A.

COGEMA

October 8, 2008

Attn: Charles Garlow, Attorney-Advisor

OECA, Air Enforcement Division

U.S. Environmental Protection Agency

1200Pennsylvania Ave, N.W. - MC 2242A

Washington, DC 20460

Dear Mr. Garlow:

Enclosed please find our response to the Request to Provide Informition Pursuant to the

Clean Air Act as discussed in the EPA letterto COGEMAMining, mc. dated September

2, 2008, signed by Adam Kushner, Director Air Enforcemeqt Divis on. As we discussed

on September 30, 2008, and confirmed through an exchange of e-IIJail on the same date,

we are responding to the first three questions of Appendix B to the ~eferencedEPA letter,

to be followed in November with the balance of the informationrecuested. Your

cooperation on this matter is appreciated.

We are perplexed by the EPA request for information on in situ lea,~huranium recovery

ponds in the context of 40 CFR Part 61, SubpartW. It has always Jeen the

understanding of COGEMAMining and affiliated firm Pathfinder l.1inesCorporation

that the intent of Subpart W was to regulate radon releases from CO!lventionaluranium

milling solid tailings piles or ponds. Pathfinder Mines compliedwith Subpart W in 1990-

1992 by conducting, as required, annual radon flux tests at its Luck'{Mc or ShirleyBasin

conventional milling sites in Wyoming. Both sitesthen went into f.nal decommissioning,

foregoing further testing until the completion of the tailings radon tarrier placement,

pursuant to Appendix A of 10CFRPart 40. Upon completion oftle radon barrier

placement at each site, final radon flux testing was conducted (solu ion Pond 3 at Shirley

Basin remains open since it is utilized for 11(e)(2)byproduct waste disposalfrom certain

in situ leach facilities -the activity is licensed by the U.S. Nuclear ltegulatory

Commission).

Duringthe 1990-1992radonfluxtesting, representativesfromEPj I.Region8 were

involved in the establishment of the sampling protocols at both Lucky Mc and Shirley

Basin. While there were questions from EPA regarding the appropriatenessof proposed

solid tailings pond units for sampling,there was never any questior about the fact that

solution-only ponds were not sampled. There was at that time COll(urrence between EPA

Region 8 and Pathfinder Mines regarding what type of tailings mat ~ria1was being

regulated under Subpart W and hence required radon flux testing:lolid tailingsl

COGEMA Mining, Inc.

935 Pendell Blvd.. P.O. Box 730. Mills. WY 82644 - Tel. ; (307) 234-5019 - Fax: (307) 473-7306
Letter, T. Hardgrove, COGEMA Mining Inc., to C. Garlow,EPA, October 8,200:1, page 2.

generated by conventional mill ore grinding and uranium extraction ITomthat processed

ore. Solutionpondsat bothsiteswereappropriatelyexcludedITom.:hesampling

protocol.' The logical inference is that ISL solution ponds are similarly not subject to the

Subpart W standard and attendant sampling protocol.

Included with this submittal is a certification signed by the General\1anager for

COGEMA Mining, Inc, and Pathfmder Mines Corporation,Mr. Bemard Bonifas. If you

have any questionsregarding the submitted information, do not hesitate to contact me.

;;:'/Z~

Tom Hardgrove

Manager, Environmental andRegulatory Affairs

EncIs.

Cc: Andrew M. Gaydosh, U.S. EPA Region 8

T. Pennington, AREVA NC

B. Bonifas

A
COGEMA Mining, Inc. & Pathfinder Mines Corp.

Appendix B Response to EPA Inquiry Dated September2, 2008.

Submitted to EPA October 8, 2008

Prepared by T. Hardgrove, Manager, Environmental and Regulator:' Affairs.

1) Pathfinder Mines Corporation, an affiliated corporation to ( OGEMA Mining,

Inc., Conventional Uranium Mill and Tailings Facilities:

(see enclosed location maps)

a. Lucky Mc Mill and Tailings

Located in SEY4Section 9, SWY4Section 10,W~ S~ction15,E~ Section

16, NEY4Section 21, and Section 22, T33N, R90W: Wyoming.

b. ShirleyBasin Mill and Tailings

Located in Section 27 and the E~ Section 28, T28N, R78W, Wyoming.

