# A
COGEMA

November 14, 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 responseto the Request to Provide Inform~ .tionPursuant to the Clean Air Act as discussed in the EPA letterto COGEMAMining, ]nc. dated September 2, 2008, signed by Adam Kushner, Director Air Enforcement Divisi)n. This is the second submittal in response to the request for information. The ini :ialresponse, submitted on October 8, 2008, addressedthe first three questions of AppendixB to the referenced EPA letter. This submittal addresses questions 4 througll 6 ofAppendix B.
Included under this cover letter is a narrativewhich addresses each Iluestion, a CD which contains various pdf files of supporting documentationthat is refererlcedin the narrative,
a guide which correlates the differentreferenced documents in the 11 arrativewith the correct pdf files, and a certification signedby the General Manager for COGEMA Mining, Inc. and Pathfinder Mines Corporation, Mr. Bernard Bonifi.s. If you have any questions regarding the submitted information, do'not hesitate to coItact me. Sincerely, 

# r~
Tom Hardgrove Manager, Environmental and Regulatory Affairs
Encls.
Cc: Andrew M. Gaydosh, U. S. EPA Region 8 T. Pennington, AREVA NC (w/o CDs) B. Bonifas (w/o CDs)

COGEMA Mining, Inc. 935 Pendell Blvd., P.O. Box 730, Mills, WY 82644

- Tel. : (307) 234-5019

- Fax: (307) 473-7306-- ----- u
- u-
-

CERTIFICATION STATEMENT Concerning the Appendix B Responses (responses to questions 4 through 6) submitted to EPA on November 14, 2008,

I certify under penalty of law that I have examined and am familiarwith the information in the enclosed documents, including all attachments. Based on my inquiry ofthose individuals with primary responsibility for obtaining the information, I certify that the statements and information are, to the best of my knowledge and belief, true and complete. I am aware that there are significant penalties for knowingly submitting false statements and information, including the possibility of fines or imprisonment pursuant to section 113(c)(2) ofthe Act, and 18 U.S.C. §§ 1001 and 1341.



### 1!IJV 

## uJ.u 

# I~~~ DateCOGEMAMining, Inc. & PathfmderMines Corp. Appendix B Response to EPA Inquiry Dated September 2, 2008. Second Phase (Questions 4-6) Responses Submittedto EPA November 14,2008 Prepared by T. Hardgrove, Manager, Environmental and Regulatory Affairs
4. Additional information on each pond identified in responseto request 3.d): a) None ofthe identified impoundments in 3.d utilized the continuous disposal method. The ponds containing solid tailings at both of Pathfinder's sites (Lucky Mc and Shirley Basin) were all constructed before December 15, 1989 as specifiedin 40 CFR 61, § 61.252(b). All of the ponds identified for COGEMAMining, Inc. sites in 3.d are or were solution only storage/evaporationponds containing no tailings. b) Not applicable. As noted in 4.a, none ofthe ponds utilized the continuous disposal method for solidtailings. c) Disposal Records: ConventionalUranium Mill and Tailings Facilities

- Pathfinder Mines Corp. Lucky Mc Mine: The tailings ponds at this site pre-datethe effective date of 40 CFR §61.252relative to work practices. Tailings were deposited by discharging a tailings slurry, forming typical beaches and allowing most ofthe liquid portion ofthe slurry to flow to the central pool of a tailings pond. Specific disposal records are not readily available (ifthey exist at all). Such disposalhas not occurred at this site for over twenty years. The method of coveringtailings is recounted in the tailings reclamation completionreport included as a pdf file on a CD included with this submittal. The cleanup of contaminated soils in
areas adjacentto the tailings is presented in the Lucky Mc Mill Site Completion Report, February, 1998, also included on the CD.
Pathfinder Mines Corp. Shirley Basin Mine: The tailings ponds at this site pre-datethe effective date of 40 CFR §61.252relative to work practices. Tailings were deposited by discharging a tailings slurry, forming typical beaches and allowing most ofthe liquid portion ofthe slurry to flow to the central pool of a tailings pond. Specific disposal records are not readily available (ifthey exist at all). Such disposalhas not occurred at this site for over sixteen years. The tailings were covered on an interimbasis before placement ofthe fmal radon barrier cover. A postdecommissioning/reclamationreport has yet to be prepared for this site, but the covering process was done as specifiedin the Shirley Basin Tailings Reclamationplan, included with this submittal as a pdffile on a CD. The cleanup of wind dispersedtailingscontaminated soils in areas adjacentto the tailings is presented inCOGEMA Mining, Inc. & PathfmderMines Corp. Appendix B Response to EP A Inquiry Dated September 2,2008. SubmittedNovember 14,2008.
the Shirley Basin Mill Site Completion Report for Reclamation of Off-Pile Windblown Area, October, 1999, included on a CD.
In-situ Leaching Facilities

