Texas Radiation Online - The Texas Uranium Mining Legacy
Latest News: In October 2004, residents of rural Kleberg County near Kingsville were notified by the EPA that uranium and radiation levels as high as eight times the federal safety standards had been detected in the water wells, and to not drink the water. The mining company URI is currently attempting to reopen two sites and start a new injection well in the county, and claiming the area pollution as naturally present. Hearings on the issue are to continue through early August.
Read more: "Uranium Mining Coming Back"



The South Texas Uranium Mining Legacy


Uranium Mining Sites in Texas
(click the image to see a bigger map)
The Texas Uranium Boom
In 1954-55, an uranium ore deposit was found in southwestern Karnes County, Texas. This discovery set events into motion which would foster the development of an industry which would supply the majority of U.S. uranium production, and, from it's legacy of poisoned land and water, forecast the destinys of ranchers and farmers.

In the years that followed, more than 20 corporations arrived and conducted a variety of exploration, development, production, and reclamation activities for uranium materials, including uranium mining, milling, and waste disposal operations which have affected thousands of acres in 18 South Texas counties.

The uranium industry in south Texas expanded until 1979 when the price of uranium oxide reached it's peak, and in 1984 when the market crashed. Up until the late 1980s, a major portion of uranium ore produced in the US came from Texas.



Things really got going by 1960, when the U.S. Atomic Energy Commission (AEC) opened a uranium-ore buying station in western Karnes County near the uranium deposits and it stockpiled some 111,000 tons of ore that assayed 0.19 percent U3O8. Later in the year, Susquehanna-Western, Inc., (SWI) entered into contracts which would last until 1968 to produce uranium for sale to the AEC, and in 1960 began construction of the first uranium mine and mill built in Texas. Many more would soon follow, and it was a time of high ore prices and low government regulation.

Uranium recovery activities in Texas grew, and consisted of both solution mining and surface mining. By 1990, the uranium solution mining industry in Texas consisted of a total of 32 solution mining sites, 80 production areas, and approximately 20,000 solution mining wells. The uranium surface mining industry in Texas consisted of: a total of 40 mine sites, 4 uranium mills, 4 mill tailing ponds and 31,000 acres of land permitted since 1975. At two sites, underground mining activities were also conducted for a brief period. In addition, prior to 1975 various unpermitted and virtually unregulated uranium mining activities were conducted in Texas, which involved approximately 19 uranium surface sites and one underground mine site in South Texas.

By 1990, approximately fourteen of twenty-three firms previously involved in Texas uranium extraction activities were no longer involved in uranium production. Texas uranium industry had dropped to nine corporations with two actively producing uranium oxide, one involved in processing activities, one onstandby status, and eight of the nine companies actively engaged in various stages of reclamation and restoration of previously mined and milled areas.

This industry has created major environmental and public health problems. The mining and milling of uranium has created millions of tons of radiological and chemical waste, and the regulations in Texas regarding related operations have been dangerously inadequate: either not enforced, or nonexistent.


Photography by Sharon Stewart, with permission
To see more photography of Sharon Stewart, which is accompanied documentary style with quotes from South Texans in the photographed regions, please visit this gallery hosted by the Boston University School of Public Health.


Solution Mining and It's Consequences
Uranium arrived in South Texas millions of years ago when volcanic eruptions brought ash which settled on the ground. Over the centuries it distributed through the soil, into the groundwater and migrated out to the Gulf of Mexico. In some areas, isolated pockets of uranium locked into clays at the edges of the aquifers and stabilized, sealed away from release into the environment. The aquifer surrounding an ore deposit is generally free of the high contamination levels that exist inside of the ore body (elevated radium concentrations are naturally found only inside the ore, and not in the aquifer material surrounding the ore itself). These ore deposits are under typically over 100-feet below the surface, making dangerous levels of exposure and radon outgassing impossible.

Problems develop when humans drill holes into these areas which disturbs the ore region's steady state and creating pathways for the toxic materials to escape into the environment. For example, Flatonia, Texas east of San Antonio, had radon concentration levels in the early 1990s of 9000 pCi/L in the municipal water supply.

