Department of Environmental Quality

To protect, conserve and enhance the quality of Wyoming'senvironment for the benefit of current and future generations.

Dave Freudenthal, Governor John Corra, Director

December 31, 2008 Certified Mail 7008 1140 0004 2414 0080

Ms. Krista WenzelManager-Health, Safety and Environmental AffairsCameco ResourcesP.O. Box 1210Glenrock, WY 82637

RE: TFN 5 3/49, Approval of Restoration Plan, Non-Significant Revision, Change No. 62Notice of Violation Docket No. 4231-08, Permit 603, Cameco Resources (CR)

Dear Ms. Wenzel:

This letter serves as Land Quality Division's (LQD) approval for the above referenced Non-Significantrevision. The final round of review comments is enclosed deeming all technical responses acceptable. Therevision is processed as Change No. 62.

With this approval, it is noted that both CR and LQD met their commitments to finalize the restorationrevisions for the Highland Uranium Permit (#603) and the Smith Ranch Permit (#633) by the deadline ofDecember 31, 2008, as defined in the Settlement Agreement for Notice of Violation Docket # 4231-08.Fulfillment of this commitment partially satisfies Item 10/24 of the Settlement Agreement. The remainingrequirement of this Item requires CR to recalculate the reclamation bond amount for the Highland andSmith Ranch Mines and submit by February 28, 2009.

Please do not hesitate to contact me at 307-777-7048 or prothw@wyo.gov, if you have any questions.

Sincerely,

Pam RothwellPermit Coordinator, District I Assistant SupervisorLand Quality Division

Enclosure: Final Review Comments

cc: Scott Bakken, Cameco Resources, Denver w/attDoug Mandeville, NRC w/o att., w/copy of revisionBecky Brocius, NOV file w/o att., w/copy of revision

xc: Steve Ingle, LQDDon McKenzie, LQD Administrator

Herschler Building • 122 West 25th Street • Cheyenne, Wyoming 82002 • http-//deq.state.wy.usADMIN/OUTREACH ABANDONED MINES AIR QUALITY INDUSTRIAL SITING LAND QUALITY SOLID & HAZ. WASTE WATER QUALITY(307) 777-7758 (307) 777-6145 (307) 777-7391 (307) 777-7368 (307) 777-7756 (307) 777-7752 (307) 777-7781FAX 777-3610 FAX 777-6462 FAX 777-5616 FAX 777-6937 FAX 777-5864 FAX 777-5973 FAX 777-5973

INDEX SHIEET FOR MINE PERMIT AMENDMENTS OR REVISIONS

LjýNE COMPANY NANME: Power Resources Inc. d/b/a Cameco ResourcesMINE NAME: Hi&Wiand Uranium Project

Page 1 of 1Date Dec. 18, 2008TFN 5 3/49PERMIT NO.: 603-A2

Statement: I, Krista Wenzel , an authorized representative of Power Resources, Inc. declare that only the items listed on this and allconsecutively numbered index Sheets are intended as revisions to the current permit document. In the event that other changes inadvertentlyoccurred due to this revision, those unintentional alterations will not be considered approved. Please initial and date. ". ,w 7

NOTES:1) Include all revision or change elements and a brief description of or reason for each revision element.2) List all revision or change e lements in sequence by volume number; number index sheets sequentially as needed.

Volume Page, Map or other Page, Map or otherNumber Permit.Entry to be Permit Entry to be Description of ChangeNumber . REMOVED ADDED

Table of Contents andPages RP-1, RP-2, RP-3,RP-4, RP-5, RP-6, RP-7, Table of Contents and8 RP-I7A, RP-7B, RP-7C, RP- Pagles RPf Conthrou and Revised Table of Contents, Section 1, Section 3, and Section 4

8P[A RP7B RP7,P Pages RP-1I through RP- 148, RP-8A, RP-9, RP-9A, of the Reclamation Plan of the Reclamation PlanRP-1l0,,RP- 11, RP-1A of Ih AlmtinPa

RP-!12 and RP-13 of the__Reclamation Plan

N/A clamation Plan, Added Attachment 1 - HUP Restoration Schedule (Projected)

