URANIUM MINING

Opportunities Exist to 

Improve Oversight of 

Financial Assurances

Report to the Ranking Member, 

Committee on Natural Resources, 

House of Representatives

May 2012

GAO-12-544

United States Government Accountability Office

GAO
United States Government Accountability Office

Highlights of GAO-12-544, a report to the 

Ranking Member, Committee on Natural 

Resources, House of Representatives 

May 2012

URANIUM MINING

Opportunities Exist to Improve Oversight of 

Financial Assurances

Why GAO Did This Study

From 2005 through 2007, uranium 

prices increased from about $20 a 

pound to over $140 a pound, leading to 

renewed interest in uranium mining on 

federal land. This interest has raised 

concerns about the potential impacts 

that more uranium operations could 

have on the environment. GAO was 

asked to (1) compare key agencies’ 

oversight of uranium exploration and 

extraction operations on federal land,

(2) determine the number and status of 

uranium operations on federal land, 

(3) identify the coverage and amounts 

of financial assurances for reclaiming 

current uranium operations on federal 

land, and (4) examine what is known 

about the number and location of 

abandoned uranium mine sites on 

federal land and their potential cleanup 

costs. GAO reviewed agency reports 

and regulations, surveyed relevant 

agency field staff on the status of these 

operations, and examined federal data 

on uranium operations, financial 

assurances, and abandoned uranium 

mine sites. 

What GAO Recommends

GAO recommends, among other 

things, that federal agencies better 

coordinate their efforts when 

establishing financial assurances and 

develop a consistent definition for

abandoned mine sites. The 

Departments of the Interior, 

Agriculture, and Energy, along with 

NRC and the Environmental Protection 

Agency (EPA), concurred with these 

recommendations. In addition, Interior 

and EPA provided technical 

comments, which GAO incorporated as 

appropriate.

 

What GAO Found

The Bureau of Land Management (BLM), the Forest Service, and the 

Department of Energy (DOE) are the key agencies that oversee uranium 

exploration and extraction on federal land, but GAO identified three areas where 

their oversight processes differ. First, these agencies have different processes 

for notification of uranium exploration or extraction activities on federal land.

Second, the agencies require operators to have in place financial assurances to 

cover the full estimated cost of reclaiming a uranium operation, but they differ in 

who estimates the value of the financial assurance and the frequency of their 

reviews of the assurances. Third, under existing authorities, DOE can collect 

royalties or rents for uranium extraction, but BLM and the Forest Service cannot. 

DOE has collected about $64 million in rents and royalties from its leasing 

program since the 1940s.

As of January 2012, a total of 221 uranium operations were on federally 

managed land, but only 7 were actively extracting uranium and all of these were 

on BLM land. An additional 29 uranium operations were awaiting federal 

approval. Of the 202 operations on BLM land, the majority were engaged in 

either reclamation or exploration activities, according to BLM field officials. In 

addition, 3 uranium operations were on Forest Service land, and 16 operations 

were on lease tracts that DOE manages, none of which were actively extracting 

uranium. 

As of January 2012, BLM, the Forest Service, and DOE reported having $249.1 

million in financial assurances, and these assurances were generally adequate to

cover the estimated reclamation costs for uranium operations on federal land. 

Nearly all of these assurances ($247.6 million) were for authorized uranium 

operations on BLM-managed land, with the remaining $1.5 million for authorized 

operations on Forest Service land and for DOE’s lease tracts. BLM and the 

Nuclear Regulatory Commission (NRC), which is responsible for overseeing 

some aspects of uranium operations on federal land, do not coordinate efforts to 

establish and review financial assurances for in situ recovery operations, which 

use a series of wells to extract uranium. Such operations account for a large 

percentage of the total financial assurances held by the agencies. 

Federal agencies do not have reliable data on the number and location of 

abandoned uranium mine sites on federal land or a definitive cost for their 

cleanup. There are likely thousands of abandoned uranium mine sites on federal 

land, but GAO identified significant limitations in agencies’ data that make their 

databases generally unreliable. For example, these databases do not have 

complete data and do not use a consistent definition of an abandoned mine site. 

Agencies do not know how many sites will need cleanup, and they do not have 

information on the total cost to clean up these sites. Based on agencies’ 

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
Page i GAO-12-544 Uranium Mining

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

Contents
Page ii 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 iii 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 1 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

 

1

GAO, Hardrock Mining: Information on Abandoned Mines and Value and Coverage of 

Financial Assurances on BLM Land, 

Activities that 

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 2 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 3 GAO-12-544 Uranium Mining

environmental standards for certain sites.6

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.

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.

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

 

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. 

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 

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 4 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

 

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.

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 
 

Page 5 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 

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

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 

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.

 

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.

10Production data are for pounds of uranium oxide (U3O8) extracted from federal, state, 

and private land. 