- COGEMAMining, Inc., Irigaray Mine and Christensen Ranch 

### Satellite Facility: Notapplicable

- 

### therearenotailings.
COGEMAMining, Inc. Holiday-El Mesquite, O'Hern, and West 

### ColeFacilities:Not applicable

- there are no tailings. d) Emissions data: See response to item 6 below. e) Compliancewith 10 acres maximum uncovered at anyone time, as specifiedin 40 CFR Section 6l.252(b )(2): As noted in 4.a above, all of Pathfinder's solidtailings ponds were constructedprior to December 15, 1989, and were not subjectto the requirements of 40 CFR Section 61.252(b). Because all COGEMAMining, Inc. ponds are solution only the work practices of40 CFR 252(b) do not apply. t) Proof of compliancewith 40 CFR § 192.32(a): ConventionalUranium Mill and Tailings Facilities

PathfinderMines Corp. Lucky Mc Mine: 1. Ponds construction [§ 192.32(a)(1)]: All tailings ponds at the site pre-date the effective date (December6, 1983) of 40 CFR § 192.32(a). 2. Conformanceto the ground water protection standard [§192.32(a)(2)]: Included with this submittal as pdffiles copied to a CD are NRC SourceMaterial License SUA-672which contains license condition 60 that incorporates alternate concentration limits for the site, a copy ofthe application for alternate concentration limits, and the NRC staff environmentalassessment prepared in support ofthe alternate concentrationlimits approval. 3. Placement of a permanent radon barrier [§192.32(a)(3)]: Includedwith this submittal as pdf files copiedto a CD are the reclamation (closure) plan for the Lucky Mc tailings site, the license approvals ofthe reclamationplan, the NRC staff environmental assessment and technical evaluation accompanying the plan approvals, the tailings reclamation completionreport (two volumes), and the NRC approval ofthe completionreport as license amendmentnumber 69. 4. Monitoring of radon releases through the permanent radon barrier [§192.32(a)(4)]: See the tailings reclamation completion report, volumes 1 and 2, for discussion, data, and laboratory reports relating to the post-constructionradon barrier flux testing results. 5. Managementofuranium byproductmaterials in conformance with Part 190 and Part 440 of40 CFR Chapter 1[§ 192.3 2(a)(5)]:

2COGEMAMining, Inc. & PathfmderMines Corp. AppendixB Responseto EPA Inquiry Dated September 2,2008. SubmittedNovember 14,2008.
Included with this submittal as pdf files copied to a CD are the dose to the public evaluations doneprior to closure. Such evaluations were not continued during the closure period. There
were no liquid effluent dischargesrelating to the tailings site.
Pathfinder Mines Corp. Shirley Basin Mine: 1. Ponds construction [§ 192.32(a)(1)]: All tailings ponds at the site pre-date the effective date (December 6, 1983) of40 CFR § 192.32(a). 2. Conformance to the groundwater protection standard [§192.32(a)(2)]: Includedwith this submittal as pdffiles copied to a CD are NRC SourceMaterial License SUA-442which contains license condition 47 that incorporates alternate concentration limits for the site, a copy ofthe application for alternate concentration limits, and the NRC stafftechnical evaluationreport prepared in support ofthe approved alternate concentration limits. 3. Placement of a permanent radon barrier [§192.32(a)(3)]: Included with this submittalas pdf files copied to a CD are the reclamation (closure) plan forthe Shirley Basin Mine tailings site, the license approval ofthe reclamationplan, and the NRC staff technical evaluation accompanyingthe plan approval. All closure plan construction relating to the Shirley Basin tailings (directly on the tailings) has been completed with the exception ofPond 3 which is still being utilized forNRC authorized disposal of 11e.(2) byproduct material from certain ISL operations. Because some peripheral (offtailings) channel features have not been completed
as ofthis submittal an interimtailings reclamation completion report has not been submittedto the NRC. Submittal of an interim completion report (covering all tailings/mill site areas exclusive of Pond 3) is anticipatedlate in 2009. 4. Monitoring ofradon releases through the permanent radon barrier [§192.32(a)(4)]: Includedwith this submittal as apdffile copied to a CD is a summaryofthe radon flux test results conducted on the final radon barrier completedto date. Also included are pdffiles ofthe laboratoryradon flux test data, and a map illustrating the sampling grid for the radon flux tests conducted to date on the final clay radon barrier. 5. Management ofuraniumbyproductmaterials in conformance with Part 190 and Part 440 of40 CFR Chapter 1[§192.32(a)(S)]: Included with this submittalas pdf files copied to a CD are the dose to the public evaluations doneprior to closure. Such evaluations were not continuedduring the closure period. There
were no liquid effluent dischargesrelating to the tailings site.

