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DRAFT Minutes

Subpart W Quarterly Conference Call w/ Interested Stakeholders

January 5, 2011 

ATTENDEES

EPA: Reid Rosnick, Angelique Diaz 

CCAT: Sharyn Cunningham, Paul Carestia, Anita (?), Lynn (Holtz) Minasi, Kay Hawklee 

Industry: Oscar Paulson (Kennecott), Josh Leftwich (Cameco), Katie Sweeney (NMA), Jim Cain 

(Cotter), John Cash, Penny Goppler (Ur Energy), Tom Pout & Nick Billstein (Strathmore) 

Sarah Fields (Uranium Watch) 

Steve Brown (SENES) 

Jan Johnson (Tetratech) 

Travis Stills, Energy Minerals Law Center 

Reid: Overview of what we’ve been working on since last conference call 

Risk Assessment from Contractor 

 Workgroup comments due 1/18/2011. March/April for final document. Peer review 

process when finalized 

 Oscar: when peer reviewed, will the group that peer reviews this be the same group 192 

was soliciting nominations for? Reid – possibly, but we haven’t solicited nominations 

yet for Subpart W. 

 Oscar: When contractor did the risk assessment, what input was considered in the risk 

assessment? Were epidemiological studies by John Boice (?) of Vanderbilt used? Reid – 

don’t believe they were included. Described the data used and the acceptable risk from 

previous study. Update – Reid has located a paper co-authored by Dr. Boice titled 

“Cancer incidence and mortality in populations living near uranium milling and mining 

operations in Grants, New Mexico, 1950-2004.” I would be interested in knowing if this 

is the study Oscar mentioned.

 Paul: Cotter assumptions are “wrong and absurd” – majority covered by water was the 

assumption 

 Jim: Wasn’t contacted by contractor 
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 Oscar: Data from 1969 exists. Provided substantial data to S. Cohen. 

 Steve: GEIS for ISL from NRC has an “excellent summary” 

 Basically, everyone is saying that actual site-specific data should be included. 

 Oscar: concerned about the validity of the data. He said he sent Reid corrected data for 

the Sweetwater site. 

 Steve: there needs to be an opportunity for the site operators to comment on the validity 

of the data. Reid – that opportunity will be given 

 Travis: data should be on website. Reid – Document is in draft form and comments from 

workgroup must be addressed. Nothing will go on website that doesn’t reflect current 

ideas. Travis: just the data should be available to the public and thinks per the agreement 

the data should be on the website. Reid – spirit and intent of consent agreement being 

followed, but we want to make sure what is on the website is valid and not misleading. 

 Process for Peer Review: Internal nomination process but reviewers may not be internal. 

Oscar – EPA put together a 40 CFR part 192 peer review group and in that case there was 

a solicitation in the FR for nominees from the public. Reid – that may be the route that 

we take, Reid will take to management. 

Economic Impact Analysis 

 Katie: how can we know the benefits and impacts if we don’t know what is proposed? 

Reid – about to say that progress is slow for this document because we don’t have all the 

necessary data yet. 

 Economist on staff (Val Anoma) has taken over the contract 

National Academy of Sciences Committee on U Mining in Virginia 

 Reid – summary of committee’s role 

 Oscar – Texas data will be applicable to Virginia because of the high moisture 

 Travis – encouraging that we are looking at relationship between mining and milling and 

we should be looking at Subpart B revision and cumulative sources should be looked at. 

Hope we are looking at both from a rulemaking perspective. Reid – Subpart B is a 

separate and distinct regulation and in the review/revision of Subpart W we won’t be 

addressing Subpart B in this rulemaking. 

 Sarah – in Paradox valley we have a proposed uranium mill with a surface mining 

operation (Cotter) and under Rad NESHAPs there is no standard for Rn released from 

surface mining operation, thinks that in Subpart W should take into consideration the 

radon from uranium mines in the vicinity of the uranium mill. 

 Travis – widely held view that regulations as they stand do not protect resources, human 

health and the environment as required by the CAA. Thinks that as they stand the 

provisions of other Subparts are in sufficient. 
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 Sarah – thinks we should also look at particulate emissions from other sources at the mill 

and we should look at all radionuclide sources from a mill when considering risks from 

radon. Should look at the whole operation and what the community is being exposed to. 

 Oscar – particulate emissions already regulated under AEA by NRC under 10 CFR Part 

20, specifically related to dose limits to general public and nearest resident. 

 Steve – 100mrem/yr includes particulates and radon in NRC regulations 

 Reid – Particulates already accounted for and not included as part of Subpart W review 

Reid’s Follow-ups 

 Why Cotter not contacted (will verify if S. Cohen spoke with CDPHE or NRC) Update: 

As soon as funding is in place, SC&A will be contacting Cotter and open dialogue with 

Kennecott. Others are invited to share data.

 Peer review information/process. Update: Management will be making a determination 

on whether the peer review will be internal or external.

 Exploring issue of impoundments in area where precipitation exceeds evaporation Oscar 

– look at two conventional operations in Washington where there is substantial 

precipitation (in Eastern Washington) Jim Cain – where was meteorological data 

obtained? Cotter has data. 

 Travis – inadequacies in Subpart A expressed, namely the lack of a public comment 

requirement - Reid – if we had sufficient resources we’d look at NESHAP Subparts A, B, 

etc. now. As such, those portions will have to wait. 

Next call. 4/7/2011, 11am EST