Information provided by T. Hardgrove and R. Owens.

2) COGEMA Mining, Inc. (COMIN) Uranium In-situ LeachingFacilities:

(see enclosed location maps)

a. Irigaray Mine -

Plant and Evaporation/HoldingPonds located in E~ Section 8 and W~

Section 9, T45N, R77W, Wyoming.

b. Christensen Ranch SatellitePlant

Plant and Evaporation/HoldingPonds located in Section 7, T44N R76W,

Wyoming.

c. Holiday/EI Mesquite Plant and Ponds

Located at N 27.41656° W 098.75465°, in south TeJ:as.

d. O'Hem Satellite Plant and Ponds

Located at N 27.39381° W 098.80412°, in south TeJ:as.

e. West Cole Satellite Plant and Ponds

Located at N 27.46099° W 098.84441°, in south TeJ:as.

Information provided by T. Hardgrove,R. Owens, and J. V,Lsquez.

3) Information on each facility listed in items 1 and 2:

Conventional Uranium Mill and Tailings FacilitiesLuckyMcMillandTailingsa) Status: permanently shut down and decomn issioned.

Method of Operation: Not applicable (operations ceased in

1991).
-n - -- - n -- n - n_-_n___- -_n_- -_n. _n -- ------

CERTDnCATIONSTATEMENT

Concerning the Appendix B Responses (responsesto questions 1 through 3) submitted to

EPA on October 8, 2008,

I certify under penalty of law that I have examined and am familiar Niththe information

in the enclosed documents, including all attachments. Based on my inquiry of those

individuals with primary responsibility for obtaining the informatiOll,I certify that the

statements and information are, to the best of my knowledge and be jef, true and

complete. I am aware that there are significant penaltiesfor knowirgly submitting false

statements and information, including the possibility of fines or im~risonmentpursuant to

section 113(c)(2)of the Act, and 18D.S.C. §§ 1001and 1341.

ocl 3" ~~ Date
COGEMA Mining, Inc. & Pathfinder Mines Corp. Appendix B Response to EPA Inquiry Dated September

2, 2008. Submitted October 8, 2008.

Methods by which compliance assured: Site went into

decommissioning status in late 1991. Subse~uently, tailings piles

were reclaimed consistent with 10CFR 40 A?pendixA. Final

radon flux test performed after placement of.:adon barrier.

Average flux was lessthan 0.8 pCi/m2/sec.

b) History of operation:

i) Originalmill construction date: 1958. Solid tailings ponds

constructed approximately 1958(Ponj 1), 1969(Pond 2),

and 1980(pond 2A).

ii) Plan of operation: Operationswere ITore or less continuous

from 1975through 1985when produc:tionwas inteITUpted

to renovate the mill. Production restarted in late 1987 and

continued for approximately six momhs (into 1988)when

the operationwent on standby until h:te 1991.

iii) Ownership changes: Facility change(. 80% of ownership

from General Electric to COGEMA b 1982with the

remaining 20% acquired from GE in 1987. The corporate

parent name only subsequently changed from COGEMA to

AREVA in 2006).

iv) Facility status: decommissioned,currentlyawaiting

permanent transfer to U.S. Departmeat of Energy long term

stewardship.

c) Size of tailings impoundments: Pond 1 = ciOacres; Pond 2 = 77

acres; Pond 2A = 76 acres; Solution Pord 3 = 11 acres; and

Solution Pond 4 = 52 acres. No liners unjer any of the ponds.

Decommissioned ponds have zero capacit:,. Ponds are located

immediately north of the former mill site, ex:ending some 9,100

feet south to north.

d) Pond 1:

1.

11.

111.

iv.

Pond 2:

i.

11.

iii.

IV.

Construction date: 1958.

Solid tailings placement date(s): 1958- 1970 with

minor additions in 1987-88.

Date of placement on standby: I' )88.

Closure date: 1991.

Construction date: 1969.

Solid tailings placement date(s): 1970 - 1980.

Date of placement on standby: I'>80(although interim

earthen cover was progressively jnstalled over the

tailings during the 1980's).

Closure date: 1991.

2
COGEMA Mining, Inc. & Pathfmder Mines Corp. Appendix B Response to EP.AInquiry Dated September

2, 2008. Submitted October 8, 2008.

