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### Subpart W Public Quarterly Conference Call
July 6, 2010

Attendees

Reid Rosnick Angelique Diaz

Paul Carestia (CCAT) Sharyn Cunningham (CCAT) Sarah Fields (Uranium Watch)

Oscar Paulson (Kennecott) Scott Charmin (Uranium One) Joe Brisner(?) (Cameco Resources) Larry Teahon (Cameco Resources - Crowe Butte)

Jan Johnson (Tetratech)

Reid – Update

 Presentations over the past 3 months

o White Mesa Subpart W – while there t oured the White Mesa Mill (on Website)

o NMA/NRC Uranium Recovery Works hop presentation on Subpart W (on Website)

o Webinar similar to face to face presentations made (on process and issues when revising rule) – will be posted on the web, along with questions and answers.

 E-mail address added to the websit e, specific to Subpart W work ( subpartw@epa.gov ). Body of e-mail will be posted to website, without names. Reid will do his best to reply to e-mails but may not be able to respond to all of them.

 Automatic notifications of newly posted items

 Contractor Work Assignments

o Comparison of new risk assessment to previous risk assessment.

 In the process of getting the work assignment approved.

 Contractor in process of putting together QA plan

 Will be on website

 Evaluating best code (model) for perf orming risk assessment, then will

move on into the risk assessment

o Economic Impact Analysis – contractor will gather data to complete this

 Includes EJ, Children’s Health, etc.

 Status – not directly overseen by Reid, moved to a staff economist

 Within the month into contracts administration and on to approval

 Radon Flux at ISL Evaporation Ponds

o Data not up, and hope to have it up in the next few weeks

o Draft documentation and data show that there is radon flux from evaporation ponds from ISL facilities, but there is no exceedance of current standard

o Document will explain the process, incl uding the calculations, explanation of what we did, etc.Page 2 of 4 Questions/Discussion Oscar Paulson: “Final Report Review of ...Technol ogies” – sent Reid a m eeting on 6/3 regarding some discrepancies in the data in the report compared to Kennecott Sweetwater.

Reid: Had a brief conversation with the contractor. Contractor is aw are of the issue. Reid needs to get back to the contractor.

Oscar: Kennecott has extensive data on Ra-226 in tailings and the S. Cohen report does not agree with those numbers.

Reid: Will get back to the Contractor

Joe Brisner: Is the contractor all the same and who is it?

Reid: Harry Pettengill is the contractor manager a nd with S. Cohen. Same contractor for all the assignments

Sarah Fields: Has the applicabil ity of Subpart W to heap leach facilities come up and how is it being addressed?

Reid: Has been EPA’s belief since late 2008 that heap leach would belong under Subpart W. We have had brief discussions among workgroup members on how we would regulate it because more transitory unit than a conventional mill ta ilings impoundment. We will expand the rule to look at three types of units we are looking at: conventional, ISL pond, and heap leach. At this point we feel that different standards will need to be applied to each facility type so that they are as protective. Reid hopes to put the Dr. Bake r paper on charcoal canisters on water on the

website.

Sarah Fields: What type of discussion has EPA had about addressing radon flux from other aspects of conventional mills, such as ponds, contaminated soils, ore pads, etc.

Reid: The question has been asked before and in many instances there are already regulations on the books that cover the emissions you have mentioned.

Sarah: Confirmatory sampling/monitoring – some thing she thinks should be happening by EPA to verify radon flux measurements.

Reid: That is a requirement for “existing im poundments”, annual report includes the data.

Sarah: There is no additional mon itoring of rads at the perimeter

Oscar: 100 mrem/year dose limit to the public ac cording to NRC – which includes radon.Page 3 of 4 Sarah: EPA has to clarify when a tailings impoundment comes out from under the reporting requirements in Subpart W. (Some background on S ubpart T and closure) Two different tailings impoundments, one in UT and one CO where th ere are no reclamation milestones present. Thinks EPA needs to look into rescission of the Subpart T.

Angelique: NRC or the Agreement State is the ove rseeing agency for closure of impoundments.

Oscar: In the case of the Agreement State, th e rules and regulations governing reclamation milestones. The primary responsib ility is the Agreement State.

Angelique: Closure of impoundments and milestones is not relevant for Subpart W, but we will clarify definitions, including “closure” and when impoundments are no longer subject to Subpart

W.

Reid: Subpart T is something we can look at and tuck away for future rulemakings, but at this point we are dealing with operating mills.

Sarah: Brings it up, because the impoundment dries out and emissi ons can increase when closure begins. Can’t just look at Subpart W in isolation.

Reid: We will address your concerns. We w ill look at definitions of closure and satisfy you with respect to your question, in cluding the definition of “final closure” and what requirements should be present prior to final closure.

Paul Carestia: “The fact the releases are ta king place and no one is being held accountable”

Some discussion on how the 100 mrem/year modeli ng is done for 6-month projects. Continuous monitoring for gamma, particulates, and radon, ge nerally at the boundary, but could be closer. Data submitted to NRC/Agreement at the end of each 6-month period.

Paul: Can you see how convoluted these rules are for something that is “so dangerous”. What seems to be done is piecemeal.

Reid: When you are in a situation where there is more than one agency regulating there is the possibility for confusion. By going back thr ough this we are trying to eliminate as much confusion as possible. We have to do what Congre ss tells us to do. We have to try to make it as simple as possible while making it protective. We have a sense of where both the public and industry are on this. We are trying to make this as straight forward as possible.

Paul: Concerns over model and data and accuracy and of both.

Oscar: Security guard on site. When sleeping alongside fence he’s a member of the general public. There are two radtrack detectors in hi s trailer to measure hi s radon dose, it is not modeled. They choose do measure instead of model.Page 4 of 4 Jan Johnson: RSO for Dawn Mining Company (as a contractor from Tetratech) in Washington

State

Sharyn Cunningham: Comment – one of the concer ns we have is that during closure period, when radon is increasing, the radon flux test required may not fall when water is off the impoundment. During review, she hopes we keep in mind that some care needs to be taken to monitor Rn emissions during that closure period. Reid: Valid point.

Next 3 Months (Next Call – Oct 5 2010, 11am EST)

 Reviewing contractor QA plan and QA report on how they will attempt to do the

risk assessment.

 Review of risk assessment model and why from contractor