3COGEMA Mining, Inc. & Pathfmder Mines Corp. Appendix B Response to EPA Inquiry Dated September 2,2008. Submitted November 14,2008.
In-situ Leaching Facilities

# - COGEMAMining, Inc., Irigaray Mine: 1. Ponds construction [§ 192.32(a)(1)]: All ponds at the site pre-datethe effective date (December 6, 1983) of40 CFR § 192.32(a). 2. Conformanceto the ground water protection standard [§192.32(a)(2)]: Includedwith this submittal as pdffiles copiedto a CD are NRC SourceMaterial License SUA-1341 which establishes operational conditions regarding ground water protection, the wellfield restoration report datedJuly, 2004, and the subsequent ground water restoration approvals by the Wyoming Department ofEnvironmental Quality (WDEQ) and the NRC. Both the WDEQ and NRC have accepted ground water restoration at ISL facilities to a secondary class ofuse standardfor select constituents that did not meet the primary restoration target (a return to baseline levels). 3. Placement of a permanentradon barrier [§192.32(a)(3)]: Not applicableto an ISL facility

- there are no tailings. All other byproduct materials have been or will be removed and transported to the Shirley Basin Mine tailings site or other licensed facility for disposal. 4. Monitoring ofradon releases through the permanent radon barrier [§192.32(a)(4)]: Not applicable. 5. Managementofuranium byproduct materials in conformance with Part 190 and Part 440 of40 CFR Chapter 1[§192.32(a)(5)]: Included with this submittal as pdf files copied to a CD are the dose to the public evaluations done prior to the latest suspension of operations. Such evaluations were not continued during the closure period. Liquid effluent discharges relating to the ISL operations were conductedunder a NPDES permit issued by the WDEQ. A copy ofthe last NPDES permit and representative dischargereports submittedunder the permit are included as pdf files on a CD.

COGEMAMining, Inc., Christensen Ranch Satellite Facility: 1. Ponds construction [§ 192.32(a)(1)]: All ponds at the site were constructed consistent with the approved mine permit update to WDEQ and the NRC license update (same documentsee pdffiles on the CD). 2. Conformanceto the ground water protection standard [§192.32(a)(2)]: Included with this submittal as pdffiles copiedto a CD areNRC SourceMaterial License SUA-1341 which establishes operational conditions regarding ground water protection and the wellfield restoration report dated March 5, 2008 which has been submittedto both the WDEQ and the NRC. That document is currently under review by both agencies.

4COGEMA Mining, Inc. & PathfmderMines Corp. Appendix B Response to EPA Inquiry Dated September 2,2008. SubmittedNovember 14,2008.
3. Placement of a pennanent radon barrier [§ 192.32(a )(3)]: Not applicableto an ISL facility

- there are no tailings. All other byproduct materials have been or will be removed and transported to the Shirley Basin Mine tailings site or other licensed facility for disposal. 4. Monitoring ofradon releases through the pennanent radon barrier [§192.32(a)(4)]: Not applicable. 5. Managementofuranium byproductmaterials in confonnance with Part 190 and Part 440 of40 CFR Chapter 1[§192.32(a)(5)]: Included with this submittal as pdf files copiedto a CD are the dose to the public evaluations done prior to the latest suspension of operations. Such evaluations were not continued during the closure period. Liquid effluent discharges relating to the ISL operations were conducted under aNPDES pennit issued by the WDEQ. A copy ofthe last NPDES pennit andrepresentative dischargereports submitted underthe pennit are included as pdf files on the CD.

COGEMAMining, Inc., Holiday-El Mesquite Facility: 1. Ponds construction [§ 192.32(a)(1)]: All ponds at the site pre-date the effective date (December 6, 1983) of40 CFR § 192.32(a). 2. Confonnance to the ground waterprotection standard [§192.32(a)(2)]: Included with this submittal as pdffiles copied to a CD are the Texas Radioactive Materials License L03024 which establishes operational conditionsregarding ground water protection and the various wellfield restoration authorizations (approvals) issued by the State ofTexas. 3. Placement of a pennanent radon barrier [§192.32(a)(3)]: 

### Notapplicable to anISLfacility

- there are no tailings. All other byproduct materials have been or will be removed and transported to the Shirley Basin Mine tailings site or other licensed facility for disposal. 4. Monitoring ofradon releases through the pennanent radon barrier [§192.32(a)(4)]: Not applicable. 5. Managementof uranium byproductmaterials in confonnance with Part 190 and Part 440 of40 CFR Chapter 1[§192.32(a)(5)]: Included with this submittal as pdffiles copiedto a CD are recent dose to the public evaluations. The enclosedreports reference the Texas Administrative Code at 25 TAC 289.202. Due to a reorganization ofthe code, the currentreference is 30 TAC §336.313 which in turn references 40 CFR Part 190. Liquid effluent discharges relating to the ISL operations did not occur at this site.