Pond 2A:

1.

11.

111.

IV.

Construction date: 1980.

Solid tailings placement date(s): 1980 - 1988.

Date of placement on standby: 1~188.

Closure date: 1991.

Pond 3 (Solution only):

i. Construction date: 1960.

ii. Solid tailings placement date(s): N/A.

iii. Date of placement on standby: 1~188.

iv. Closure date: 1991

Pond 4 (Solution only):

i. Construction date: 1963(Dam re ;onstructed in 1980-

81).

Solid tailings placement date(s): N/A.

Date of placement on standby: l~t88.

Closure date: 1991

11.

iii.

IV.

Information provided by T. Hardgrove and R. Owens.

Shirley Basin Mill and Tailingsa) Status: permanently shut down and decommissionedwith the

exception of the Pond 3 area which is curren ly utilized as a

licensed 11(e)(2) byproduct material disposal area pursuant to 40

CFR 192.32(a)(3)(iv).

Method of Operation: Not applicable (opera:ions ceased in

June, 1992).

Methods by which compliance assured: Site went into

decommissioning status in 1992. Subsequently,solid tailings

piles were reclaimed consistent with 10 CFR 40 Appendix A.

Final radon flux test performed after placemc:ntof radon barrier

over solid tailings ponds and mill site/ore pall. Average flux was

3.46 pCi/m2/sec.

b) History of operation:

i) Originalmill construction date: 1970.1971. Solid tailings

ponds constructed 1969(pond 4), and 1976 (pond 5).

The solution only Pond 3 was constn lctedapproximately

1969-1970.

ii) Plan of operation: Conventionalmill.ng operations were

more or less continuousfrom 1970until 1992when

production permanently ceased.

iii) Ownership changes: Facility changed 80% of ownership

from General Electric to COGEMA it11982with the

remaining 20% acquired from GE in 1987. The corporate

3
COGEMA Mining, Inc. & Pathfmder Mines Corp. Appendix B Response to EPA Inquiry Dated September

2, 2008. Submitted October 8, 2008.

parent name only subsequently chang~dfrom COGEMAto

AREVA in 2006).

iv) Facility status: mill and solid tailing~ponds

decommissioned; solution pond 3 art a currently utilized

for 11(e)(2) byproduct material dispo::al.

c) Size of tailings impoundments: Pond 3 = 3.~acres; Pond 4 = 162

acres; Pond 5 = 144 acres. No liners uncler any of the ponds.

Decommissioned ponds have zero capacitr. Pond 3 basin has

theoretical liquid capacity, but is not utilized for solution

storage. Ponds are located immediately northwest of the former

mill site.

e) Pond 3:

1.

11.

111.

IV.

Pond 4:

i.

11.

111.

IV.

Pond 5:

1.

v.

VI.

V11.

Construction date: 1969-1970.

New tailings continuous placement date(s): not

applicable.

Date of placement on standby: n<Itapplicable.

Closure date: not applicable.

Construction date: 1969.

New tailings continuous placement date(s): 1970-

1976.

Date of placement on s!andby: 1~176(used for excess

solution storage during the balance of the operational

life of the mill).

Closure date: 1992.

Construction date: 1976.

New tailings continuous placemelt date(s): 1976-

1992.

Date of placement on standby: nt)t applicable.

Closure date: 1992.

Information provided by T. Hardgrove and R. Owens.

In-situ Leaching FacilitiesIrigaray Mine -

a) Status: standby.

Method of Operation: Not applicable (no so.id tailings - solution

ponds only).

Methods by which compliance assured: CO:\1INinterprets 40

CFR 61.252 as applicable to conventionaluranium mills that

4
COGEMA Mining, Inc. & PathfInderMines Corp. Appendix B Response to EPA Inquiry Dated September

2, 2008. Submitted October 8, 2008.

generate solid tailings and not to solution por.ds. Solution ponds at

in situ operations have an assumed radon flm: of zero (see Part 61,

Appendix B, Method 115).

b) History of operation:

i) Original plant construction date: 197:: - 1979. Evaporation

ponds constructed 1978-1979(Ponds A, B, C, D, and E),

and 1979(Ponds RA and RB).