Background
 

Page 6 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 offsite processing facility, called a mill, where extracted uranium is 

concentrated into a product called yellowcake (U3O8).11

 

11At 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.

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.
 

Page 7 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 8 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

 

12According 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. 

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.

13Susan Hall, USGS, Groundwater Restoration at Uranium In-Situ Recovery Mines, South 

Texas Coastal Plain (Reston, Virginia: 2009).
 

Page 9 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 10 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 planlevel 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

 

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

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 
 

Page 11 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

• 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.

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.

• 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 

 

15In 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.

16On 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 12 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

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 

NRC regulations 

make EPA’s groundwater protection standards generally applicable to 

uranium milling sites, including ISR operations.

 

17Arizona, 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.

18New 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.

19EPA is currently reviewing its existing groundwater standards under 40 C.F.R. pt. 192. 
 

Page 13 GAO-12-544 Uranium Mining

site.20

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.

Memorandums of understanding among the federal and state 

agencies aim to encourage coordination between states and federal 

agencies in overseeing mining operations.

BLM, the Forest Service, and DOE all oversee uranium exploration and 

extraction operations on the federal land they manage, but we identified 

three areas where their processes differ: (1) notification of exploration or 

extraction operations, (2) oversight of financial assurances, and (3) 

royalties and rents earned.

BLM, the Forest Service, and DOE require uranium operators to provide 

notification of their intent to undertake either uranium exploration or 

extraction activities on federal land, but their notification processes differ 

slightly. Under regulations for proposed activities on BLM land, “casual 

use”—generally defined as activities ordinarily resulting in no or negligible 

disturbance to the public lands or resources—is allowed without any notice.21

 

20Colorado, 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.

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 

21BLM’s regulations for hardrock mining are in 43 C.F.R. subpt. 3809.

Agencies Differ in 

Their Oversight of 

Uranium Operations 

on Federal Land

BLM, the Forest Service, 

and DOE Have Different 

Processes for Notification 

of Exploration or 

Extraction
 

Page 14 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

 

22Forest 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. 

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.
 

Page 15 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: Summary of Notification Requirements for Uranium Operations across Three Agencies

Table 1 describes some of the differences in notification 

requirements among BLM, the Forest Service, and DOE.

Agency Filing requirement for a notice-level operation Filing requirement for a plan of operations

BLM Exploration-related surface disturbance of 5 acres or 

less

Exploration that disturbs more than 5 acres or any 

extraction-related operations 

Forest Service Operations that might cause significant disturbance of 

surface resources

Operations that are likely to cause significant 

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.

 

23DOE’s previous environmental assessment was conducted on the uranium leasing 

program in 1995.
 

Page 16 GAO-12-544 Uranium Mining

BLM, the Forest Service, and DOE require operators to have financial 

assurances in place to cover the full estimated cost of reclaiming areas 

disturbed by operations; however, the agencies differ in who is 

responsible for initial calculation of these assurances, how frequently they 

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 

Agency

Coverage 

required 

Party responsible 

for initial 

calculation

Frequency of 

review

Documentation 

of review

When reclamation must 

begin following end of 

operations

BLM Full cost of 

reclamation

Operator 24 months for a 

notice; 36 months 

for plan of 

operations

Documented in 

LR2000 and 

summarized annually 

in Bond Review 

Report

Promptly for notices; earliest 

feasible time for plans of 

operations

Forest Service Full cost of 

reclamation

Forest Service Annually Recorded in case file, 

but no agencywide 

summary of review 

Within 1 year, or longer with 

Forest Service approval

DOE Full cost of 

reclamation

DOE Periodically, or 

whenever lessee 

proposes a change 

in operations

Recorded in case file, 

but no agencywide 

summary of review 

Promptly and must be 

completed within 180 days or 

date agreed to by DOE and 

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 

BLM, the Forest Service, 

and DOE Differ in Their 

Oversight of Financial 

Assurances
 

Page 17 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

The Forest Service also directs operators to provide a financial assurance 

for the full cost of reclamation.

In these cases, the state holds the financial assurance, but it is 

also redeemable by BLM.

26

 

24BLM 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. 

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 

25BLM does not have an agreement covering joint bonding with Arizona.

26Forest Service guidance directs its staff to obtain financial assurances to cover the 

estimated reclamation costs for mining operations on National Forest System lands.
 

Page 18 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 19 GAO-12-544 Uranium Mining

Under existing statutory authorities, BLM and the Forest Service cannot 

collect rents for the use of federal land or charge royalties on hardrock 

minerals, including uranium, extracted from that land.27 BLM does charge 

claimants an initial $34 location fee, a $15 processing fee, and an annual 

$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.

 

27Unlike 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.

28The 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. 

Unlike BLM and the Forest 

Service, DOE Earns 

Royalties and Rents from 

Uranium Operations
 

Page 20 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 

managed land, but only 7 of these operations were actively extracting 

uranium and these were all on BLM land.