5- --- mCOGEMA Mining, Inc. & Pathfmder Mines Corp. Appendix B Response to EPA Inquiry Dated September 2,2008. Submitted November 14,2008.
COGEMA Mining, Inc., O'Hem Facility: 1. Ponds construction [§ 192.32(a)(1)]: The pond atthe site pre-dated the effective date (December 6, 1983) of 40 CFR § 192.32(a). 2. Conformanceto the ground water protection standard [§192.32(a)(2)]: Included with this submittal as pdffiles copiedto a CD are the Texas RadioactiveMaterials License L03024 which establishes operational conditions regarding ground water protection and the various wellfield restoration authorizations (approvals) issued by the State ofTexas. 3. Placement of a permanent radon barrier [§I92.32(a)(3)]: 

### Notapplicable to anISLfacility

- 

### thereareno tailings. All other byproduct materials have been or will be removed and transported to the Shirley Basin Mine tailings site for disposal. 4. Monitoring ofradon releases through the permanent radon barrier [§192.32(a)(4)]: Not applicable. 5. Management ofuraniumbyproduct materials in conformance with Part 190 and Part 440 of40 CFR Chapter I [§ 192.32(a)(5)]: See discussion above for Holiday- EI Mesquite regarding dose to the public evaluations; such evaluations were not done specificto this satellite facility since the main processing facility was at Holiday-EIMesquite. Liquid effluent discharges relating to the ISL operations were not conducted at this site.
COGEMA Mining, Inc., West Cole Facility: 1. Ponds construction [§ 192.32(a)(1)]: The ponds at the site pre-dated the effective date (December 6, 1983) of 40 CFR § 192.32(a). 2. Conformanceto the ground water protection standard [§192.32(a)(2)]: Includedwith this submittal as pdffiles copied to a CD are the Texas RadioactiveMaterials License L03024 which establishes operational conditions regarding ground water protection and the final completionreview report (approval) issued by the State ofTexas, and the concurrence letter from the NRC. 3. Placement of a permanentradon barrier [§ 192.32(a)(3)]: 

### Not applicable to anISLfacility

- there are no tailings. All other byproduct materials have been or will be removed and transported to the Shirley Basin Mine tailings site for disposal. 4. Monitoring ofradon releases through the permanent radon barrier [§192.32(a)(4)]: Not applicable. 5. Management ofuraniumbyproductmaterials in conformance with Part 190and Part 440 of40 CFR Chapter 1[§192.32(a)(5)]: See discussion above for Holiday-EIMesquite regarding dose to the public evaluations; such evaluationswere not done specificto this satellite facility since the main processing facility was at

6COGEMA Mining, Inc. & PathfmderMines Corp. Appendix B Response to EPA Inquiry Dated September 2,2008. Submitted November 14,2008. Holiday-EIMesquite. Liquid effluent discharges relating to the ISL operations were not conducted at this site. g) Constructionpennit applications or pennits issued pursuant to 40 CFR §§ 61.07 and 61.08 or any state authority: ConventionalUranium Mill and Tailings Facilities



## - PathfmderMines Corporation, Lucky Mc Mine: Air quality pennits for this site were limited to the pennit issued by WDEQ for the operation ofthe mill facility. That pennit, MD-28,
was issued in June, 1979. It is no longer in effect due to site reclamation. See the enclosed pdffile ofthe pennit. No other specific air qualitypennits applied to any ofthe tailings ponds. There was one constructionpermit issued by WDEQ/Water Quality Division for the construction of an enlargementto the No. 4 tailings embankment, the furthest downgradient structure in the tailings system. None ofthe other ponds were permitted for construction, primarily due to their vintage.
PathfinderMines Corporation, Shirley Basin Mine: 

### No pastairquality pennitorpondconstruction

. applications/pennits could be located in the company files. site closure such records may have been lost. Due to

In-situ Leaching Facilities



## -

. 

### COGEMA Mining,Inc.lrigarayMine: There is an air qualitypennit issued by the WDEQ for the operation of a yellowcake (uranium concentrate) dryer. See the enclosed pdffile ofthe pennit. No other specific air quality permits appliedto any ofthe ponds. A search of existing files produced infonnation from three sourcesrelating to the constructionpennitting ofthe ponds at Irigaray. The ponds are presented as part ofthe mine pennit application and NRC license renewal; they are covered by Pennits to Construct issuedby the WDEQ/Water QualityDivision; and they are pennitted through the Wyoming State Engineer (see enclosed pdf file regarding Irigaray pond constructionpermits/applications). Note that the 517ponds referenced in the renewal document were small lined structures utilized in a pilot (feasibility) operationprior to the pennitting of full scale operations. Those ponds have been removed (including removal of all radiologicallycontaminatedmaterial) and the site reclaimed.