8 N/A Reclamation Plan, Added Attachment 2 - Highland Uranium Project Mine UnitI Attachment 2 Extraction Rates and Pore Volumes18 N/A Attchamentio 3la,

8 Reclamation Plan,, Added Attachment 3 - Projected HUP Water Disposal Balance

INDEX SHEET FOR MINE PERMIT AMENDMENTS OR REVISIONS Page 1 of 1Date Dec. 31, 2008TFN 5 3/49PERMIT NO.: 603-A2

MINE COMPANY NAME: Power ResourMINE NAME: Highland Uranium Proiect

ces Inc. d/b/a Cameco Resources

Statement: 1, Krista Wenzel , an authorized representative of Power Resources, Inc. declare that only the items listed on this and allconsecutively numbered'Index Sheets are intended as revisions to the current permit document. In the event that other changes inadvertentlyoccurred due to this revision, those unintentional alterations will not be considered approved. Please initial and date.

NOTES:I) Include all revision or change elements and a brief description of or reason for each revision element.2) List all revision or change ilements in sequence by volume number; number index sheets sequentially as needed.

u Page, Map or other Page, Map or otherVolume I1 Permit Entry to be Permit Entry to be Description of ChangeNumber _ REMOVED - ADDED

8 ~~Pag es RP-2 afi'd RP-13 of Pages RP-2 an'R'P-13 of Scin . n .. hnethe Reclamation Plan the Reclamation Plan of

8 a~s1 ecins3. nd4..-cane

I Al

At'

'f ý /'--I "- i

TABLE OF CONTENTS

RECLAMATION PLAN

1. GENERAL

2. RADIOLOGICAL DECONTAMINATION

2.1 Decommissioning Surveys

3. RECLAMATION AND REVEGETATION

3.1 Reclamation of CPF, Satellite Buildings,Auxiliary Structures and Roads

3.2 Reclamation of Wellfields3.3 Reclamation of Drillholes3.4 Revegetation

3.4.1 Pe3.4.2 Mu3.4.3 As3.4.4 Tr

rmanent Seed Mixlchingsessment of Revegetation Successees

PageRP-1

RP-1

RP-2

RP-2

RP-2

RP-2RP-3RP-4

RP-4RP-4RP-5RP-5

RP-5

RP-5RP-6RP-6

RP-7RP-7RP-8RP-8

RP-9RP-10RP-11RP-13RP-13

RP-14

RP-14

4. GROUND WATER RESTORATION

4.1 Restoration Standards4.2 Pre-Mining Background Water Quality4.3 Restoration Methods

4.3.14.3.24.3.34.3.4

Ground Water SweepClean Water InjectionBioremediation/Reductant AdditionSelenium Treatment Facility

4.44.54.64.74.8

Ground Water Restoration ScheduleRestoration Water BalanceOperational MonitoringStability MonitoringWell Plugging and Abandonment

5-.- -......BONDING-

5.1 General

AttachmentsAttachment 1Attachment 2Ittachment 3

Ground Water Restoration ScheduleMine Unit Extraction Rates and Pore VolumesWaste Water Balance

11 '•: 111 1-.. evised December 18, 2008)

31.Acý C49

RECLAMATION PLAN

1. GENERAL

Reclamation at the project site is comprised of four majoractivities which include the following:

1. Radiological decontamination of buildings, process vesselsand other structures or affected areas.

2. Removal and reclamation of the CPF, Satellite and auxiliarystructures.

3'. Ground water restoration within affected wellfields,

including production and monitor well plugging.

4. Surface reclamation and revegetation of restored wellfields.

The schedule for mining related activities is included in Section1.4 of the Operations Plan. Attachment 1 shows the projectionschedule for restoration related activities of restorationprogress. At completion of wellfield restoration/reclamation theCPF and Satellite Facilities will ! be decommissioned andreclaimed. Ground water restoration, and wellfield decommissioningwill be accomplished as wellfields are mined out. Satellitefacilities will also be decommissioned as soon as ground waterrestoration is complete and they are no longer needed.

Both the surface reclamation plan and ground water restorationplan are intended to return areas affected by mining activitiesto a condition which supports the premining land use of sheep andcattle grazing and associated wildlife habitat.