29 An additional 29 uranium 

operations were awaiting federal approval. Most of the operations—202—

were on BLM land; another 3 were on Forest Service land, and the 

remaining 16 were on DOE lease tracts.

Of the 221 uranium operations on federal land, 202, or 91 percent, were 

on land managed by BLM, according to our analysis of agency data. Of 

these 202 operations, BLM’s LR2000 database identified 144 as 

authorized, which means BLM has acknowledged an operator’s notice or 

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 

 

29This 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. 

Over 200 Uranium 

Operations Are on 

Federal Land, but 

Few Are Actively 

Extracting Uranium

Uranium Operations on 

BLM Land Are Generally 

Engaged in Exploration or 

Reclamation
 

Page 21 GAO-12-544 Uranium Mining

pending operations could involve disturbing up to 24,300 acres of BLMmanaged 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.

 

30This 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.

31Staff 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. 

32On 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 22 GAO-12-544 Uranium Mining

Table 3: Results of GAO’s Survey of BLM Field Offices on Status of Uranium Operations

Type of operation

Exploration 

permitting Exploration

Extraction 

permittinga Extractiona Standby Reclamation Closed Other

Don’t 

know

Authorized operations

Authorized notices 1 55 0 0 7 45 5 2 0 

Authorized plans of 

operations

1 5 2 7 15 6 0 1 0 

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 

operations

2 1 13 0 2 0 1 1 0 

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 23 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

Pandoraa Denison Utah Underground

La Sala Denison Utah Underground

Highlandb Cameco Wyoming ISR 

Smith Ranchb 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.

We identified three uranium operations on land managed by the Forest 

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 

 

33GAO, Standards for Internal Control in the Federal Government, GAO/AIMD-00-21.3.1

(Washington, D.C.: November 1999).

Three Uranium Operations 

Are on Forest Service Land
 

Page 24 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.

As part of is uranium leasing program, DOE oversees 31 lease tracts, 

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

• Seven lease tracts have approved exploration plans, but no 

exploration work is ongoing.

These 

lease tracts cover about 6,900 acres, but the operations have 

disturbed only about 260 acres of land.

• 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

 

34One 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. 

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 

35DOE officials also reported that no exploration activity has taken place on the lease 

tracts since 2010.

36The 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. 

All 9 Mines on DOE’s Lease 

Tracts Are on Standby
 

Page 25 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 

million in financial assurances, and these assurances appear to be 

generally adequate to cover the estimated reclamation costs for uranium 

operations on federal land, according to our analysis of agency data.38

Agency data indicate that nearly all of these assurances ($247.6 million of 

the $249.1 million) are for operations that are at least partially on BLMmanaged land.39

 

37In February 2012, the court modified the injunction to allow certain surface-disturbing 

activities, including those that are absolutely necessary to conduct the environmental 

analysis.

Although almost all of these financial assurances were 

adequate to cover the estimated cost of reclamation, we identified some 

issues in how BLM oversees these assurances. We also found the value 

of financial assurances for two ISR operations had increased significantly, 

but that BLM and NRC did not coordinate their efforts to establish and 

review financial assurances for these operations. The remaining $1.5 

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.

38The 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. 

39For 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.

Agency Data Indicate 

That Financial 

Assurances 

Adequately Cover 

Nearly All Operations, 

but BLM and NRC Do 

Not Coordinate in 

Establishing Some 

Assurances
 

Page 26 GAO-12-544 Uranium Mining

As of January 2012, BLM had financial assurances of about $245.5 

million for 144 authorized uranium operations, according to our review of 

BLM’s Bond Review Report, and the financial assurances were adequate 

for all but 2 of the operations. Specifically, we found 1 operation where 

BLM field staff reported that the assurance in place was likely inadequate 

to reclaim an acid pit lake that had formed at an older, inactive open pit 

uranium mine in Wyoming. The operation has in place a financial 

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

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.

In general, we found that most of the financial assurances for 

operations on BLM land are for less than $100,000.

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 

 

40According to BLM officials, the agency has contacted the new owner of this operation 

about the need to increase the financial assurance amount.

BLM Had Financial 

Assurances to Cover 

Reclamation Costs for 

Nearly All Operations, but 

Some Issues Exist 

Regarding Agency 

Oversight
 

Page 27 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.

We found that two ISR operations—the Smith Ranch and Highland 

operations in Wyoming—account for $213 million in financial assurances, 

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 

financial assurances for these two operations also covers activities on 

land that is not managed by BLM, such as state or private land.41

 

41According to BLM officials, the financial assurances held for uranium operations are not 

broken out by the entity that manages the surface. 

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 

BLM and NRC Do Not 

Coordinate when 

Establishing and 

Reviewing Assurances for 

ISR Operations
 

Page 28 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

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.