ii) Plan of operation: Operationswere i:iltiated in 1979 and

continued with some interruptions un il 1990when mining

operations were terminated. From 1990to 2002 active

aquifer restoration was ongoing. Dur.ngthat period the

restoration process relied upon the co Itinued use of the

evaporationponds. Upon completion of aquifer restoration

and post-restorationaquifer monitoring, five of the seven

evaporationponds underwent partial,lecommissioning

beginning in June, 2003, involving th ~removal of

contaminated sediments,the Hypalon liners, the underdrains and leak detection systems, anll any other

contaminated soils. The contaminate,i soils were sent to

the ShirleyBasin 11(e)(2) disposal si1e. The remaining

ponds (B and RB) are intact and cum ntly hold solution

(from natural precipitation, as periodically augmented to

assure coverage of the bottom sediments with water).

iii) Ownership changes: The facility is O'wed by Malapai

Resources Company, an Arizona cOll'orationwhich is a

wholly-owned subsidiary of Fuel International Trading

Corporation (FITCO), a Delaware Ccrporation. Electricite

de France (EDF), a major French util ty company acquired

MalapaIFITCOin 1990. Malapai ent~redinto a Joint

Participation with Total Minerals C01l1pany(TOMIN)in

1990whereby TOMIN became operator of the property.

COGEMA, a French corporation, acquired TOMIN in 1993

and changed the name to CogemaMimng,Inc. COGEMA

became AREVA NC, Inc. in 2006. 1he property is

currently owned by MalapaiResourc'~sCompany and

operated by CogemaMining, Inc. Tl.e property is

. ,,",,l~~neficiallyowned71% by AREVA md29% byEDF.

iv) Facility status: on standby;"portionsI)fthe plant have been

decommissioned. Remaining plant fidlities consist of the

"back end" of the processing, involvilg resin elution,

precipitation, and concentrate drying!packaging. An

amendment of the NRC license was ~pproved by the NRC

on 9/30/08 to allow a resumption ofl'foduction at

ChristensenRanch which would enta IIthe restart of some

5
COGEMA Mining, Inc. & Pathfmder Mines Corp. Appendix B Response to EPA Inquiry Dated September

2, 2008. Submitted October 8, 2008.

plant activities at lrigaray. However, no startup date has

been established at this point.

c) Size of evaporationponds:

Pond Surface area (ac.)

A 1.43

B 1.44

C 1.43

D 1.44

E 0.57

RA 2.75

RB 2.98

Dimensions(ft}

160 x 390

250 x 250

160 x 390

250 x 250

100 x 250

260 x 460

250 x 520

Capacity (gal.)

2,052,861

2,052,861

2,052,861

2,052,861

879,798

6,451,850

6,451,850

Ponds A through D are located immediately southwest of the plant

site. Pond E is located immediately east of the plant, and Ponds RA

and RB are immediately north of the plant.

d) Dates of pond construction and use: .

Pond Constr. Use Period Date to Stanlfuy

A 1978-79 1979-2002 Not Applica)le

B 1978-79 1979-2002 2003

C 1978-79 1979-2002 Not Applica)le

D 1978-79 1979-2002 Not Applica')le

E 1978-79 1979-2002 Not Applica")le

RA 1979 1979-2002 Not Applicahle

RB 1979 1979-2002 2003

Current Status

Partial Decomm.

Standby

Partial Decomm.

Partial Decomm.

Partial Decomm.

Partial Decomm.

Standby -

Information provided by T. Hardgrove,R. Owens, D. AndeJ'son,and L. Arbogast

Christensen Ranch Satellite Facility -

a) Status: standby.

Method of Operation: Not applicable (no so:id tailings - solution

ponds only).

Methods by which compliance assured: CO]viINinterprets 40

CFR 61.252 as applicable to conventionalur mium mills that

generate solid tailings and not to solution pOJids. Solution ponds at

in situ operationshave an assumed radon flue of zero (see Part 61,

Appendix B, Method 115).

b) History of operation:

i) Original plant construction date: 198~- 1989. Evaporation

ponds CR-1 and CR-2 constructed lS88 -1989; ponds CR-3

and CR-4 constructed 1996. The per:neate pond was

constructed in 1988.

ii) Plan of operation: Operationswere itritiatedin 1989and

continued until 2000 when mining OJerations were

6
unn_- --- n______--------

COGEMA Mining, Inc. & Pathfmder Mines Corp. Appendix B Response to EP.AInquiry Dated September

2, 2008. Submitted October 8, 2008.

tenninated. From 2000 to 2005 activ,~aquifer restoration

was ongoing. During that period the :estorationprocess

relied upon the continued use of the evaporationponds.