2. RADIOLOGICAL DECONTAMINATION

All radiologically contaminated buildings, process vessels andother structures and affected areas will be decontaminated priorto final reclamation to unrestricted release standards inaccordance with NRC requirements, or removed to the appropriatedisposal facilities. Decontamination will include acid and waterwashdown of structures and concrete. The resultihg waste waterwill be disposed of in the waste disposal well (Section 4.6 of

-.--....... t h e- _Ope r ati on s--Plan) -. ............ Equ-ipment-- whi€ch---cannot -- be--- decontaminat-ed--will be dismantled and disposed of in an U.S. NRC licensed wastedisposal facility or utilized at another NRC licensed uraniumfacility. All uncontaminated foundations will be removed orbroken up and buried in place.

Detailed- decommissioning plans for the CPF will be provided prior

4 to the beginning of decommissioning activities.

r-3

2.1 Decommissioning Surveys

Required radiological surveys will be conducted to ensureand verify that affected areas meet decommissioning,criteria.

3. RECLAMATION AND REVEGETATION

3.1 Reclamation of CPF, Satellite Buildings, AuxiliaryStructures and Roads

Final reclamation of these areas will be done at, or nearthe end of operations, although certain Satellitebuildings and roads may be reclaimed sooner if they areno longer needed. Once structures are removed the areawill be ripped to break up compaction and contoured tonear the predisturbance land configuration. At least 12inches of topsoil will be applied if that quantity oftopsoil was originally available. If needed, secondarytillage will be accomplished with disc harrows followedby drag or finger harrows.

The area will then be seeded with the permanent seed mix(Section 3.4) by drill, or drill mounted grass seedingbox. In areas where vegetation is present the use of ano-till type drill will be considered. The area willremain fenced to exclude livestock until vegetation issufficiently established.

Certain. roads and/or buildings may be left for thelandowner's use if desired and permission from thelandowner is obtained. If this occurs it will be handledon a case by case basis at the appropriate time.

3.2 Reclamation of Wellfields

Surface reclamation will be completed within two (2)years after ground water restoration is complete. Referto Attachment 1, Groundwater Restoration Schedule, whichindicates the projected restoration/reclamation schedule.

.Se c t ion-10-. 4--off-th-e--Op~erations- la-di-§c-dSe- temporaryrevegetation of operating wellfields. Wellfields will beseeded with the approved seed mix within one year afterground water restoration is complete, wells are pluggedand all structures, piping and powerlines are removed.Areas which have been compacted will be ripped and, whereneeded, the surface

(Revised December 31, 2008) RP-2

- 3/,.,

will be contoured approximate to the predisturbance landconfiguration. In the unlikely event that surfacedrainage is significantly altered, it will be returned tonear predisturbance conditions prior to topsoiling andseeding. In areas that were stripped of topsoil at least12 inches of topsoil, if available, will be applied.Secondary tillage will be utilized as needed.

The permanent seed mix (Section. 3.4) will be .seeded bydrill or drill mounted grass seeding. box. In areas wherevegetation is present inter-seeding will be accomplishedwith a no-till type drill. The area will remain fencedto exclude livestock until vegetation is sufficientlyestablished. Once vegetation is sufficientlyestablished, fences will be removed so that the reclaimedarea can be grazed by both domestic livestock andwildlife in order that bond release criteria can bedemonstrated.

As discussed in Section OP 10.6.2 - Wetlands •Protection,all wetland type areas disturbed. will be returned totheir preaffection condition as soon as possible. Sinceany perceived disturbance is limited to very minorsurface disturbance, existing revegetation commitments,including the use of the permanent seed mix forrevegetation are adequate to restore wetland type areas.

Proposed wellfield activities in the SW'i of Section 21,T36N, R73W will result in the potential disturbance ofapproximately 113 acres of a 160 acre dryland wheatgrasspasture which is currently (January 1991) in CRP.Agreements are in-place with the landowner to replace anyaffected surface to CRP or the desired crop.

The amount and depths of replaced topsoil and areas which

are seeded or reseeded are reported in the Annual Report.