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.

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 

 

42Wyoming Department of Environmental Quality, “In Situ Uranium Permits 603 and 633, 

Notice of Violation, Docket No. 4231-08” (Cheyenne, Wyoming, 2008).
 

Page 29 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 DOE have financial assurances for uranium 

operations that are adequate to cover the current estimated cost of 

reclamation for the sites they oversee, according to our analysis of 

agency data. Specifically, the Forest Service reported having about 

$42,000 in financial assurances for the three operations on its land, one 

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 

 

43Alternate 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). 

The Forest Service and 

DOE Have Adequate 

Financial Assurances to 

Cover Reclamation Costs 

for Uranium Activity
 

Page 30 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 

abandoned uranium mine sites on federal lands and the potential cleanup 

costs associated with these sites, according to our review of agencies’ 

databases and discussions with agency staff. We found that agency 

databases generally lack complete data and a common definition of an 

abandoned mine site, and contain information that has not been verified 

through field inspections. In addition, federal agencies do not have 

estimates of the potential total cleanup cost for abandoned uranium mine 

sites on the land they manage. According to agency officials, the cost to 

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 

of sites needing cleanup.

There are likely thousands of abandoned uranium mine sites on federal 

land where either exploration or extraction may have taken place, but the 

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 

 

44According to DOE, the financial assurances for the 2 lease tracts that were not leased 

out were last reviewed in June 2008.

45DOE 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. 

Federal Agencies Do 

Not Have Reliable 

Data on the Number 

and Location of 

Abandoned Uranium 

Mines or Their 

Associated Cleanup 

Costs

Federal Data on 

Abandoned Uranium 

Mines Are Unreliable
 

Page 31 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

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 

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.

 

46According 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.

47New 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 32 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 

 

48In 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. 

49EPA, Technical Report on Technologically Enhanced Naturally Occurring Radioactive 

Materials from Uranium Mining, Volume 2 (Washington, D.C.: August 2007). 

50GAO, 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. 

51The 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 33 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.

 

52According 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 34 GAO-12-544 Uranium Mining 

Table 5: Limitations with Four Federal Agencies’ Databases on Abandoned Uranium Mines 

 Limitations with these databases 

Agency Database namea

Partially tracks 

the commodity 

extracted 

Does not track 

the extent to 

which 

extraction took 

place at a site 

Does not track 

which sites 

have been 

cleaned up 

Used an 

inconsistent 

definition of a site

Some sites in 

the database 

have not been 

verified 

through field 

inspection 

 BLM Abandoned Mine/Site 

Cleanup Module 

X X X X 

The Forest 

Service 

Forest Service 

Abandoned Mineral 

Lands Database 

X X X X X 

National Park 

Service 

Servicewide 

Abandoned Mineral 

Lands Database 

X 

EPA Technologically 

Enhanced Naturally 

Occurring Radioactive 

Materials Uranium 

Location Database 

 X X X X 

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

 

53BLM, Draft Feasibility Study for AML Inventory Validation and Physical Safety Closures

(Washington, D.C.: May 2011). 
 

Page 35 GAO-12-544 Uranium Mining

In addition to not knowing how many abandoned uranium mines are on 

federal land, BLM, the Forest Service, EPA, and the National Park 

Service do not have information on the total cost of cleaning up 

abandoned uranium mines. Officials noted that cleanup costs are 

determined not only by the total number of mines that need cleanup, but 

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

 

54As 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.

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.

Cleanup Costs for 

Abandoned Uranium 

Mines Vary Greatly, 

Depending on Site-Specific 

Conditions
 

Page 36 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 37 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 

Primary cleanup work 

conducted at a site 

Number of abandoned 

uranium sites 

examined

Range of cost

(in 2011 dollars)

Address physical safety 6 $1,800–$33,000

Conduct surface reclamation 6 $2,500–$98,000

Conduct environmental 

remediation

6 $203,000–$193,000,000a

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

 

55The cleanup costs provided in this section are in 2011 dollars. 

56According 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 38 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

• 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.

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.

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

 

57BLM contracted with DOE to conduct this reclamation work on its land. 

Most of this cost is for treating acid rock drainage in two 

58Both of these examples are from EPA’s Superfund program.

59This 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 39 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 

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, 

Conclusions
 

Page 40 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 

mining operations on federal land, we are recommending the following 

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. 

Recommendations for 

Executive Action 
 

Page 41 GAO-12-544 Uranium Mining

We provided a draft of this report to the Department of Agriculture, the 

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.

Agency Comments
 

Page 42 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
Appendix I: Objectives, Scope, and 

Methodology

Page 43 GAO-12-544 Uranium Mining

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

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 

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.

 

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. 

