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 response to 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 isthe

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 of Appendix B.

Included under this cover letter is a narrativewhich addresses each Iluestion, a CD which

contains various pdf files of supporting documentation that is refererlcedin the narrative,

a guide which correlatesthe differentreferenced documentsin the 11arrativewith the

correct pdf files, and a certification signed by 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 (responsesto questions 4 through 6) submitted to

EPA on November 14, 2008,

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

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

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 penaltiesfor knowingly submitting false

statements and information, including the possibility of fines or imprisonment pursuant to

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

1!IJVuJ.u I~~~

Date
COGEMAMining, Inc. & Pathfmder Mines Corp.

Appendix B Response to EPA Inquiry Dated September 2, 2008.

Second Phase (Questions 4-6) Responses Submitted to EPA November 14,2008

Prepared by T. Hardgrove, Manager, Environmental and Regulatory Affairs

4. Additional information on each pond identified in response to request 3.d):

a) None of the identified impoundmentsin 3.d utilized the continuous

disposal method. The ponds containing solid tailings at both of

Pathfinder's sites (Lucky Mc and ShirleyBasin) were all constructed

before December 15, 1989as specified in 40 CFR 61, § 61.252(b). All of

the ponds identified for COGEMAMining, Inc. sitesin 3.d are or were

solution only storage/evaporationponds containing no tailings.

b) Not applicable. As noted in 4.a, none of the ponds utilized the continuous

disposal method for solid tailings.

c) Disposal Records:

ConventionalUranium Mill and Tailings Facilities -

Pathfinder Mines Corp. Lucky Mc Mine: The tailings ponds at

this site pre-date the effective date of 40 CFR §61.252relative to

work practices. Tailings were deposited by discharging a tailings

slurry, forming typical beaches and allowingmost of the liquid

portion ofthe slurry to flow to the central pool of a tailings pond.

Specific disposalrecords are not readily available (if they 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 adjacent to the tailings is presented in the Lucky Mc Mill Site

CompletionReport, February, 1998,also included on the CD.

Pathfinder Mines Corp. ShirleyBasin Mine: The tailings ponds at

this site pre-date the effective date of 40 CFR §61.252relative to

work practices. Tailings were deposited by discharging a tailings

slurry, forming typical beaches and allowingmost of the liquid

portion of the slurry to flow to the central pool of a tailings pond.

Specific disposalrecords are not readily available (if they exist at

all). Such disposalhas not occurred at this site for over sixteen

years. The tailings were covered on an interimbasis before

placement of the fmal radon barrier cover. A postdecommissioning/reclamationreport has yet to be prepared for this

site, but the covering process was done as specified in the Shirley

Basin Tailings Reclamationplan, included with this submittal as a

pdffile on a CD. The cleanup of wind dispersed tailingscontaminated soilsin areas adjacent to the tailingsis presented in
COGEMA Mining, Inc. & Pathfmder Mines Corp. Appendix B Response to EPA Inquiry Dated September

2,2008. SubmittedNovember 14,2008.

the ShirleyBasin Mill Site CompletionReportfor Reclamation of

Off-Pile Windblown Area, October, 1999, included on a CD.

In-situ Leaching Facilities -

COGEMAMining, Inc., Irigaray Mine and ChristensenRanch

SatelliteFacility:Not applicable- 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 10acres maximum uncovered at anyone time, as

specified in 40 CFR Section 6l.252(b )(2): As noted in 4.a above, all of

Pathfinder's solid tailings 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 of 40 CFR 252(b) do not apply.

t) Proof of compliancewith 40 CFR § 192.32(a):

ConventionalUranium Mill and Tailings FacilitiesPathfinder Mines 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 of the application for alternate concentration

limits, and the NRC staff environmentalassessment prepared in

support of the alternate concentrationlimits approval.

3. Placement of a permanent radon barrier [§192.32(a)(3)]:

Includedwith this submittal as pdf files copied to 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 completion report (two

volumes), and the NRC approval of the completionreport as

license amendment number 69.

4. Monitoringof radon releasesthrough the permanent radon

barrier [§192.32(a)(4)]: See the tailingsreclamation completion

report, volumes 1 and 2, for discussion, data, and laboratory

reportsrelating to the post-construction radon barrier flux testing

results.

5. Management of uranium byproductmaterialsin conformance

with Part 190 and Part 440 of 40 CFR Chapter 1[§192.32(a)(5)]:

2
COGEMAMining, Inc. & Pathfmder Mines 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 done prior to closure. Such

evaluations were not continued during the closure period. There

were no liquid effluent dischargesrelating to the tailings site.

