# 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 EnforcemeqtDivis on. As we discussed on September 30, 2008, and confirmedthrough an exchange of e-IIJ ail on the same date, we are responding to the first three questions of Appendix B to the ~eferenced EPA letter, to be followed in November with the balance ofthe informationrecuested. Your cooperation on this matter is appreciated. We are perplexed by the EPA request for information on in situ lea,~h uranium recovery ponds in the context of 40 CFR Part 61, SubpartW. It has always Jeen the understanding of COGEMA Mining and affiliated firm Pathfinder l.1ines Corporation that the intent of Subpart W was to regulate radon releases from CO! lventionaluranium milling solid tailings piles or ponds. PathfinderMines 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 sites then went into f.nal decommissioning, foregoing further testing until the completion ofthe tailings radon tarrier placement, pursuant to Appendix A of 10 CFR Part 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 disposal from certain in situ leach facilities

# -the activity is licensed by the U.S. Nuclear ltegulatory Commission). 

### Duringthe 1990-1992 radonfluxtesting, representatives fromEP j I.

### Region8 were involved in the establishment ofthe samplingprotocols at both Lucky Mc and Shirley Basin. While there were questions from EPA regarding the appropriatenessofproposed 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 oftailings mat ~ria1 was 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) 473-7306Letter, T. Hardgrove, COGEMA Mining Inc., to C. Garlow, EPA, October 8,200:1, page 2. generated by conventional mill ore grinding and uranium extraction ITom that processed 

### ore. Solution pondsat bothsiteswereappropriately excluded ITom

.

### :hesampling protocol.' The logical inference is that ISL solution ponds are similarly not subject to the Subpart W standard and attendant samplingprotocol. 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 questions regarding the submitted information, do not hesitate to contact me. 

# ;;:'/Z~

Tom Hardgrove Manager, Environmental and Regulatory Affairs EncIs. Cc: Andrew M. Gaydosh, U. S. EPA Region 8 T. Pennington, AREV A NC B. Bonifas 

### ACOGEMA Mining, Inc. & PathfinderMines Corp. Appendix B Response to EP A Inquiry Dated September2, 2008. Submitted to EP A 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 SEY4 Section 9, SWY4 Section 10, W~ S ~ction 15, E~ Section 16, NEY4Section 21, and Section 22, T33N, R90W: Wyoming. b. Shirley Basin 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 Facilities



### LuckyMcMillandTailings

a) 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 (responses to questions 1 through 3) submittedto 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 bejef, true and complete. I am aware that there are significantpenalties for knowirgly submitting false statements and information, including the possibility of fines or im~risonmentpursuant to section 113(c)(2) ofthe Act, and 18 D.S.C. §§ 1001 and 1341. 

# ocl 3" ~~ DateCOGEMA 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 10 CFR 40 A ?pendixA. Final radon flux test performed afterplacement of.:adon barrier. Average flux was less than 0.8 pCi/m2/sec. b) History of operation: i) Original mill construction date: 1958. Solid tailings ponds constructed approximately 1958 (Ponj 1), 1969 (Pond 2), and 1980 (pond 2A). ii) Plan of operation: Operations were IT ore or less continuous from 1975 through 1985 when produc:tion was inteITUpted to renovatethe mill. Production restarted in late 1987 and continued for approximately six mom hs (into 1988) when the operation went on standbyuntil h:te 1991. iii) Ownership changes: Facility change(. 80% of ownership from General Electric to COGEMAb 1982with the remaining 20% acquired from GE in 1987. The corporate parent name only subsequently changed from COGEMA to AREV A 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 = c iOacres; 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 ofthe 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. Solidtailings placement date(s): 1958

- 1970 with minor additions in 1987-88. Date ofplacement on standby: I' )88. Closure date: 1991.

Construction date: 1969. Solid tailings placement date(s): 1970


### - 1980. Date ofplacement on standby: I' >80 (although interim earthen cover was progressivelyjnstalledover the tailings during the 1980's). Closure date: 1991.

2COGEMA 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. Solidtailings placement date(s): N/A. iii. Date ofplacement 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 ofplacement 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 ofthe 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 afterplacemc :ntofradon barrier over solid tailings ponds and mill site/orepall. Average flux was 3.46 pCi/m2/sec. b) History of operation: i) Original mill 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 continuous from 1970until 1992when production permanently ceased. iii) Ownership changes: Facility changed 80% of ownership from General Electric to COGEMA it11982 with the remaining 20% acquired from GE in 1987. The corporate

3COGEMA 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 AREV A in 2006). iv) Facility status: mill and solid tailing~ponds decommissioned; solutionpond 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 ofplacement on standby: n< Itapplicable. Closure date: not applicable.