COGEMAMining, Inc. Christensen Ranch Satellite Facility: Since this is a satellite facility to the Irigaray Mine, there is no separate air qualitypennit issued in conjunction with the site.

7COGEMA Mining, Inc. & Pathfmder Mines Corp. Appendix B Response to EPA Inquiry Dated September 2,2008. SubmittedNovember 14,2008.
See the pdf file for the Wyoming constructionpemits for the various ponds.
COGEMAMining, Inc. Holiday-EIMesquite Facility: Air quality operating permit issued by the Texas Air Control Board for the central plant, primarily relating to the operation ofthe yellowcake dryer and packaging facilities, and a hot oil heater. All such facilities have been decommissioned, and the air quality permit is no longer in effect. See the enclosedpdf file ofthe permit. No other specific air qualitypermits applied to any ofthe ponds. Only one pond constructionpermit application could be located in company files (see the enclosedpdf file).
COGEMAMining, Inc. O'Hem Facility: No air quality permit could be located in company files for this facility. No pond construction application or permit to construct could be found in company files.
COGEMAMining, Inc. West Cole Facility: No air quality permit located for this facility. Apparently there was an original permit relating to the site, but it could not be found in accessible files. Note that this facility has been permanently closed, decommissioned, and released to unrestricted use. No separate pond constructionpermit or applicationto construct was found in company files. h) Otherpermits under the Clean Air Act: ConventionalUranium Mill and Tailings Facilities



## - Pathfinder Mines Corporation, Lucky Mc Mine and Shirley Basin Mine: none.
In-situ Leaching Facilities

- COGEMAMining, Inc., Irigaray Mine and ChristensenRanch Satellite Facility: none. COGEMAMining, Inc. Holiday-EIMesquite, O'Hem, and West Cole Facilities: none. i) Copies of licenses or license applications issued by or filed with the Nuclear Regulatory Commission (NRC): ConventionalUranium Mill and TailingsFacilities

- Pathfinder Mines Corporation, Lucky Mc Mine: See enclosedpdf file of current license issued by the NRC. Note that this site has been closed and is awaiting permanenttransfer to the U.S. Department ofEnergy. There are no license applications for construction or operation outstanding.

8-- -- n_____-

COGEMA Mining, Inc. & Pathfmder Mines Corp. Appendix B Response to EPA Inquiry Dated September 2,2008. Submitted November 14,2008.
Pathfinder Mines Corporation, Shirley Basin Mine: See enclosed pdffile of current license issued by the NRC. Note that this site has been, for the most part, closed. The only ongoing activity is the licensed disposal of II.e.(2) material from select ISL operations in the No.3 pond area. There are no license applications for construction or operation outstanding.
In-situ Leaching Facilities



## - COGEMA Mining, Inc. Irigaray Mine and Christensen Ranch Satellite Facility: See enclosedpdffile ofthe current license issued by the NRC. A licenserenewal application for the project
was submitted to the NRC on May 31, 2008. See enclosedpdf file ofthe renewal application.
COGEMA Mining, Inc. Holiday-EIMesquite, O'Hem, and West Cole Facilities: See enclosedpdffile ofthe current license issued by the State of Texas. There are no license applications for construction or operation outstanding since all ofthese sites are in closure. j) Copies of any other licenses issued by states under state authority: Conventional Uranium Mill and Tailings Facilities



## - Pathfinder Mines Corporation, Lucky Mc Mine and Shirley Basin Mine: none.
In-situ Leaching Facilities



## - COGEMAMining, Inc. Irigaray Mine and Christensen Ranch Satellite Facility: See enclosedpdf file ofmine permit issuedby the WDEQ. The mine permit covers aspects ofprocessing plant, including evaporation ponds.
COGEMAMining, Inc. Holiday-EIMesquite, O'Hem, and West Cole Facilities: none. k) Current license status: ConventionalUranium Mill and Tailings Facilities

Pathfinder Mines Corporation, Lucky Mc Mine: License is in a decommissioning/closurestatus. Site closure completed; awaiting site transfer to DOE and termination ofPathtinder's license.

Pathfinder Mines Corporation, Shirley Basin Mine: License is in a decommissioning/closurestatus with proviso for continuation of II.e.(2) material disposal atthe site. Balance oftailings area closure has been completed.