Since completion of aquifer restoraticn in 2005, the four

evaporation ponds have been on stan<lbywith periodic

clean water additionsto maintain wat~rlevels over the

bottom sediments. The permeate pond is an unlined

structure that exclusively stores very ,~leanpermeate water

that was generatedby the aquiferrest )ration reverse

osmosis process in the plant. All ope :ationsare on

standby; an amendment of the NRC lcense to allow a

resumption of operations was approv,:dby the NRC on

9/30/08, but no startup date has been ietermined.

iii) Ownership changes: The facility is 4)wnedby Malapai

Resources Company, an Arizona c01]lorationwhich is a

wholly-owned subsidiary of Fuel International Trading

Corporation (FITCO), a Delaware Ccrporation. Electricite

de France (EDF), a major French util ty company acquired

Malapa/FITCO in 1990. Malapai ent~redinto a Joint

Participation with Total Minerals COJapany (TOMIN) in

1990whereby TOMIN became operator of the property.

COGEMA, a French corporation, acquired TOMIN in 1993

and changed the name to CogemaMi1ing,Inc. COGEMA

became AREVA NC, Inc. in 2006. 1 he property is

currently owned by Malapai Resourc,:sCompany and

operated by Cogema Mining, Inc. He property is

beneficially owned 71% by AREVA md 29% by EDF.

iv) Facility status: on standby; a resumption of operationsis

planned but no startup date has been: ;et at this time.

c) Size of evaporationponds:

Pond Surface area (ac.)

CR-l 0.92

CR-2 0.92

CR-3 0.92

CR-4 0.92

Perm. 1.6

Dimensions(ft,}

100 x 400

100 x 400

100 x 400

100 x 400

160 x 440

Capacity (gal.)

1,795,439

1,795,439

1,795,439

1,795,439

8,472,100

All of the ponds are located immediately south of the plant. Ponds

CR-l through CR-4 are lined with Hypalon. As noted above, the

permeate pond is unlined due to the very cle.L1lwater it stores.

7
COGEMA Mining, Inc. & Pathfinder Mines Corp. Appendix B Response to EPf. Inquiry Dated September

2, 2008. Submitted October 8, 2008.

d) Dates of pond construction and use:

Pond Construction Use Period Date to S'andbv Current Status

CR-1 1988-1989 1989-2005 2005 Standby

CR-2 1988-1989 1989-2005 2005 Standby

CR-3 1996 1996-2005 2005 Standby

CR-4 1996 1996-2005 2005 Standby

Perm. 1988 1989-2005 2005 Standby

Information provided by T. Hardgrove,R. Owens,D. Ande1son,and L. Arbogast.

Holiday-EI Mesquite Facilitya) Status: decommissioning.

Method of Operation: Not applicable (no so]id tailings- solution

ponds only).

Methods by which compliance assured: COJ.1INinterprets 40

CFR 61.252 as applicable to conventionalur.miummills that

generate solid tailings and not to solution p01lds. Solution ponds at

in situ operations have an assumed radon flu:::of zero (see Part 61,

Appendix B, Method 115).

b) History of operation:

i) Original plant construction date: 197'}. Evaporation pond

HEM North Pond constructed 1978; HEM South Pond

constructed 1981;HEM Backwash Pit and Chemical Sump

constructed 1979. The HEM North ald South Ponds were

lined with Hypalon; the backwash pit and chemicalsump

were constructedwith reinforced con~reteand interior

Hypalon liners..

ii) Plan of operation: Operationswere io.itiatedin 1979 and

continuedwith some interruption oot 1 1996when mining

operations were terminated. From 1S96 to 2002 active

aquifer restoration was ongoing. Dilling that period the

restorationprocess relied upon the continueduse of the

evaporationponds. Since the completion of aquifer

restoration all activities have been de votedto the

decommissioningof the plant and att,mdantfacilities.