Environmental assessments completed prior to the mining operations show levels of background radiation in the area to have been below the national average background for the United States. Minute levels of free, unlocked uranium appeared near the ore body, however, 200 feet outside of the ore zone levels were less than 0.5 mg/L. Once operations were underway, these levels increased significantly. For example, at Westinghouse's Bruni site, free uranium levels averaged 0.692 ppm, and by 1975, these levels jumped to 150 ppm.

Prior to mining, thousands of exploratory holes are drilled in order to establish the shape of the ore field and determine the most profitable areas for mining. Since ore bodies reside in close proximity to aquifers, this results in puncturing the aquifers repeatedly in the process. Although these holes are supposed to be plugged so that contaminants do not migrate out of the ore zone into other strata during mining operations, this has very often been neglected. As Westinghouse put it, "these holes were not plugged when the companies abandoned the area, and therefore, left conduits for leachate migration." As indicated in the site specific example sections, aquifer contamination has been widespread at all sites used for extracting uranium, including those owned by Westinghouse.

After uranium ore has been located, the in situ leach mining process begins. A hole is drilled down into the ore body, and a leaching solution of ammonium bicarbonate is injected into the hole in order to loosen the ore and surrounding clay for removal. The resulting slurry is sucked out and processed to extract the raw uranium, which is characteristic of yellow mud and is nicknamed "yellowcake." A majority of this slurry is water from the neighboring aquifer which is mixed with the leaching fluids and a host of toxic and radioactive sediments which accompany the uranium, including arsenic, selenium, thorium, molybdenum, and radium.

Once the uranium has been extracted, the byproduct slurry is left to dry out in open evaporation ponds. The sediments which were sucked out with the uranium contain much higher levels of radioactivity than the uranium itself, and once dried are refered to as "tailings." These tailing ponds, or evaporation ponds, have often been unlined, which provides yet another pathway into the groundwater. They also vent particles into the atmosphere. A 1978 study by the TDH-BRC entitled "The Uranium District of the Texas Gulf Coastal Plain" stated that fluids at the Clay West site contained a radon content of 167,000 pCi/L. "This implies that very high levels of radon in the air can be expected above the water in the tanks." At the Westinghous Bruni site, five evaporation ponds had the capacity for 2,169,173 gallons of tailing fluids.

Large amounts of the same radioactive waste resides in underground waste deposits at the mining source, but can'not be retrieved or isolated from the groundwater. In addition, ammonia is absorbed by the clays and trapped underground. This bound ammonia is undetectable by standard monitor well sampling. An estimate by Westinghouse after the mining was completed showed approximately 4330 pounds of ammonia remained locked up in the clays for every 40 square-foot area of the mine zone.

Uranium Mining Sites used as Radioactive Waste Dumps
During the mining operations, waste other than tailings is generated such as pipe, machinery, liners, filters, soil, and building material. All of this waste used to be dumped at CONOCO's Conquista site, which operated as a de facto low-level waste dump without a permit. In addition, large amounts of waste were dumped at Chevron's Panna Maria site, which also was unlicensed for disposing of radioactive material. Both of these sites also accepted waste from outside of the state of Texas on numerous occassions. Niether CONOCO or Chevron was ever fined for this activity, and it remains largely ignored by the Department of Energy, who has assumed ownership of these sites under the UMTRA program.

What is Happening Now?
In the late 1980's, the uranium market shifted due to the opening of the Russian markets and reserves. The money left the US industry and the mining stopped. Currently, there are no active licensees in Texas mining uranium. All are either terminated or on hold, and one company is in violation. Several companies are under penalty for not completing decommissioning, for example, Everest Exploration's Mt. Lucas site is quite overdue for completing it's rudamentary cleanup. Some sites were abandoned by their owners. Sites which have fallen under the care of the DOE have recieved some minimal federal cleanup, others receive even less remediation. The DOE's method of cleanup is to gather the waste, cover the waste with a clay cap, place soil and grass atop and declare sufficient completion for long-term stewardship care. Although the maximum concentration levels have been raised repeatedly, groundwater contaminant levels are over-the-mark in most of the areas. The DOE has been quite assertive that it has no plans to try to clean any of the aquifers of south Texas.



Graphic (including text) taken from the San Antonio Express-News, October 2003. Mainstream media, often not being sufficiently familiar
with the issue to be critical, often repeat misleading assurances from industry "experts," who use phrases such as "impenetrable clay."
(a term used frequently with sites such as Pantex, and WCS's site in Andrews County). The DOE graphics
above imply that containment is more effective than is demonstrated, and ignore that the groundwater
is already severely contaminated at these sites, and are beyond being protected with any barrier.