9COGEMA Mining, Inc. & Pathfmder Mines Corp. Appendix B Response to EPA Inquiry Dated September 2,2008. Submitted November 14,2008.
In-situ Leaching Facilities

COGEMA Mining, Inc. Irigaray Mine and ChristensenRanch Satellite Facility: The license was recently amendedby the NRC from a decommissioningstatus to operational (as yet operations have not started). The NRC considers the license to be under "timely renewal", based on the submittal ofthe renewal application for continuing operations submitted on May 31, 2008.
COGEMAMining, Inc. Holiday-El Mesquite, O'Hem, and West Cole Facilities: The Holiday-El Mesquite and O'Hem sites are coveredby the same Texas radioactive materials license. Because Texas is an agreement state, the Texas Commission on Environmental Quality is the administrator/licensorofthe current license. That license, while technically expired, has continued as a functionalregulatory device. Renewal ofthe license has been postponed in anticipationofthe near term completion of decommissioning, and final sites closure. The West Cole facility previously was coveredby a separate license, but was subsequently merged into the existing license (L03024). The site has been decommissioned,released for unrestricted use, and the license terminated.
1) Construction and operation of facilities and ponds in accordancewith all permits and federal regulations: 

### Conventional Uranium MillandTailings Facilities

Pathfinder Mines Corporation, Lucky Mc Mine: To the best of Pathfinder Mines Corporation's knowledge, the construction ofthe tailings ponds and facilities was done in accordancewith the permits and federalregulations in effect at the times of construction. Due to the completion of site decommissioning, there are no current operations.
PathfinderMines Corporation, Shirley Basin Mine: To the best of Pathfinder Mines Corporation's knowledge, the construction ofthe tailings ponds and facilities was done in accordance with the permits and federalregulations in effect at the times of construction. Due to the completion ofmost site decommissioning,there are no current operations. However, an intermittent activity is the disposal of 11.e.(2)wastes from certain ISL licensees in the No.3 pond area; that activity, to the best of PathfinderMines Corporationsknowledge, is being conducted in accordance with all permits and federal regulations.
In-situ LeachingFacilities



## - COGEMAMining, Inc. Irigaray Mine and ChristensenRanch Satellite Facility: To the best of COG EMA Mining, Inc.'s

10COGEMA Mining, Inc. & PathfmderMines Corp. Appendix B Response to EPA Inquiry Dated September 2,2008. SubmittedNovember 14,2008. knowledge, the construction ofthe evaporation/holdingponds ~d facilities was done in accordance with the permits and federal regulations in effect at the times of construction. The ponds and facilities are being operated in accordance with all permits and federal regulations,to the best of COGEMAMining, Inc.' s knowledge.
COGEMAMining, Inc. Holiday-EIMesquite, O'Hem, and West Cole Facilities: To the best of COGEMAMining, Inc.'s knowledge, the construction ofthe evaporation/holdingponds and facilities was done in accordance with the permits and federal regulations in effect at the times of construction. Most ofthe facilities andponds at these sites have been decommissioned. Remaining facilities and ponds are being operated in accordance with all permits and federal regulations, to the best of COGEMA Mining, Inc.' s knowledge. m) Description of any pollution control equipment: ConventionalUranium Mill and TailingsFacilitiesPathfinderMines Corporation, Lucky Mc Mine: Due to the completion of site decommissioning,there is no pollution control equipment on site.
PathfinderMines Corporation, Shirley Basin Mine: All ofthe solid tailings ponds have been covered, including placement ofthe final radon barrier. The II.e.(2) burial process involves using one open trench at a time for material placement with periodic earthen covering ofthe waste. The rest ofthe No.3 pond basin has an interim earthen cover in place. There is no other pollution control equipment on site.
In-situ Leaching Facilities



## - COGEMAMining, Inc. Irigaray Mine and ChristensenRanch Satellite Facility: Pollution control equipmentincludes a scrubber
on the uranium concentrate (yellowcake) dryer with a 95% to 99% efficiency for the removal of uraniumparticulates, a dust collection baghouse for the dried product packaging process, and the maintenance of a partial vacuum in the dryer enclosure to contain particulates. The operating permit from WDEQ specifies operating limits for scrubberpressure, scrubberliquid flow rate, and stack emissions. Other equipment consists of enclosedtanks to limit radon and other releases, curbed containmentbasins around tanks with retrieval sumps to control spills, alarm systems to detect pipeline pressure drops, indicative of a possible leak, and the routine maintenance of sufficientpond liquid levels to cover

11COGEMA Mining, Inc. & Pathfmder Mines Corp. Appendix B Response to EPA Inquiry Dated September 2,2008. Submitted November 14,2008.
bottom sediments in holding/evaporationponds. Two permitted deep disposal wells are available for the disposal ofprocess waste water.

