 3 03-31-91 tieanse Licensee Umeteo Minerals corporation site Maybe11, Uranium Heap Leach License No 460-01 l Expiration: 1981, under timely renewal status shut down; reclamation begun ..

p_en current 5 Amount 52,184,407 ,

l Type Letter of credit, #1-006298, Texas commerce Bank Established: 1975

' Original $ Amount: $1,360,000 Renewal Cate: May 31, 1992 Ixpiration Dates Automatic renewal Locations state Treasurer's office RCD Reviews currently ongoing via 11conee renewal, inflationary upgrade i

to 2,184,407. red 10-31-90 l

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' current 5 Amount: $459,200 original S Amount $459,200 Types Letter of credit, #1-006299; Texas commerce Bank

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Istablished: Undated current Renewal May 31, 1992 Expiration Dates May 31, 1992 Locations state Treasurer's office RCD Review In progress I

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MHR-20-01 WED 1G144 P.09 FAA DATA SIEET l 03-31-91 l i

license i

Licensee: Union 74 - Holycorp sites Louviere, rare-earth Plant License No 500-03 Expiration: February 24, 1993 i status: Operational DDR l Current 5 Amount: $628,000 Type Performance Bond, #U629405, with standby truet agreement 3

Established: July 10, 1989 i original s Amount: $628,000 Renewal Dates automatic

! Ixpiration Dates None Location: State Treasurer's office RCD Review Holycorp 2/31/91 letter 'consite to' revised' cost estimate'by i 03-31-91

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Current S Amount None required i original 5 Amount Tund Types Established i Current Renewal:

Expiration Date Lecations

, RCO Reviews J

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l FAA DATA SEEET 03-31-91 License Licensee Cotter Corporation site Canon City, Uranium Mill License No: 369-01 Expiration: August,1984 - under timely renewal Status: Uranium-bearing water reefcle operating only DDR Current $ Amount: $10,$00,000 Type Forformance Bond, 088 100052143 SCAR Aetna casusity & surety Estaelished: october 2, 1984 Original 5 Amount: 510,000,000 Renewal Dates automatic Expiration Date:

Locations state Treasurer's office RCO Reviews Letter of February 15, 1991 auggeste increase to

$18,843,855, until renewal agreement Note additional security of court and enforced RAP and independent surety for various cleanup activities i?C Ourrent 5 Amount: $220,000 criginal 5 Amount: $278,000 Fund Type: Cash ($210,000): yellowcake tvalue estimated at $10,000 Estaclished: August 21, 1979 Current Renewal --

Expiration Dates Location: State Treasurer's office (cash); canon city mill (YC)

ACO Reviews to be revised in renewal O