Construction date: 1969. New tailings continuous placement date(s): 1970- 1976. Date ofplacement on s!andby: 1~176 (used for excess solution storage during the balance ofthe operational life ofthe mill). Closure date: 1992.

Construction date: 1976. New tailings continuous placemelt date(s): 1976- 1992. Date ofplacement on standby: nt)tapplicable. Closure date: 1992. Information provided by T. Hardgrove and R. Owens. In-situ Leaching Facilities

Irigaray 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 applicableto conventionaluranium mills that

4COGEMA Mining, Inc. & PathfInderMines Corp. Appendix B Response to EP A Inquiry Dated September 2, 2008. Submitted October 8, 2008. generate solid tailings and not to solutionpor .ds. Solutionponds at in situ operations have an assumedradon 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: Operations were i:iltiated in 1979 and continued with some interruptions un il 1990when mining operations were terminated. From 1990to 2002 active aquiferrestoration was ongoing. Dur .ngthat period the restoration process relied upon the co Itinueduse ofthe evaporationponds. Upon completion of aquiferrestoration and post-restoration aquifer monitoring, five ofthe seven evaporationponds underwentpartial,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 sentto the Shirley Basin 11(e )(2) disposal si1 e. The remaining ponds (B and RB) are intact and cum ntly hold solution (from natural precipitation, as periodically augmentedto assure coverage ofthe 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 ofFuel 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 ofthe property. COGEMA, a French corporation, acq uired TOMIN in 1993 and changedthe name to CogemaMimng,Inc. COGEMA became AREV A NC, Inc. in 2006. 1 he property is currently owned by Malapai Resourc'~sCompany and operatedby CogemaMining, Inc. Tl.e property is

. ,,",,l~~neficiallyowned 71% by AREVA md29% byEDF. iv) Facility status: on standby;"portions I)fthe plant have been decommissioned. Remainingplant fidlities consist ofthe "back end" ofthe processing, involvilg resin elution, precipitation, and concentrate drying!packaging. An amendment ofthe NRC license was ~ pproved by the NRC on 9/30/08 to allow a resumption ofl'foduction at Christensen Ranch which would entaII the restart of some

5COGEMA Mining, Inc. & Pathfmder Mines Corp. Appendix B Response to EP A 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 ofthe plant site. Pond E is located immediately east ofthe plant, and Ponds RA and RB are immediately north ofthe 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 applicableto conventionalur mium mills that generate solid tailings and not to solutionpOJ ids. Solutionponds at in situ operationshave an assumedradon 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: Operations were itritiatedin 1989 and continueduntil 2000 when mining OJ erations were

6unn_- --- 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 ofthe evaporationponds. Since completion of aquiferrestoraticn in 2005, the four evaporation ponds have been on stan< lbywith periodic clean water additions to maintain wat~rlevels over the bottom sediments. The permeatepond is an unlined structure that exclusively stores very ,~lean permeate water that was generatedby the aquiferrest )ration reverse osmosis process in the plant. All ope :ations are on standby; an amendment ofthe 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)wned by Malapai Resources Company, an Arizona c01]loration which is a wholly-owned subsidiary ofFuel 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 COJ apany (TOMIN) in 1990whereby TOMIN became operator ofthe property. COGEMA, a French corporation, acquired TOMIN in 1993 and changedthe name to CogemaMi 1ing,Inc. COGEMA became AREV A NC, Inc. in 2006. 1 he property is currently owned by Malapai Resourc,:sCompany and operatedby Cogema Mining, Inc. He property is beneficially owned 71% by AREV A md 29% by EDF. iv) Facility status: on standby; a resumption of operations is planned but no startup date has been: ;etat 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 ofthe ponds are located immediately south ofthe plant. Ponds CR-l through CR-4 are lined with Hypalon. As noted above, the permeate pond is unlined due to the very cle.L1l water it stores.

7COGEMA Mining, Inc. & Pathfinder Mines Corp. Appendix B Response to EP f. Inquiry Dated September 2, 2008. Submitted October 8, 2008. d) Dates ofpond 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.1IN interprets 40 CFR 61.252 as applicableto conventionalur.miummills that generate solid tailings and not to solution p01lds. Solutionponds at in situ operations have an assumedradon 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 chemical sump were constructedwith reinforced con~reteand interior Hypalon liners.. ii) Plan of operation: Operations were i o.itiated in 1979 and continuedwith some interruption oot 1 1996when mining operations were terminated. From 1S96 to 2002 active aquiferrestoration was ongoing. Dilling that period the restorationprocess relied upon the continueduse ofthe evaporationponds. Sincethe completion of aquifer restoration all activities have been de votedto the decommissioningofthe plant and att,mdantfacilities. Upon completion of aquiferrestorati< III in 2002, HEM South was dewateredwith decommis:;ioning occurring in 2005. Decommissioning consisted o:~the removal of bottom sediments,removal ofthe linc:r,and removal of any adjacent contaminated soils. All con aminated materials from the pond decommissioningwen: transported to Pathfinder's Shirley Basin site for di~ posal. The backwash pit and chemical sump were cleaned, mt in 2004 with contaminatedmaterial transported to Shirley Basin. The empty structures still exist, but only (.ccasionallyhold