Pathfinder Mines Corp. ShirleyBasin Mine:

1. Ponds construction [§ 192.32(a)(1)]: All tailings ponds at the

site pre-date the effective date (December 6, 1983) of 40 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 of the application for

alternate concentration limits, and the NRC staff technical

evaluation report prepared in support of the approved alternate

concentration limits.

3. Placement of a permanent radon barrier [§192.32(a)(3)]:

Included with this submittal as pdf files copied to a CD are the

reclamation (closure) plan forthe Shirley Basin Mine tailings site,

the license approval of the reclamationplan, and the NRC staff

technical evaluation accompanyingthe plan approval. All closure

plan construction relating to the ShirleyBasin tailings (directly on

the tailings) has been completed with the exception of Pond 3

which is still being utilized for NRC authorized disposal of 11e.(2)

byproduct material from certain ISL operations. Because some

peripheral (off tailings) channel features have not been completed

as of this submittal an interimtailingsreclamation 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 anticipated late in 2009.

4. Monitoring of radon releasesthrough the permanent radon

barrier [§192.32(a)(4)]: Includedwith this submittal as apdffile

copied to a CD is a summaryof the radon flux test results

conducted on the final radon barrier completedto date. Also

included are pdffiles of the 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 of uraniumbyproductmaterials in conformance

with Part 190 and Part 440 of 40 CFR Chapter 1[§192.32(a)(S)]:

Included with this submittal as pdf files copied to a CD are the

dose to the public evaluations done prior to closure. Such

evaluations were not continued during the closure period. There

were no liquid effluent dischargesrelating to the tailings site.

3
COGEMA 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-date 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 NRC SourceMaterial License SUA-1341which

establishes operational conditionsregarding ground water

protection, the wellfield restoration report dated July, 2004, and the

subsequent ground water restoration approvals by the Wyoming

Department of Environmental Quality (WDEQ) and the NRC.

Both the WDEQ and NRC have accepted ground water restoration

at ISL facilitiesto a secondary class of use standard for select

constituentsthat did not meet the primary restoration target (a

return to baseline levels).

3. Placement of a permanentradon barrier [§192.32(a)(3)]:

Not applicable to an ISL facility - there are no tailings. All other

byproduct materials have been or will be removed and transported

to the ShirleyBasin Mine tailings site or other licensed facility for

disposal.

4. Monitoring of radon releasesthrough the permanent radon

barrier [§192.32(a)(4)]: Not applicable.

5. Management of uranium byproduct materialsin conformance

with Part 190 and Part 440 of 40 CFR Chapter 1[§192.32(a)(5)]:

Included with this submittal as pdf files copied to a CD are the

dose to the public evaluationsdone prior to the latest suspension of

operations. Such evaluationswere not continued during the

closure period. Liquid effluent dischargesrelating to the ISL

operations were conducted under a NPDES permit issued by the

WDEQ. A copy ofthe last NPDES permit and representative

discharge reports submitted under the permit are included as pdf files on a CD.

COGEMAMining,Inc., ChristensenRanch 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 copied to

a CD areNRC SourceMaterial License SUA-1341 which

establishes operational conditionsregarding ground water

protection and the wellfield restoration report dated March 5, 2008

which has been submitted to both the WDEQ and the NRC. That

document is currently under review by both agencies.

4
COGEMA Mining, Inc. & Pathfmder Mines 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 applicable to an ISL facility - there are no tailings. All other

byproduct materials have been or will be removed and transported

to the ShirleyBasin Mine tailings site or other licensed facility for

disposal.

4. Monitoring of radon releasesthrough the pennanent radon

barrier [§192.32(a)(4)]: Not applicable.

5. Management of uranium byproductmaterials in confonnance

with Part 190 and Part 440 of 40 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 dischargesrelating to the ISL

operations were conducted under a NPDES pennit issued by the

WDEQ. A copy of the last NPDES pennit and representative

discharge reports 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) of 40 CFR §

192.32(a).

2. Confonnance to the ground water protection standard

[§192.32(a)(2)]: Included with this submittal as pdffiles copied to

a CD are the Texas RadioactiveMaterials License L03024 which

establishes operational conditionsregarding ground water

protection and the various wellfield restoration authorizations

(approvals)issued by the State of Texas.

3. Placement of a pennanent radon barrier [§192.32(a)(3)]:

Not applicableto an ISLfacility- there are no tailings. All other

byproduct materials have been or will be removed and transported

to the ShirleyBasin Mine tailings site or other licensed facility for

disposal.

4. Monitoring of radon releases through the pennanent radon

barrier [§192.32(a)(4)]: Not applicable.

