It's pretty poorly worded legislation, and it would be easy enough to fudge the numbers during the early exploration phase to keep the potential average below 100pmm (ie by 'exploring' a larger area that doesn't contain U to keep the overall average down). But as soon as you have a JORC compliant resource, and especially a reserve, then hiding the fact that what you intend to mine is above 100ppm would be very difficult to do. They could always just selectively assay for U, but I don't know how long they'd get away with that for.
Draft Proposal for near zero tolerance, page-4
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