Appendix I: Objectives, Scope, and 

Methodology 
Appendix I: Objectives, Scope, and 

Methodology

Page 44 GAO-12-544 Uranium Mining

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.” 
Appendix I: Objectives, Scope, and 

Methodology

Page 45 GAO-12-544 Uranium Mining

• 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 
Appendix I: Objectives, Scope, and 

Methodology

Page 46 GAO-12-544 Uranium Mining

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 
Appendix I: Objectives, Scope, and 

Methodology

Page 47 GAO-12-544 Uranium Mining

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

• address safety hazards, which means that most cleanup activities at 

the site are intended to mitigate safety hazards;

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

• 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. 
Appendix I: Objectives, Scope, and 

Methodology

Page 48 GAO-12-544 Uranium Mining

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.
Appendix II: Information on In Situ Recovery 

Operations on BLM Land That Are Extracting 

Uranium, on Standby, or Awaiting Federal 

Authorization

Page 49 GAO-12-544 Uranium Mining

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

Name Location Operator

Financial assurance amount 

(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 

assurance covers this 

operation.

Authorized by BLM and NRC but not 

extracting uranium.

Ross Wyoming Strata No decision on financial 

assurance yet.

Waiting for BLM and NRC authorization. 

Ruth Wyoming Cameco $0.18 BLM has not yet received a plan of 

operations for this operation. Authorized by 

NRC. 

Dewey Burdock South 

Dakota 

Powertech No decision on financial 

assurance yet.

Waiting for BLM and NRC authorization. 

Source: GAO analysis of BLM and NRC information.

Appendix II: Information on In Situ Recovery 

Operations on BLM Land That Are Extracting Uranium, 

on Standby, or Awaiting Federal Authorization
Appendix III: Detailed Information on Federal 

Abandoned Mine Databases 

Page 50 GAO-12-544 Uranium Mining

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

Agency Database name

Number of 

abandoned 

uranium 

mines listed 

in the 

databasea

Mines 

cleaned up to 

date listed in 

the databasea

Number of 

abandoned 

uranium mines 

in the database 

that remain to 

be cleaned upa Limitations with the data 

BLM Abandoned MineSite Cleanup 

Module (AMSCM)b

3,038 1,849 1,189 • Entering the mined commodity in 

this database is optional. Only three 

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 

Service 

Forest Service 

Abandoned 

Mineral Lands

Database, which 

relies entirely on 

the U.S. 

Geological 

Survey’s (USGS) 

Mineral Resources 

Data System 

(MRDS)c

1,097 Unknown Unknown • MRDS has not been updated since 

1995. Also, it does not include 

information on the major commodity 

mined for over 22,000 of its records.

• The database does not provide 

updated information on the extent to 

which extraction took place at a site.

• The definition used by the Forest 

Service for a site is different than 

the definition used by the USGS for 

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 

Service 

Servicewide 

Abandoned 

Mineral Lands 

Database

46 21 25 • Entering the commodity field is 

optional for National Park Service 

staff.

Appendix III: Detailed Information on 

Federal Abandoned Mine Databases
Appendix III: Detailed Information on Federal 

Abandoned Mine Databases 

Page 51 GAO-12-544 Uranium Mining 

Agency Database name 

Number of 

abandoned 

uranium 

mines listed 

in the 

databasea

Mines 

cleaned up to 

date listed in 

the databasea

Number of 

abandoned 

uranium mines 

in the database 

that remain to 

be cleaned upa

 Limitations with the data 

EPA Technologically 

Enhanced 

Naturally Occurring 

Radioactive 

Materials Uranium 

Location Database 

8,124 Unknown Unknown  Some data were not included in the 

database because they did not have 

adequate geographic coordinates. 

 The database does not track the 

extent to which extraction took place 

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. 
Appendix IV: Examples of Cleanup Activities at 

Abandoned Uranium Mine Sites

Page 52 GAO-12-544 Uranium Mining

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 

agency managing 

the land) Description of the mine

Address physical 

safety hazards

Conduct surface 

reclamation

Conduct 

environmental 

remediation

Total cost

(in 2011 

dollars)

Mines where cleanup focused on physical safety

Salt Valley Wash 

Mines, Utah 

(National Park 

Service) 

Two small underground 

mines, each with one 

shaft (vertical mine 

opening) in Arches 

National Park, dating from 

the 1940s. 

Backfilled two shafts 

by hand with 24 and 

63 cubic yards of 

adjacent waste 

material

None None $1,818

Loma Mines, 

Colorado (Bureau of 

Land Management)

Conventional 

underground mines 

located beneath a bluff 2 

miles from an interstate 

highway.

Backfilled two mine 

adits (horizontal mine 

opening) with trash 

and wood debris, and 

closed them with 

polyurethane foam

None None 2,105

Terry Mine, Utah 

(National Park 

Service) 

Conventional 

underground mine 

located in the Capitol 

Reef National Park, within 

one-quarter mile of a 

main road. 