5. Management of uranium byproductmaterials in confonnance

with Part 190 and Part 440 of 40 CFR Chapter 1[§192.32(a)(5)]:

Included with this submittal as pdf files copied to a CD are recent

dose to the public evaluations. The enclosed reportsreference the

Texas Administrative Code at 25 TAC 289.202. Due to a

reorganization of the code, the current reference is 30 TAC

§336.313which in turn references 40 CFR Part 190. Liquid

effluent dischargesrelating 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. Conformance to the ground water protection standard

[§192.32(a)(2)]: Included with this submittal as pdffiles copied to

a CD are the Texas RadioactiveMaterials License L03024 which

establishes operational conditionsregarding ground water

protection and the various wellfield restoration authorizations

(approvals)issued by the State of Texas.

3. Placement of a permanent radon barrier [§I92.32(a)(3)]:

Not applicableto an ISLfacility- thereareno tailings. All other

byproduct materials have been or will be removed and transported

to the ShirleyBasin Mine tailings site for disposal.

4. Monitoring of radon releasesthrough the permanent radon

barrier [§192.32(a)(4)]: Not applicable.

5. Management of uraniumbyproduct materialsin conformance

with Part 190 and Part 440 of 40 CFR Chapter I[§192.32(a)(5)]:

See discussion above for Holiday-EI Mesquite regarding dose to

the public evaluations; such evaluationswere not done specific to

this satellite facility since the main processing facility was at

Holiday-EIMesquite. Liquid effluent dischargesrelating 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. Conformance to the ground water protection standard

[§192.32(a)(2)]: Includedwith this submittal as pdffiles copied to

a CD are the Texas RadioactiveMaterialsLicense L03024 which

establishes operational conditionsregarding ground water

protection and the final completion review report (approval)issued

by the State of Texas, and the concurrence letter from the NRC.

3. Placement of a permanentradon barrier [§192.32(a)(3)]:

Not applicableto an ISLfacility- there are no tailings. All other

byproduct materials have been or will be removed and transported

to the ShirleyBasin Mine tailings site for disposal.

4. Monitoring of radon releasesthrough the permanent radon

barrier [§192.32(a)(4)]: Not applicable.

5. Management of uraniumbyproductmaterials in conformance

with Part 190and Part 440 of 40 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

6
COGEMA Mining, Inc. & Pathfmder Mines Corp. Appendix B Response to EPA Inquiry Dated September

2,2008. Submitted November 14,2008.

Holiday-EIMesquite. Liquid effluent dischargesrelating to the

ISL operationswere 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 - Pathfmder Mines Corporation, Lucky Mc Mine:

Air quality pennits for this site were limited to the pennit issued by

WDEQ for the operation of the 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 of the pennit. No other

specific air quality pennits applied to any of the tailings ponds.

There was one construction permit issued by WDEQ/Water

Quality Division for the construction of an enlargementto the No.

4 tailings embankment, the furthest downgradientstructure in the

tailings system. None of the other ponds were permitted for

construction, primarily due to their vintage.

Pathfinder Mines Corporation, ShirleyBasin Mine:

No pastair qualitypennitor pondconstruction .

applications/pennits could be located in the company files.

site closure such records may have been lost.

Due to

In-situ Leaching Facilities- . COGEMAMining,Inc.lrigarayMine:

There is an air quality pennit issued by the WDEQ for the

operation of a yellowcake (uranium concentrate) dryer. See the

enclosed pdffile of the pennit. No other specific air quality

permits applied to any of the ponds. A search of existing files

produced infonnation from three sourcesrelating to the

construction pennitting ofthe ponds at Irigaray. The ponds are

presented as part of the mine pennit application and NRC license

renewal; they are covered by Pennits to Construct issued by 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) operation prior to the pennitting of

full scale operations. Those ponds have been removed (including

removal of all radiologically contaminatedmaterial) and the site

reclaimed.

COGEMAMining,Inc. ChristensenRanch Satellite Facility:

Since this is a satellite facility to the Irigaray Mine, there is no

separate air quality pennit issued in conjunction with the site.

7
COGEMA 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 of the

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 of the

permit. No otherspecific air quality permits applied to any of the

ponds. Only one pond construction permit application could be

located in company files (see the enclosed pdf 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 construction permit or applicationto construct was found in

company files.

h) Other permits under the Clean Air Act:

ConventionalUranium Mill and Tailings Facilities- Pathfinder Mines Corporation, Lucky Mc Mine and ShirleyBasin

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 applicationsissued by or filed with the

Nuclear Regulatory Commission (NRC):

ConventionalUranium Mill and TailingsFacilities -

Pathfinder Mines Corporation,Lucky Mc Mine: See enclosed pdf

file of current license issued by the NRC. Note that this site has

been closed and is awaiting permanent transfer to the U.S.