Upon completion of aquifer restorati<IIIin 2002, HEM

South was dewateredwith decommis:;ioningoccurring in

2005. Decommissioningconsisted o:~theremoval of

bottom sediments,removal of the linc:r,and removal of any

adjacent contaminated soils. All con aminated materials

from the pond decommissioningwen: transported to

Pathfinder's ShirleyBasin site for di~posal. The backwash

pit and chemicalsump were cleaned, mt in 2004 with

contaminatedmaterial transported to ShirleyBasin. The

empty structuresstill exist, but only (.ccasionallyhold

8
-- - -----

COGEMA Mining, Inc. & Pathfinder Mines Corp. Appendix B Response to EPA Inquiry Dated September

2, 2008. Submitted October 8, 2008.

water from rainfall. The HEM North Pond continuesto be

used. It serves as a holding pond for .vatercontaminated

by plant site decommissioning activit.es. The contaminated

water held in HEM North'is eventual]y injected into a

pennitted deep disposal well.

iii) Ownership changes: The facility is o'iVIledby Malapai

Resources Company, an Arizona coq ,orationwhich is a

wholly-owned subsidiary of Fuel InternationalTrading

Corporation (FITCO), a Delaware Ccrporation. Electricite

de France (EDF), a major French util:ty company acquired

Malapa/FITCO in 1990. Malapai ent~redinto a Joint

Participation with Total Minerals Company (TOMIN) in

1990whereby TOMIN became operator of the property.

COGEMA, a French corporation, acquired TOMIN in 1993

and changedthe name to CogemaMi :ring,Inc. COGEMA

became AREVA NC, Inc. in 2006. 1 he property is

currently owned by MalapaiResourci~sCompany and

operated by Cogema Mining, Inc. TIe property is

beneficially owned 71% by AREVA md 29% by EDF.

iv) Facility status: decommissioning.

c) Size of evaporationand other ponds:

Pond Surface area (ac.) Dimensions(ft,}

HEM N. 0.92 200 x 200

HEM S. 0.92 200 x 200

Back W. 0.115 100x 50

Chm. Sump 0.115 100 x 50

Capacity (gal.)

2,300,000

1,725,000

299,000

299,000

All of the ponds were located in the immedi,te vicinity of the

plant. Pond HEMNorth is lined with HypaJon. The backwash pit

and chemicalsump are constructed of reinfo:'ced concrete. As

noted above, pond HEM South is decommi)sioned.

d) Dates of pond construction and use:

Pond Construct. Use Period Date Stn:lbv

HEM N. 1978 1979-present NA

HEM S. 1981 1981-2002 NA

Back W. 1979 1979-2002 NA

Chm. Sump 1979 1979-2002 NA

Current Status

In use

Decommiss.

Partly Decomm.

Partly Decomm.

Information provided by T. Hardgrove,B. Bonifas, D. Andc:rson,and D.

Benevides.

9
COGEMA Mining, Inc. & Pathfmder Mines Corp. Appendix B Response to EPA Inquiry Dated September

2, 2008. Submitted October 8, 2008.

O'Hem Facility -

a) Status: decommissioned.

Method of Operation: Not applicable (no so]idtailings - solution

pond only).

Methods by which complianceassured: CO~,fINinterprets 40

CFR 61.252 as applicable to conventionalur:miummills that

generate solid tailings and not to solution pmlds. Solution ponds at

in situ operationshave an assumed radon flru:of zero (see Part 61,

Appendix B, Method 115).

b) History of operation:

i) Original plant construction date: 197:;. Evaporation pond

with Hypalon liner constructed 1976.

ii) Plan of operation: Operationswere i litiated in late 1975

and continued until 1989when minin~operations were

terminated. From 1989to 1997 activ,~aquifer restoration

was ongoing. During that period the ~estorationprocess

relied upon the continued use of the evaporation pond.

Upon completion of aquifer restoraticn in 1997,the pond

was on standby (pending regulatory approvalof

restoration), and was decommissionellin 2001.