8-- - -----

COGEMA Mining, Inc. & Pathfinder Mines Corp. Appendix B Response to EP A Inquiry Dated September 2, 2008. Submitted October 8, 2008. water from rainfall. The HEM North Pond continues to 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'iVIled by Malapai Resources Company, an Arizona coq ,orationwhich is a wholly-owned subsidiary ofFuel 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 ofthe property. COGEMA, a French corporation, acq uired TOMIN in 1993 and changedthe name to CogemaMi :ring,Inc. COGEMA became AREV A NC, Inc. in 2006. 1 he property is currently owned by Malapai Resourci ~s

Company and operatedby Cogema Mining, Inc. TIe property is beneficially owned 71% by AREV A md 29% by EDF. iv) Facility status: decommissioning. c) Size of evaporation and otherponds: 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 ofthe ponds were located in the immedi,te vicinity ofthe plant. Pond HEM North is lined with HypaJ on. The backwash pit and chemical sump are constructed of reinfo:'ced concrete. As noted above, pond HEM South is decommi )sioned. d) Dates ofpond 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.

9COGEMA Mining, Inc. & PathfmderMines Corp. Appendix B Response to EP A 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~,fIN interprets 40 CFR 61.252 as applicableto conventionalur:miummills that generate solid tailings and not to solutionpmlds. Solutionponds at in situ operationshave an assumedradon 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: Operations were i litiated in late 1975 and continueduntil 1989 when minin~operations were terminated. From 1989to 1997 activ, ~aquiferrestoration was ongoing. During that period the ~estoration process relied upon the continueduse ofthe evaporation pond. Upon completion of aquiferrestoraticn in 1997,the pond was on standby (pending regulatory approvalof restoration), and was decommissionellin 2001. Contaminatedmaterials and liner wete removed for disposal at Shirley Basin. Upon fmal release, the remnant excavation was backfilled. iii) Ownership changes: The facility is o'm1ed by 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 ofthe property. COGEMA, a French corporation, acquired TOMIN in 1993 and changedthe name to CogemaMi :ling,Inc. COGEMA became AREV A NC, Inc. in 2006. 1 he property is currently owned by Malapai Resourcl:SCompany and operatedby CogemaMining, Inc. n e property is beneficially owned 71% by AREV A md 29% by EDF. iv) Facility status: decommissioned. c) Size of evaporationpond: Pond Surface area (ac.) O'Hem 0.34 Dimensions (ft J 132 x 112 Capacity (gal.) 461,000 The pond was located immediately adjacent' 0 the now decommissionedplant.

10COGEMA Mining, Inc. & Pathfmder Mines Corp. Appendix B Response to EPA Inquiry Dated September 2, 2008. Submitted October 8, 2008.
d) Dates ofpond construction and use: Pond Construction Use Period Date to S1 andby 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 applicableto conventionalurimiummills that generate solid tailings and not to solution pOI Lds.Solution ponds at in situ operations have an assumedradon 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<.}e South) were constructed with Hypalon liners in 1S80. ii) Plan of operation: Operations were i litiated in 1981 and continuedwith interruptionuntill98~ Iwhen mining operations were terminated. From 1989to 2003 active aquiferrestoration was ongoing. Duringthat period the restoration process relied upon the cotltinueduse ofthe evaporationponds. Upon completior of aquiferrestoration in 2003, the two ponds were subjectt) decommissioning. The decommissioningwas accomplishedin 2004. All contaminatedmaterials and liners we :eremoved for transport to Shirley Basin 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:>erty was formally released for unrestricted use. iii) Ownership changes: The facility is 0 NIled and operated by CogemaMining, Inc. (previouslynarled Total Minerals), which is owned by AREV A NC, Inc., a Delaware corporation, which is owned by ARE V A, a French corporation. Due to the decommissic ned and released status ofthe West Cole site, COGEM A 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.

11COGEMA 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 ofthe ponds were located in the immediate vicinity of the plant. d) Dates ofpond construction and use: Pond Construction Use Period Date to S':andbv Current 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 SUBMITTED BY NOVE:vfBER8, 2008.

12

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