COGEMAMining, Inc. Holiday-EIMesquite, O'Hern, and West Cole Facilities: All processing plant facilities have been decommissioned, and there is no plant-relatedpollution control equipment left at the sites. There are two above ground storage tanks used in support of injection into a permitted deep disposal well at the Holiday-El Mesquite site. The Holiday-EIMesquite site is the only one where any ofthe holding/evaporationponds are still present, and they have been cleaned out and only hold minor amounts of water from rainfall.
n) Statement concerning applicability ofNESHAP for radon emissions as defined under 40 CFR §§ 61.250 et. seq. (SubpartW): 

### Conventional Uranium MillandTailings Facilities

Pathfinder Mines Corporation, Lucky Mc Mine: The radon-222 emission standard of 20 pCi/(m2-sec)is applicable to the site. The required annualtesting ofradon flux was conducted at the site until the site went into final closure. Subsequentto completion of the final radon barrier over the tailings ponds, a final radon flux test was conducted, demonstratingcompliancewith the radon emission standard. The site was not subject to the work practices due to the early construction and use ofthe ponds.
PathfinderMines Corporation, Shirley Basin Mine: The radon-222 emission standard of 20 pCi/(m2-sec) is applicableto the site. The required annualtesting ofradon flux was conducted at the site until the site went into final closure. Subsequentto completion ofthe final radon barrier over the solid tailings ponds, a final radon flux test was conducted, demonstratingcompliance with the radon emission standard. The site was not subjectto the work practices due to the early construction and use ofthe ponds.
In-situ Leaching Facilities



## - COGEMAMining, Inc. Irigaray Mine and Christensen Ranch Satellite Facility: The facilities are not subjectto the NESHAP for radon emission under SubpartW since there are no tailings. While there are solutionponds that contain sediments, water levels are maintained over those sediments.

COGEMAMining, Inc. Holiday-EIMesquite, O'Hern, and West Cole Facilities: The facilities are not subject to the NESHAP for radon emission under SubpartW since there are no tailings. Any

12COGEMA Mining, Inc. & Pathfmder Mines Corp. Appendix B Response to EPA Inquiry Dated September 2,2008. SubmittedNovember 14,2008. ponds structures left (Holiday-EIMesquite only) have been cleaned out and are no longer in use.
Infonnation provided by: T. Hardgrove, R. Owens, L. Arbogast, D. Benevides

5. Results of all air and radon emission tests under 40 CFR §§ 61.253 and 61.255: 

### Conventional Uranium MillandTailings Facilities

Pathfinder Mines Corporation, Lucky Mc Mine: See the enclosed radon flux test reports to EPA Region 8 along with supporting infonnation, all in pdf fonnat. The tests were conducted as specifiedin 40 CFR §§ 61.253 and 61.255. Also see the results and data forthe radon flux test conducted on the fmal radon barrier as referenced earlier in this submittal. Also included are pdf files of emission reports to EP A under40 CFR 61 Subpart 1.
Pathfinder Mines Corporation, Shirley Basin Mine: : See the enclosedradon flux test reports to EPA Region 8 along with supporting infonnation, all in pdf fonnat. The tests were conducted as specifiedin 40 CFR §§ 61.253 and 61.255. Also see the results and data for the radon flux test conducted on the final radon barrier as referenced earlier in this submittal.

In-situ Leaching Facilities 

# - COGEMA Mining, Inc. Irigaray Mine and ChristensenRanch Satellite Facility: No radon flux tests were conductedfor the reason stated in 4. n) above: there are no tailings on site.
COGEMA Mining, Inc. Holiday-EIMesquite, O'Hem, and West Cole Facilities: No radon flux tests were conductedfor the reason statedin 4. n) above: there are no tailings on site.
Infonnation provided by: T. Hardgrove

6. Provide copies ofreports as specifiedin 40 CFR § 61.254: 

### Conventional Uranium MillandTailings Facilities

Pathfinder Mines Corporation, Lucky Mc Mine and Shirley Basin Mine: No reports were generatedpursuant to 40 CFR § 61.254 since eitherthe sites were in compliance with the radon emission standardor were in final closure.
In-situ Leaching Facilities

# - Not applicable.
Infonnation provided by: T. Hardgrove

13COGEMA Mining, Inc. & Pathfmder Mines Corp. Appendix B Responses to EPA Inquiry Dated September 2,2008. Submitted November 14,2008.

Guide Relating Narrative to pdfFiles on CD
Narrative Section Document CD file 4.c) Lucky Mc Tailings Reclamation Completion Report... ..LuckyMcTailings Reclamation Completion RptVOL-Lpdf LuckyMc Tailings Reclamation Completion RptVOL-II.pdf Lucky Mc Mill Site Completion Report.

. . . . . .Lucky Mc

- Mill_Site _Completion_Report. pdf Shirley Basin Tailings Reclamation Plan ..ShirleyBasinTailings Reclamation Plan.pdf Shirley Basin Mill Site Completion Report For Reclamation of Off-Pile Windblown Area .XSBM- Windblown TailingsCleanup Report.pdf 4.f) Lucky Mc .NRC Source Material License SUA-672 .XSML_SUA-672.pdf Lucky Mc Application for ACLs .LuckyMcACLApplication.pdf NRC Staff Environmental Assessment Of Lucky Mc ACLs Application .XLuckyMc_ACLEA.pdf Tailings Reclamation Plan.