Department of Energy. There are no license applicationsfor

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, ShirleyBasin 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

operationsin the No.3 pond area. There are no license

applicationsfor construction or operation outstanding.

In-situ Leaching Facilities - COGEMA Mining,Inc. Irigaray Mine and ChristensenRanch

Satellite Facility: See enclosed pdffile ofthe current license

issued by the NRC. A license renewal application for the project

was submitted to the NRC on May 31, 2008. See enclosed pdf file

of the renewal application.

COGEMA Mining,Inc. Holiday-EIMesquite, O'Hem, and West

Cole Facilities: See enclosedpdffile of the current license issued

by the State of Texas. There are no license applicationsfor

construction or operation outstanding since all of these sites are in

closure.

j) Copies of any other licensesissued by states under state authority:

Conventional Uranium Mill and Tailings Facilities - Pathfinder Mines Corporation, Lucky Mc Mine and ShirleyBasin

Mine: none.

In-situ Leaching Facilities - COGEMAMining, Inc. Irigaray Mine and ChristensenRanch

Satellite Facility: See enclosed pdf file of mine permit issued by

the WDEQ. The mine permit covers aspects of processing plant,

including evaporation ponds.

COGEMAMining, Inc. Holiday-EIMesquite, O'Hem, and West

Cole Facilities: none.

k) Current license status:

ConventionalUranium Mill and Tailings FacilitiesPathfinder 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, ShirleyBasin Mine: License is in a

decommissioning/closurestatus with proviso for continuation of

II.e.(2) material disposal at the site. Balance of tailings area

closure has been completed.

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

2,2008. Submitted November 14,2008.

In-situ Leaching FacilitiesCOGEMA Mining,Inc. Irigaray Mine and ChristensenRanch

Satellite Facility: The license was recently amendedby the NRC

from a decommissioningstatusto operational(as yet operations

have not started). The NRC considersthe license to be under

"timely renewal", based on the submittal of the renewal application

for continuing operationssubmitted on May 31, 2008.

COGEMAMining,Inc. Holiday-El Mesquite, O'Hem, and West

Cole Facilities: The Holiday-El Mesquite and O'Hem sites are

covered by the sameTexas radioactive materialslicense. Because

Texas is an agreementstate, the Texas Commission on

EnvironmentalQuality is the administrator/licensorof the current

license. That license, while technically expired, has continued as a

functionalregulatory device. Renewal of the license has been

postponed in anticipationof the 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:

ConventionalUraniumMillandTailingsFacilitiesPathfinder Mines Corporation,Lucky Mc Mine: To the best of

Pathfinder Mines Corporation's knowledge, the construction of the

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.

Pathfinder Mines Corporation, ShirleyBasin Mine: To the best of

Pathfinder Mines Corporation's knowledge, the construction of the

tailings ponds and facilities was done in accordancewith the

permits and federalregulations in effect at the times of

construction. Due to the completion of most site

decommissioning,there are no current operations. However, an

intermittent activity isthe disposal of 11.e.(2)wastes from certain

ISL licenseesin the No.3 pond area; that activity, to the best of

Pathfinder Mines Corporationsknowledge, is being conducted in

accordancewith all permits and federal regulations.

In-situ LeachingFacilities- COGEMAMining,Inc. Irigaray Mine and ChristensenRanch

Satellite Facility: To the best of COGEMA Mining,Inc.'s

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

2,2008. SubmittedNovember 14,2008.

knowledge, the construction of the evaporation/holdingponds ~d

facilities was done in accordance with the permits and federal

regulationsin effect at the times of construction. The ponds and

facilities are being operated in accordancewith 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 of the evaporation/holdingponds and

facilities was done in accordance with the permits and federal

regulations in effect at the times of construction. Most of the

facilities and ponds 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 TailingsFacilitiesPathfinder Mines Corporation, Lucky Mc Mine: Due to the

completion of site decommissioning,there is no pollution control

equipment on site.

Pathfinder Mines Corporation, ShirleyBasin Mine: All of the

solid tailings ponds have been covered, including placement of the

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 of the 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 enclosed tanks

to limit radon and other releases, curbed containment basins

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 levelsto cover

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

2,2008. Submitted November 14,2008.

bottom sedimentsin holding/evaporationponds. Two permitted

deep disposal wells are available for the disposal of process waste

water.