Backfilled a shaft with 

85 cubic yards and an 

adit with 50 cubic 

yards of waste 

materials

Erected two fences of 

800 and 960 feet in 

length to exclude 

grazing cattle

Placed warning signs 

around the site 

Revegetated the site 

Burned wooden 

structures 

None 10,443

Whirlwind, Utah 

(National Park 

Service) 

Conventional 

underground mine 

located about 400 feet 

above the elevation of a 

lake in Glen Canyon 

National Recreation Area. 

The cleanup crew and 

equipment were flown in 

by helicopter. 

Demolished 

structures 

Backfilled adits with 

steel, wood, and 

other debris

Closed a drill hole 

with polyurethane 

foam

Posted four warning 

signs

Demolished an 800-

square-foot steel ore 

bin

None 11,448

Appendix IV: Examples of Cleanup Activities 

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

Abandoned Uranium Mine Sites

Page 53 GAO-12-544 Uranium Mining

Summary of cleanup work performed or planned at the sitea

Mine name, 

location / (federal 

agency managing 

the land) Description of the mine

Address physical 

safety hazards

Conduct surface 

reclamation

Conduct 

environmental 

remediation

Total cost

(in 2011 

dollars)

White Rim, Utah 

(National Park 

Service) 

Four conventional 

underground mines 

located in Glen Canyon 

National Recreation Area. 

One site is located about 

1 mile from the park’s 

Visitors Center and 

another about 1 mile from 

a campground. 

Installed steel gates 

over five adits

Backfilled by hand 

one adit using 8 cubic 

yards of material

None None 22,499

Lathtrop Canyon 1-

8, Utah (National 

Park Service)

Conventional 

underground mine 

located in Canyonlands 

National Park that was 

developed in the late 

1950s. The crew 

accessed the site by foot 

and the equipment was 

flown in by helicopter. 

Closed 11 adits using 

various methods

Installed warning 

signs throughout the 

site

None None 33,021

Mines where cleanup focused on surface reclamation

Nine Mile Hill Mines, 

Colorado (Bureau of 

Land Management)

Conventional 

underground mines 

located above a public 

highway.

Backfilled two small 

adits with waste rock 

material using an 

excavator

Recontoured 70 cubic 

yards of waste rock 

materials

Revegetated 1 acre 

of land

None 2,524

Mesa No. 5, 

Colorado (Bureau of 

Land Management)

Conventional 

underground mine that 

contained a waste rock 

pile, which affected an 

adjacent, intermittent 

stream. 

Closed two smalldiameter ventilation 

shafts with 

polyurethane foam

Backfilled a mine 

opening with 5,200 

cubic yards of waste 

rock materials and 

trash and debris

Recontoured 10,200 

cubic yards of waste 

rock material

Covered the 

recontoured area with 

topsoil excavated 

from a nearby site

Revegetated 4 acres 

of land 

None 12,963 

Northern Light 

Mines, Colorado 

(Bureau of Land 

Management)

Conventional 

underground mine.

Placed wood debris 

from demolished 

structures in mine 

openings

Installed gates over 3 

adits

Backfilled 5 additional 

shafts with waste rock 

Recontoured 600 

cubic yards of waste 

rock 

Covered the 

recontoured area with 

topsoil

Revegetated 2 acres 

of land

None 17,121
Appendix IV: Examples of Cleanup Activities at 

Abandoned Uranium Mine Sites

Page 54 GAO-12-544 Uranium Mining

Summary of cleanup work performed or planned at the sitea

Mine name, 

location / (federal 

agency managing 

the land) Description of the mine

Address physical 

safety hazards

Conduct surface 

reclamation

Conduct 

environmental 

remediation

Total cost

(in 2011 

dollars)

Rainy Day, Utah 

(National Park 

Service) 

Conventional 

underground mine 

located in the Capital 

Reef National Park 4 

miles from the main road. 

The site was accessible 

by foot. 

Placed debris from 

demolished structures 

in mine adits

Backfilled 12 adits 

with earth from the 

disturbed slope using 

a backhoe 

Demolished 

structures 

Corrected areas of 

severe erosion and 

built drainage controls 

None 30,768

New Verde Mine, 

Colorado (Bureau of 

Land Management)

Single underground large 

mine. This is a historic 

site where parts of the 

operation were left in 

place and preserved.

None Demolished and 

disposed of structures 

offsite

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

None 78,524

Hawk Mine 

Complex, Colorado 

(Bureau of Land 

Management) 

A complex of 

underground mines that 

started operations in 

1948, consisting of eight 

separate and distinct 

mine sites, six mine 

access ramps, three 

adits, and one surface pit.