. . . . . . . . . . . . . . .. . . .. .Lucky Mc Tailings Reclamation Plan Voll.pdf Lucky Mc Tailings Reclamation Plan V012.pdf. Lucky Mc Tailings Reclamation Plan Addendum Lpdf NRC License Approval of TRP.

. . . . . . . . . . . . . . .XLuckyMc _Tailingsy-eclamation]lan

- NRC

- Approvals.pdf XNRC approval 1MTailings Reclamation Plan Addend. Lpdf NRC Staff Environmental Assessment & 

### Technical Evaluation forthe TRP



### .....XLuckyMc _Tailings_Reclamation ]lan

- NRC

- Approvals.pdf XNRCapprovallMTailings Reclamation PlanAddend. Lpdf Tailings Reclamation Completion Report.

. ... LuckyMc Tailings Reclamation Completion RptVOL-Lpdf LuckyMcTailings Reclamation Completion RptVOL-II.pdf 

### NRCApproval ofTR Completion Report.

. ...XNRC

- Approval- LM-Tailings_Reclamation

- Completion-Rpt.pdf Lucky Mc Dose to Public Evaluations ...XLuckyMc- 40-CFR-190_Dose_to]ublic.pdf Shirley Basin... NRC Source Material License SUA-442 .XShirley_Basin_Source_Material_License_SUA-442.pdf Shirley Basin Application for ACLs ..ShirleyBasinACLApplication.pdf NRC Staff Technical Evaluation for Shirley Basin ACLs .XShirleYJ3asin_NRC-Lic-Amendmentjor_ACLs-TER.pdf Tailings Reclamation Plan Shirley BasinTailings Reclamation Plan.pdfCOGEMA Mining,

. COGEMA Mining, Inc. & Pathfmder Mines Corp. Appendix B Responses to EPA Inquiry Dated September 2,2008. Submitted November 14,2008.

Guide Relating Narrative to pdfFiles on CD Narrative SectiorHolidayEl Mesquite. Narrative Section Document CD file

O'Hem....... NRC License Approval of TRP

. . . . . . . . . . . . . . .. SBM TRP Approval.pdf XShirley _Basin

- SUA-442_Amend.Approving-TRP _(with-TER).pdf NRC Staff Technical Evaluation for the TRP SBMTRPApproval.pdf XShirley ~asin

- SUA -442_Amend. Approving- TRP_(with- TER).pdf Final Radon Barrier Flux Test Summary Shirley BasinFinalRadonBarrier FluxTests.pdf Laboratory Rn Flux Data.

. . . . . . . . . . . . . . . . . . . . . .. Shirley Basin Final Radon Barrier Flux Tests.pdf Map of Rn Flux Sampling Grid for Final Radon Barrier ...S.B. FinalRadon Flux Test Sample Locations-MAP.pdf Shirley Basin Dose to Public Evaluations.

. . .. .xShirley _Basin_Dose

- to_Public _Eval_in

- Lic.Renewal- EA.pdf Irigaray NRC Source Material License SUA-1341 September 30, 2008NRCLicense Amendment Approval.pdf Wellfield Restoration Report

... Irigaray- Wellfield_Restorationy-pt.pdf 

### Wellfield Restoration Approval byWDEQ.

.. 2004-Irigaray _groundwater Jestoration-WDEQ-Approval.pdf Well field Restoration Approval by NRC 2004_irigaray~roundwater_restoration_NRC_Approval.pdf Irigaray Dose to Public Evaluations XIrigaray_MineJ)ose_to]ublic.pdf Irigaray NPDES Permit ...IRNPDESPERMIT.pdf IRNPDESPERMIT-l.pdf West Cole... 4.g) Lucky Mc...

Irigaray

.

Christensen Ranch

.HolidayEl Mesquite. Irigaray Representative NPDES Discharge Reports.

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .Irigaray and Christensen NPDES.pdf XIrigaray Christensen Ranch NPDES-2.pdf 4.i) Lucky Mc.., Shirley BasilIrigarayChristensen Ranch........ Christensen Ranch .Mine Permit & License Update (1996) XCurrent]emit_To_Mine- 478.pdf NRC Source Material License SUA-1341 September 30,2008 NRCLicense Amendment Approval.pdf Well field Restoration Report CR-2008- Wellfield_Restoration_Rpt.pdf Christensen Ranch Dose to Public Evaluations XChristensen_Ranch_Dose_to]ub1ic.pdf Christensen Ranch NPDES Permit Irigaray andChristensen NPDES.pdf Christensen Ranch Representative NPDES Discharge Reports Irigaray andChristensen NPDES.pdf XIrigaray Christensen Ranch NPDES-2.pdf Texas ISL... 4.j) Wyoming IS: 5. Lucky Mc...