Contaminatedmaterials and liner wet e removed for

disposal at ShirleyBasin. Upon fmal release, the remnant

excavation was backfilled.

iii) Ownership changes: The facility is o'm1edby Malapai

Resources Company, an Arizona cOIJ,orationwhich is a

wholly-owned subsidiary of Fuel International Trading

Corporation (FITCO), a Delaware Ccrporation. Electricite

de France (EDF), a major French uti!:ty company acquired

Malapa/FITCO in 1990. Malapai ent~redinto a Joint

Participation with Total Minerals Company (TOMIN) in

1990whereby TOMIN became operator of the property.

COGEMA, a French corporation, acquired TOMIN in 1993

and changed the name to CogemaMi:ling,Inc. COGEMA

became AREVA NC, Inc. in 2006. 1 he property is

currently owned by MalapaiResourcl:SCompany and

operated by CogemaMining, Inc. n e property is

beneficially owned 71% by AREVA md 29% by EDF.

iv) Facility status: decommissioned.

c) Size of evaporationpond:

Pond Surface area (ac.)

O'Hem 0.34

Dimensions (ftJ

132 x 112

Capacity (gal.)

461,000

The pond was located immediately adjacent' 0 the now

decommissionedplant.

10
COGEMA Mining, Inc. & Pathfmder Mines Corp. AppendixB Response to EPA Inquiry Dated September

2, 2008. Submitted October 8, 2008.

d) Dates of pond construction and use:

Pond Construction Use Period Date to S1andby Current Status

O'Hem 1976 1976-2000 NA Decommiss. '

Information provided by T. Hardgrove,B. Bonifas, D. Anderson, and D.

Benevides.

West Cole Facilitya) Status: decommissionedand released to unn:stricted use.

Method of Operation: Not applicable (no so]id tailings- sol.ution

ponds only).

Methods by which complianceassured: COlInN interprets 40

CFR 61.252 as applicable to conventionalurimiummills that

generate solid tailings and not to solution pOILds.Solution ponds at

in situ operations have an assumed radon fl~~ of zero (see Part 61,

Appendix B, Method 115).

b) History of operation:

i) Original plant construction date: 1981).Two evaporation

ponds (West Cole North and West C<.}eSouth)were

constructed with Hypalon liners in 1S80.

ii) Plan of operation: Operationswere i litiated in 1981 and

continuedwith interruptionuntill98~ Iwhen mining

operations were terminated. From 1989to 2003 active

aquifer restoration was ongoing. Duringthat period the

restoration process relied upon the cotltinueduse of the

evaporationponds. Upon completior of aquifer restoration

in 2003, the two ponds were subjectt) decommissioning.

The decommissioningwas accomplishedin 2004. All

contaminatedmaterials and liners we :eremoved for

transport to ShirleyBasin for disposal. The pond sites were

then backfilled with clean soil. After the successful

completion of all plant and ancillary: acilities

decommissioning,the West Cole pro:>ertywas formally

released for unrestricted use.

iii) Ownership changes: The facility is 0 NIledand operated by

CogemaMining, Inc. (previously narled Total Minerals),

which is owned by AREVA NC, Inc., a Delaware

corporation,which is owned by AREVA, a French

corporation. Due to the decommissicned and released

status of the West Cole site, COGEMA Mining, Inc. has

little remaining legal obligation for tl.e site. There are two

wells that provided clean water to the site that still have to

be plugged and abandoned, and there is an access gate that

must be removed.

11
COGEMA Mining, Inc. & Pathfmder Mines Corp. Appendix B Response to EPP.Inquiry Dated September

2, 2008. Submitted October 8, 2008.

iv) Facility status: decommissioned and released to

unrestricted use.

c) Size of evaporationponds:

Pond Surface area (ac.) Dimensions(ft.) Capacity (gal.)

WC N. 0.23 100 x 100 301,195

WC S. 0.23 100 x 100 301,195

All of the ponds were located in the immediate vicinity of the

plant.

d) Dates of pond construction and use:

Pond Construction Use Period Date to S':andbvCurrent Status

WC-N. 1980 1981-2003 NA Decommiss.

WC-S. 1980 1981-2003 NA Decommiss.

Information provided by T. Hardgrove,B. Bonifas, D. And{rson, and D.

Benevides.

4) Additional Information: TO BE SUBMITTEDBY NOVE:vfBER8, 2008.

12
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