Site Example I: CONOCO - El Conquista - Falls City, Karnes Co
In the early 1970's CONOCO, in cooperation with Pioneer Nuclear Corporation, began a venture known as the Conquista Project to mine uranium and build a 1750 ton-per-day processing mill southwest of Falls City. The project mined uranium by open pit in a 56-kilometer (35-mile) radius from the mill. Mining began in 1971, and milling operations ran from 1972-1982.

At Conquista, 9 million metric tons of radioactive waste was dumped in 256-acre unlined, uncovered uranium mill tailings pond. Until February 1989, CONOCO was allowed by the TDH-BRC to operate the facility as the only commercial radioactive mining waste dump in Texas. For 8 years, CONOCO was allowed to run this unlicensed disposal facility. Refering to an internal policy of "timely renewal," TDH-BRC explained they were "not able to get around to" licensing the site. Timely renewal allowed a loophole "grace period," for which TDH-BRC claimed the 8 years qualified as. This site disposed of waste from numerous uranium in-situ leach operators in Jim Hogg, Webb, and other counties. One primary generator of waste disposed of at the site was Rhone-Poulenc in Freeport.

Rhone-Poulenc, a french nationalized chemical manufacturing corporation, had purchased Union Carbide's agricultural chemical division after the accident in Bhopal India. This made it the third-largest chemical company in the world. Rhone-Poulenc dumped rare earths at Conquista until the dump stopped receiving in 1988. ("rare earths" refers to the lanthanide series of the periodic table: atomic numbers 57-71 plus yttrium, scandium, and thorium). Rare earths are used in superconductors and specialized alloys relating to high-tech industry.

Rare earth ores typically contain high concentrations of thorium, for which there is no market. Rhone-Poulenc's waste contained levels of radioactivity over 50-500 times higher than typical south Texas mill tailings. The wastes also contained an array of chemicals, although obtaining a complete analysis of the waste composition was in fact blocked by a federal judge in Waco. (the judge was persuaded by Rhone-Poulenc to deny access to further information regarding the waste in a case involving a request by Citizens for Closing the CONOCO El Conquista). There has been speculation that Rhone-Poulenc may have also brought waste from sites in Australia, where it also was mining.

The site was closed in 1989, and was to have been remediated by CONOCO to hand over to the DOE. The leaking unlined pits had already contaminated the aquifer to levels considered beyond remediation, and the final disposal cell itself was also an unlined pit, which was filled with waste, capped with clay and covered with soil and grass. Relaxed groundwater standards are still being sought from the state to bring the site into complete compliance. After 1989, the site had fallen under the partial ownership of the DOE under UMTRCA Title II, and the DOE is to assume full ownership as of 2002 under long-term stewardship.



Site Example II: Sesquehana Western - Falls City, Karnes Co.
Sesquehana Western (SWI) built the first uranium mine and mill in south Texas in 1960. The site originally covered about 1,600 acres. The mill went into operation in April 1961 with an initial capacity of 220 tons of ore per day (TPD) throughput, and it was expanded by 1969 to 1,000 TPD. Most of the mill feed was trucked from neighboring sites in south Texas, and from 1961-64, all of the ore that had been purchased at the AEC's ore-buying station was sold to SWI for processing at the Falls City mill. SWI had two separate contracts with the AEC until 1968, and a total of about 1.2 million tons of ore that averaged 0.19 percent U3O8 was processed during this period. (of this, 31 percent was sold to the AEC and 61 percent was sold commercially). After expiration of the AEC contracts, the mill continued to produce uranium for commercial sales until it was closed in 1973.

In the late 1970s, Solution Engineering, Inc., acquired about 200 acres of the Falls City mill site, including the mill and four of the nearby tailings piles. Between 1978-1982, Solution Engineering, under a license from the State of Texas, used a solution mining process to produce a relatively small quantity of uranium concentrate from the in-place tailings piles. The mill tailings were stored in 7 impoundments: there were 6 tailings piles (four were located in unlined mined-out pits) and one pond contaminated with tailings and mill residues. Afterwards, the site was abandoned and fell under the ownership of the DOE in 1992, who was to remediate and close the site under the UMTRCA Title-I program.