Placed debris from 

eight locations in 

mine openings

Backfilled seven mine 

openings with waste 

rock 

Installed gates at 

three mine openings

Closed nine small 

ventilation shafts and 

132 exploration drill 

holes using 

polyurethane foam

Backfilled 500 cubic 

yards of surface pits 

with waste rock 

materials

Recontoured 6,800 

cubic yards of waste 

rock materials from 

eight waste rock piles

Covered the 

recontoured area with 

1,000 cubic yards of 

topsoil

Revegetated 4 acres 

of land

None 97,589 
Appendix IV: Examples of Cleanup Activities at 

Abandoned Uranium Mine Sites

Page 55 GAO-12-544 Uranium Mining

Summary of cleanup work performed or planned at the sitea

Mine name, 

location / (federal 

agency managing 

the land) Description of the mine

Address physical 

safety hazards

Conduct surface 

reclamation

Conduct 

environmental 

remediation

Total cost

(in 2011 

dollars)

Mines where cleanup focused on environmental remediation

Pryor Mountain 

Mine, Carbon 

County, Montana 

(the Forest Service)

Two separate mines 

developed in the 1950s 

located in an area where 

hiking and camping take 

place. The site is also 

used as a sacred ground 

by a nearby Indian tribe. 

The site was accessible 

by four-wheel-drive roads, 

and large equipment was 

brought in by helicopter. 

Installed gates over 

three adits

Backfilled a number 

of exploration pits

Removed 4- to 8- foot 

highwalls (edge of the 

mine)

Removed one 

collapsed structure

Revegetated all of the 

disturbed areas within 

the site

Removed human 

health risks related to 

the site (no details 

were available of the 

actual work 

conducted)

203,238

Workman Creek 

Uranium Mines, Gila 

County, Arizona (the 

Forest Service)

The site, developed in the 

1950s, encompasses 

eight mines on steep 

hillsides located near 

campgrounds. Waste 

rock piles contain 

elevated levels of 

carcinogenic and 

radioactive elements, and 

there is concern of these 

materials getting into 

major water supplies that 

serve the Phoenix 

metropolitan area. 

Plan to:

Install warning signs

Plan to:

Backfill the excavated 

areas with clean soil

Recontour some 

areas to establish 

stability and prevent 

water runoff

Cut off road access to 

the site

Plan to:

Backfill all 33 mine 

openings with 30,500 

cubic yards of waste 

rock, some of which 

is contaminated, and 

close them with 

polyurethane foam

Remove 500 cubic 

yards of 

contaminated waste 

rock piles from the 

campgrounds and 

creek side and place 

in a repository on site

600,000b

(estimate)

San Mateo Uranium 

Mine, New Mexico 

(the Forest Service)

The site, which operated 

between 1957 and 1971, 

is located in a remote 

location with limited public 

access. The waste rock 

pile is toxic and 

radioactively 

contaminated, and storm 

water runoff from this pile 

flows into a nearby creek. 

Plan to:

Install an 8-foot-high 

chain-link fence to 

enclose 

approximately 17 

acres necessary to 

exclude wildlife and 

livestock from 

destroying the 

vegetation

Plan to:

Recontour and 

revegetate 

approximately 35 

acres to further 

reduce windblown 

transport of any 

residual 

contamination

Plan to:

Consolidate and 

cover 180,000 cubic 

yards of 

contaminated waste 

rock pile

Conduct ongoing 

maintenance to repair 

erosion of the cap 

material and of the 

drainage channels 

after heavy rainfall 

events

3,095,750b

(estimate)
Appendix IV: Examples of Cleanup Activities at 

Abandoned Uranium Mine Sites

Page 56 GAO-12-544 Uranium Mining

Summary of cleanup work performed or planned at the sitea

Mine name, 

location / (federal 

agency managing 

the land) Description of the mine

Address physical 

safety hazards

Conduct surface 

reclamation

Conduct 

environmental 

remediation

Total cost

(in 2011 

dollars)

White King Lucky 

Lass, Oregon (the 

Forest Service)

This site consists of two 

conventional open pit 

mines for a combined 140 

acres of disturbed land. It 

operated between 1955 

and 1965. The site had 

three large waste rock piles 

of approximately 1.26 

million cubic yards and two 

large pits that cover 

approximately 5 and 14 

acres, which are full with 

millions of gallons of water. 

Carcinogenic and 

radioactive contaminants 

were found at the site and 

a creek runs next to the 

mine and received 

discharge from this 

contaminated pit. This site 

was added to EPA’s 

National Priority List in 

1995. 

Installed three-strand 

barbed wire fencing 

around wetlands and 

reclaimed waste 

stockpiles

Regraded, replaced 

topsoil, capped with a 

dry cover system, and 

revegetated the 

waste rock piles

Restored and 

revegetated other 

disturbed areas

Removed 

contaminated soil from 

the stockpiles

Relocated the flow of 

the creek into historic 

channels and 

constructed three 

wetland areas to 

prevent runoff into the 

creek

Installed 10 wells for 

groundwater 

monitoring

Plan to perform longterm monitoring and 

regular neutralization 

of the pit water to 

prevent any acidic 

water from reaching 

the creek 

5,939,087

Riley Pass Mine, 

Harding County, 

South Dakota (the 

Forest Service)

This site, which operated in 

the 1950s and 1960s, 

involves 12 mine groups 

and spreads over 

approximately 1,000 acres. 