COGEMAMining, Inc. Holiday-EIMesquite, O'Hern, and West

Cole Facilities: All processing plant facilities have been

decommissioned, and there is no plant-related pollution 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 of the 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):

ConventionalUraniumMillandTailingsFacilitiesPathfinder Mines Corporation, Lucky Mc Mine: The radon-222

emission standard of 20 pCi/(m2-sec)is applicable to the site. The

required annualtesting of radon 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 of the ponds.

Pathfinder Mines Corporation, ShirleyBasin Mine: The radon-222

emission standard of 20 pCi/(m2-sec)is applicable to the site. The

required annualtesting of radon flux was conducted at the site until

the site went into final closure. Subsequentto completion of the

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 of the ponds.

In-situ Leaching Facilities - COGEMAMining, Inc. Irigaray Mine and ChristensenRanch

Satellite Facility: The facilities are not subjectto the NESHAP for

radon emission under Subpart W since there are no tailings. While

there are solution ponds 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 Subpart W since there are no tailings. Any

12
COGEMA Mining, Inc. & Pathfmder Mines Corp. Appendix B Response to EPA Inquiry Dated September

2,2008. SubmittedNovember 14,2008.

ponds structuresleft (Holiday-EIMesquite only) have been

cleaned out and are no longerin 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:

ConventionalUraniumMillandTailingsFacilitiesPathfinder Mines Corporation,Lucky Mc Mine: See the enclosed radon flux

test reportsto EPA Region 8 along with supporting infonnation, all in pdf

fonnat. The tests were conducted as specified in 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 reportsto EPA under 40 CFR 61 Subpart 1.

Pathfinder Mines Corporation, ShirleyBasin 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 specified in 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 earlierin this submittal.

In-situ Leaching Facilities - COGEMA Mining, Inc. Irigaray Mine and ChristensenRanch Satellite

Facility: No radon flux tests were conducted for 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 conducted for the reason stated in 4. n)

above: there are no tailings on site.

Infonnation provided by: T. Hardgrove

6. Provide copies of reports as specified in 40 CFR § 61.254:

ConventionalUraniumMillandTailingsFacilitiesPathfinder Mines Corporation,Lucky Mc Mine and Shirley Basin Mine: No

reports were generated pursuant to 40 CFR § 61.254 since eitherthe sites were

in compliance with the radon emission standard or were in final closure.

In-situ Leaching Facilities- Not applicable.

Infonnation provided by: T. Hardgrove

13
COGEMA Mining, Inc. & Pathfmder Mines Corp. Appendix B Responsesto 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... ..LuckyMcTailingsReclamationCompletionRptVOL-Lpdf

LuckyMcTailingsReclamationCompletionRptVOL-II.pdf

Lucky Mc Mill Site Completion Report. .. ....LuckyMc- Mill_Site_Completion_Report. pdf

Shirley Basin Tailings Reclamation Plan ..ShirleyBasinTailingsReclamationPlan.pdf

Shirley Basin Mill Site Completion Report

For Reclamation of Off-Pile Windblown

Area .XSBM-WindblownTailingsCleanupReport.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 &

TechnicalEvaluationfortheTRP .....XLuckyMc_Tailings_Reclamation]lan - NRC- Approvals.pdf

XNRCapprovallMTailingsReclamationPlanAddend.Lpdf

Tailings Reclamation Completion Report. . ... LuckyMcTailingsReclamationCompletionRptVOL-Lpdf

LuckyMcTailingsReclamationCompletionRptVOL-II.pdf

NRCApprovalof TRCompletionReport.....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 ShirleyBasinTailingsReclamationPlan.pdf
COGEMA 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 Sectior

HolidayEl 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 ShirleyBasinFinalRadonBarrierFluxTests.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 September30,2008NRCLicenseAmendmentApproval.pdf

Wellfield Restoration Report ... Irigaray-Wellfield_Restorationy-pt.pdf

WellfieldRestorationApprovalbyWDEQ... 2004-Irigaray_groundwaterJestoration-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

4.i) Lucky Mc.., XIrigaray Christensen Ranch NPDES-2.pdf

Shirley Basil

IrigarayChristensen

Ranch........

Christensen

Ranch .Mine Permit & License Update (1996) XCurrent]emit_To_Mine-478.pdf

NRC Source Material License SUA-1341 September30,2008 NRCLicenseAmendmentApproval.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 IrigarayandChristensenNPDES.pdf

Christensen Ranch Representative NPDES

Discharge Reports IrigarayandChristensenNPDES.pdf

XIrigarayChristensenRanchNPDES-2.pdf

Texas ISL...

4.j) Wyoming IS:

5. Lucky Mc...