About 800 acres of privately-owned farmland surrounding the site had been contaminated by wind-blown material. The DOE had stripped the topsoil off of this land to dispose of with the tailing piles which had been gathered. Below the topsoil was caliche, so nothing would grow on this farmland once replaced with the fertilizer and seed. The farmer's only two choices were to either have their land stripped or condemned.

All of the waste had been placed into a single area and covered with a clay and rock cap with a bit of vegetation on top. This $22 million operation was said to isolate the waste for at least 200 years. In 1978, the DOE announced that water was unsafe to drink from the aquifers (the Conquista/Deweesville, and the Dilworth) and later in 1988 had estimated that the cleanup of the contaminated aquifer would require $350 million. Due to the cost of the operation, the DOE has decided to not remediate the aquifers.

The DOE had finished the engineered disposal cell in 1994, and obtained an NRC license for it by April 1998. The site was transferred to the Long-Term Surveillance and Maintenance Program in August 2000.


Site Example III: Chevron - Panna Maria Site - Panna Maria, Texas
In 1989, Chevron had the largest operating mill in the state at Panna Maria. The site was open from 1979-1992 and the onsite mines at the site had been closed after the first few years. Over 6 million tons of radioactive waste was dumped onsite in an unlined 160-acre tailings pond. Radioactive waste from Allied Chemical Processing's gaseous-diffusion plant in Illinois, from Kerr-McGee/Seqoayah Fuels in Oklahoma, and radioactive pipe scale from Mississippi was dumped on the site, as well as hazardous and mixed wastes. The law states that only mining waste and milling byproduct can be dumped at a mining waste site, but Chevron had been allowed to accept this questionable outside waste due to the TDH-BRC's broad definition of byproduct waste. The NRC had questioned whether the federal government could legally share ownership of site due to the amounts of non-mining waste which had been dumped there.

Chevron had also begun using waste acid from it's refining facility near El Paso as a leach solution in it's uranium mill. This waste acid is classified as a hazardous substance and the EPA had fined Chevron for trying to dispose of it in El Paso (as a violation of water protection law). Chevron was shipping 16 railroad tanker cars of this acid a week to Panna Maria to be used as leaching solution.

Chevron is still completing remediation activities at the site, which include placing all of the waste in a single disposal cell. The groundwater is contaminated to the extent that the TDH-BRC will not raise the alternate concentration levels (ACLs) any further. The site was expected to be transfered to DOE ownership under UMTRCA (Type II) in 2001.




Photography by Sharon Stewart, with permission


Site Example IV: Everest Exploration - Mt. Lucas
In October 1983, Everest Exploration was illegally given permission to begin an untested concept for disposal of untreated radioactive waste water from their Mt. Lucas in-situ uranium mine. This allowed Everest to dispose of it's process plant waste stream by simply spraying it on top of the ground. For 3 years leading up to April 1986, Everest surface-irrigated a 22.5 acre plot less than 900 ft from the shoreline of Lake Corpus Christi. In some areas, the levels have risen to 173 times above normal. Half of the irrigation water has percolated into the water table. Corpus Christi and 38 communities depend on Lake Corpus Christi as their only source of drinking water.

It has been said that "from 1983 to 1985 it appears the Bureau gave Everest Exploration the responsibility for acting as it's own environmental watchdog." Apparently, it was some time before the TDH-BRC discovered the company was irrigating with waste water containing high levels of radioactivity, up to 8000 pCi/L (picocuries per litre). In August 1984, agency personnel found gamma radiation levels in the test plot of 20 to 60 µR/hr compared to 9 µR/hr average background.

In 1985, Everest expressed interest in expanding the irrigation area beyond the original 22.5 acre experimental plot. A department inter-office memo explained that the legality of the original site was in question for two reasons: 1) The TDH-BRC never gave permission for irrigation at the site, and 2) the license at Mt. Lucas specifically required disposal of liquid waste by deep well injection. Two months later, the legal council for the TDH-BRC informed the agency that the Everest irrigation project was in violation of it's license.