The site consists of

numerous open pits, waste 

rock piles, and five 

sediment ponds. The area 

is prone to erosion, and the 

site poses safety concerns 

from unstable highwalls. 

The site also poses health 

and environmental risks 

from heavy metals and 

radiation. Two mines have 

already been cleaned up 

and cleanup at a third is 

ongoing. The U.S. 

government is currently 

involved in a bankruptcy 

proceeding with potentially 

responsible parties to 

recover costs for the 

remaining cleanup. 

None Plan to:

Reshape the 

highwalls

Fill or reshape the 

erosion gullies

Stabilize the fragile 

soils and revegetate 

the area

Plan to:

Establish a series of 

sediment control 

measures, such as 

sediment ponds, to 

control runoff

Excavate and place 

contaminated 

material in designed 

repositories, or cap 

the contaminated 

material in place

The Forest Service 

estimates that a longterm maintenance 

effort will be needed 

for at least 100 years 

because of the fragile 

soil and climate 

conditions

74,733,520b

(estimate)
Appendix IV: Examples of Cleanup Activities at 

Abandoned Uranium Mine Sites

Page 57 GAO-12-544 Uranium Mining

Summary of cleanup work performed or planned at the sitea

Mine name, 

location / (federal 

agency managing 

the land) Description of the mine

Address physical 

safety hazards

Conduct surface 

reclamation

Conduct 

environmental 

remediation

Total cost

(in 2011 

dollars)

Midnite Mine, 

Stevens County, 

Washington (Bureau 

of Land 

Management)

This is a more than 320- 

acre open pit mine that 

operated from 1954 to 

1981. Approximately 33 

million tons of waste 

material was dug up from 

six large pits, two of 

which have not been 

backfilled and are full of 

water. Numerous piles of 

waste materials are also 

located throughout the 

site. High levels of toxic 

and radioactive chemicals 

are at the site. Acidic 

water drains into a nearby 

creek. Some cleanup 

work at the site has 

already been conducted. 

This site was added to 

EPA’s National Priority 

List in 2000.

Plan to:

Build a fence around 

the site and boulder 

barriers around the 

contaminated waste 

piles

Plan to:

Cover the four pits 

that were backfilled 

with a thick dry cover, 

clean soil, and 

vegetation

Grade and cover 

waste piles and areas 

cleaned of waste 

throughout the site 

with fresh soil and 

vegetation

Conduct long-term 

maintenance and 

monitoring of the dry 

cover systems and 

the vegetation to 

mitigate acid rock 

drainage

Plan to:

Empty out the two 

pits full with acid 

water and treat this 

water at a water 

treatment plant on 

site

Cover the bottom of 

these pits with a thick 

drainage layer where 

water can collect and 

install a water 

removal system along 

with filling the pits 

with waste rock and 

covering the pits with 

a thick vegetated 

cover 

Build a new water 

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 

193,000,000b

(estimate)

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. 
Appendix V: Comments from the Department 

of Agriculture

Page 58 GAO-12-544 Uranium Mining

Appendix V: Comments from the Department 

of Agriculture
Appendix VI: Comments from the Department 

of Energy

Page 59 GAO-12-544 Uranium Mining

Appendix VI: Comments from the 

Department of Energy
Appendix VI: Comments from the Department 

of Energy

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

of the Interior

Page 61 GAO-12-544 Uranium Mining

Appendix VII: Comments from the 

Department of the Interior
Appendix VIII: Comments from the 

Environmental Protection Agency

Page 62 GAO-12-544 Uranium Mining

Appendix VIII: Comments from the 

Environmental Protection Agency
Appendix VIII: Comments from the 

Environmental Protection Agency

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

Regulatory Commission

Page 64 GAO-12-544 Uranium Mining

Appendix IX: Comments from the Nuclear 

Regulatory Commission
Appendix IX: Comments from the Nuclear 

Regulatory Commission

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

Acknowledgments

Page 66 GAO-12-544 Uranium Mining

Anu K. Mittal, (202) 512-3841 or mittala@gao.gov

In addition to the individual named above, Andrea Brown and Elizabeth 

Erdmann (Assistant Directors), Antoinette Capaccio, Julia Coulter, Maria 

Gaona, Scott Heacock, Cristian Ion, Rebecca Shea, Carol Herrnstadt 

Shulman, and Jena Sinkfield made key contributions to this report.

Appendix X: GAO Contact and Staff 

Acknowledgments 

GAO Contact

Staff 

Acknowledgments

(361296)
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