Suprisingly, on October 3, 1985, the TDH-BRC went ahead and amended the license to include liquid waste disposal by irrigation on the 22.5 acre experimental plot. The legality of this action remains to be explained by the TDH-BRC, and appears to be a cover-up for bureaucratic mistakes. This amendment went even further, setting a 5 pCi/g radium-266 limit for radioactive soil pollution levels (whereas the national average is 0.6 pCi/g). Anything over 5 pCi/g requires remedial action, and studies showed the site averaged at 27 pCi/g radium-266 - nearly 6 times the limit. Some portions of the site measured 20 times the limit. What this means is that by law, the 22.5 acres should have been dug up and transported to a licensed waste dump.

In October 1985, Everest met with TDH-BRC to discuss the irrigation process. The TDH-BRC then authorized pre-treatment of the wastewater to remove excess radioactivity, and also set a limit for radioactivity in the irrigation water to 400 pCi/L. (whereas the EPA limit for surface discharge from uranium in-situ mines is 10 pCi/L). The meeting closed with Everest's vice-president stating that bermuda grass would be planted so that cattle could graze on the area.

Several experts at TDH-BRC insisted being on record as protesting these measures, and brought attention to several points, most notably that aerosolization/evaporation of irrigation wastewater at 400 pCi/L of Radium 266 could contribute significantly to public exposure to radioactivity, and that irrigation flows south out of the plot toward the lake.

In December 1985, Everest was granted an expansion to their license, from the 22.5 acres to the 105 acres they had requested- despite the expert advice of the staff. This was granted before any in-depth studies were completed on the original 22.5 acre lot. Analysis in December showed Radium-266 contamination to be 4 to 93 times higher than the 5 pCi/g limit. Contamination was shown to spread outside of the plot. Irrigation water showed radium-266 levels at 1420 pCi/L and uranium concentrations at 17,900 pCi/g. The EPA limits for surface discharge of radium and uranium are 30 pCi/L and 4mg/L (40 CFR 440 daily maximum). October 1986 irrigation water levels of uranium showed 41,400 pCi/g.

Everest also did not follow the licensing requirements for settling ponds they had built onsite, which had no liner. There was no testing for subsoil type, permeability, or depth-to-groundwater. TDH-BRC estimated the subsoil under the ponds to be sandy, with high-permeability, and the base of the pond within 5 feet of an unconfined water table.

Everest Exploration has yet to conduct any cleanup at the site. As recorded in the Texas Register, Everest was charged and fined in Sept 2001 for violations of it's license, and disposal of material without a license. By Feb 2002, an Emergency Order was issued to Everest citing "failure to timely and adequately decommission." Later in the month, Everest settled with the State by agreeing to begin decommissioning at it's sites no later than July 2002.



Site Example V: US Steel/ Niagra Mohawk - George West Area
US Steel owned and operated several sites in the George West area of Live Oak County, including Burns Ranch, Clay West, Moser, and Boots sites. In 1973, a pilot project at Clay West was jointly set underway by US Steel, DALCO Oil Co, and Atlantic Richfield to test ammonia in-situ solution mining. In 1975, US Steel opened it's Clay West site as the first large-scale commercial in-situ mine, capable of a yielding of 1 million pounds a year of uranium. US Steel soon expanded their operation and opened up the Burns site adjacent to Clay West, with an rated capacity of 400,000 lbs a year.

Over 22 spills were reported by US Steel at the Clay West and Burns sites alone, amounting to over 1,200,000 gallons of radioactive toxic chemicals at just these two sites. On 12-28-1977, contaminated water was detected at the Boots mine. 03-17-1978, leach fluids and high uranium levels were found in the upper aquifer on the west side of Moser I. It was found that a plastic pipe conduit between wells was linking the ore zone with the aquifer and allowing a steady flow. By 07-20-1979, the contamination had spread to detection wells on the east side of Moser I at the site perimeter detection wells. US Steel then expanded it's mining operations to include this area, and named it Moser II. Contamination reached new detection wells on the site perimeter of Moser II by 05-16-1980, and was detectable at Burns on 06-20-1980.

During the same time that this contaminant migration was being recorded, a 12-inch fiberglass pipe elbow had broken resulting in a 90,000 gallon spill of uranium rich liquid which flowed for a mile and underneath a major farm road before forming a pool. A sample of the pool indicated 8 ppm of uranium, and mud from the area made the meter go off the scale. A survey of the area showed high gamma readings in a 50-foot radius around the rupture. Although this accident occured 04-23-1980, US Steel did not report the incident until July. Some of this material was later gathered up and disposed of at the CONOCO dump.

Starting in 09-15-1980, the Texas Bureau of Radiation Control began to also look into worker overexposures, for which US Steel had blamed upon the workers themselves, although simultaneously admitted that high levels of uranium dust were a serious problem. During the 11 years of 1977-1983, 82 workers were reported to be overexposed from injesting or inhaling uranium particles. The NRC considers 30 µg/L to be the exposure limit. The largest overexposure ever recorded by the Bureau by this time was a US Steel worker named Armand Salazar in August of 1982, who was recorded with 50,494 µg/L of uranium in urine. US Steel discounted his sample as contaminated and immediately fired Salazar.

During an inspection on 09-04-1980, gamma radiation levels at storage areas around Burns were found to be so high as to peg the meters. Later in November, it was found that the company was transfering uranium liquid around without a conveyance system; routinely transfering from one plant process to the next by dumping the slurry on the concrete plant floor where workers would shovel it into the closest sump pit so it could be pumped away. Uranium fluid was found flowing off of the concrete pad onto the ground, and forming a solid yellow sheet of dried uranium. During this same inspection, a chair in the control room was found covered with yellow uranium measuring 1300 counts per minute of alpha radiation. Over time, it was found that the slurry had also eaten away the concrete surrounding these sumps in the ground. Shortly after, excavations for a new foundation at the plant revealed that the entire plant was sitting on soil completely saturated with uranium fluids. Fresh monitor wells showed levels in this saturated soil to be 32 mg/L to 3060 mg/L. The Bureau of Radiation Control ordered the soil to be cleaned up, although they never levied fines against US Steel for any of these incidents. As of 1991, the plant and the soil remained in place at the Burns site untouched.

If this wasn't bad enough, on 06-14-1981 the largest spill recorded in Texas history occured at the Burns site. 850,000 gallons of leaching solution spilled when a fiberglass pipe ruptured at 4:15 AM and flowed for 4 hours. The spill went offsite, reached the local state highway and followed along the highway for 2600 feet before soaking a surrounding pasture. Only 42,000 gallons was recovered by pumping into a holding pond, which was itself later discovered to have a severely damaged plastic liner which was leaking. and it is reported that two days later, heavy rains washed away any remaining fluid. The landowners, never notified by the company or any agency, were shocked to learn of the spill from newspapers the following month.




Sources:

["Analysis of In-Situ Uranium Mines: US Steel/ Niagra Mohawk and Westinghouse/ Wyoming Minerals," Texas Energy Alliance, Sibley, 1989.]
["Summary of Incident Files: US Steel/ Niagra Mohawk In-Situ Uranium Mine," Texas Energy Alliance, Sibley, 1989.]
["Wyoming Minerals/ Westinghouse Mine, Bruni, Texas," Texas Energy Alliance, Sibley, 1988.]
["Details of Uranium Mining, Wastes and Regulation" Texas Energy Alliance, Sibley, 1988.]
["Draft Synopsis of Uranium Mining and Milling in Texas," Texas Energy Alliance, Sibley, 1988.]
["A Synopsis of Uranium Mining, Milling, and Radioactive Waste Disposal in Texas," Texas Energy Alliance, Sibley, 1989.]
["Surface Irrigation at the Everest Exploration, Mt. Lucas Site" Texas Energy Alliance, Sibley, 1989.]
["Report on the Chevron Panna Maria License Renewal Hearing," Sibley, 1990.]
["Incident File on US Steel/ Niagra Mohawk In-Situ Uranium Mine, George West, Texas," Compiled from TDH-BRC, Sept 14, 1977- Dec 22, 1988. Texas Energy Alliance, Sibley, 1989.]
[Texas Department of Health, Bureau of Radiation Control, Interoffice Memorandum, "Leakage off Ur Fluids from US Steel Pad, Burns Ranch," John Haygood, Assistant Chief, License 8-2449, Incident File 2702]
[Texas Department of Water Resources, Interoffice Memorandum, "Wyoming Mineral Corporation Permit No. 01942A, Bruni Site, Inspection of Plant, Processing, and Storage Facilities," November 22, 1978]
[Texas Department of Water Resources, Interoffice Memorandum, "Chronological Noncompliance Record for Wyoming Mineral Corporation Permit No. 01942," October 29, 1982]