3.3 Reclamation of Drillholes

There are three types of drillholes at' the Highland.. .....Uranium roject-. -.--. -These--inelude--dri l-lholes.----for----utanlumn....exploration, 'uranium delineation, and cased wellinstallation. All of these drillhoes are abandoned inaccordance with WS-35-11-404 and Chapter XV of theWDEQ-LQD Rules and Regulations.

Surface reclamation of drillhole sites consists ofbackfilling of the associated mud pit, topsoilapplication and seeding. Exploration holes and any wells

(Revised December 18, 2008) RP-3

which are not within a near term proposed wellfield areseeded with the permanent seed mix. Uranium delineationdrillholes, which are drilled to determine the limits ofan identified ore body for which a wellfield is planned,are not revegetated as the area undergoes wellfielddevelopment within one year. Once the wellfield isinstalled the entire disturbed area, including thedelineation drillholes, is seeded and revegetated.

3.4' Revegetation

3.4.1 Permanent Seed Mix

The permanent seed mix to be used for revegetation is asfollows:

Species lbs PLS/Acre

Western Wheatgrass (Agropyron smithii) 4Sheep Fescue (Festuca ovina) 2Thickspike Wheatgrass (Agropyron dasystachyum) 4Canby Bluegrass (Poa canbyi) 2Green Needlegrass (Stipa viridula) 2

Indian Ricegrass (Oryzopsis hymenoides) or any of thenative wheatgrasses may be substituted in the seed mixfor the wheatgrasses if any of the above species areunavailable or cost prohibitive.

The above seed mix is adequate to reestablish avegetative cover which is consistent with the preminingland use of livestock grazing and use by wildlife.Shrubs are not included in the seed mix as the majorityof the land to be disturbed is in private ownership andshrub establishment is not desired. This should notadversely affect wildlife as the areas to be affected bymining activities are of limited size and typically aredominated by grasslands and not shrubs. Additionally, ifshrubs such as sagebrush are present in wellfield areasresidual plant§ remain within the area following

.op eratio ns-- and--revegeta-t- ion-. ....- ........ ........... ..... . . . . .

3.4.2 Mulching

Areas with slopes greater than 25% will be seeded withthe permanent seed mix and will be mulched with a strawmulch crimped at a rate of two tons per acre or plantedwith a temporary cover crop such as barley, winter wheat,millet or rye at 30 lbs per acre. This will be done to

(Revised December 18, 2008) RP-4 -3

assist in protecting the topsoil resource and the plantedseed bed from erosion.

3.4.3 Assessment of Revegetation Success

The success of revegetation in meeting land use andreclamation success standards will be assessed prior toapplication for bond release by utilizing the "ExtendedReference Area" method as detailed in WDEQ-LQD GuidelineNo. 2 - Vegetation (March 1986) . This method compares,on a statistical basis, the reclaimed area (percentvegetation cover, percent total ground cover, and totalherbaceous production) with adjacent undisturbed areasof the same vegetation type.

The extended reference areas will be located adjacentto the reclaimed area being assessed for bond releaseand will be sized such that it is at least half aslarge as the area being assessed. In no case will theextended reference area be less than 25 acres in size.

The WDEQ-LQD will be consulted prior to selection ofextended reference areas to ensure agreement that theundisturbed areas chosen adequately represent thereclaimed areas being assessed.

3.4.4 Trees

As discussed in the baseline information presented inAppendix D8 the number of trees is very, limited withinthe permit area and most are limited to individual orsmall groups of cottonwoods (Populas deltoides) alongmajor drainageways. Proposed mining activities shouldnot adversely affect any trees. In the unlikely eventthat any trees are affected they will be replaced.

4. 'GROUND WATER RESTORATION

4.1 Restoration-Standards

Ground water restoration is achieved by returning theaffecLed ground water in the production zone, on amine unit average, to a quality of use equal to orbetter than, and consistent with the uses for which'the water was suitable prior to mining, by employingthe best practicable technology (BPT) available (W.S.§ 35-11-103(f) (i)and(iii)). For the purposes of this

(Revised December 18,2008) RP-5

application, "quality of use" is based on the pre-mining class of use suitability standards establishedby the Wyoming Department of Environmental Quality,Water Quality Rules and Regulations, Chapter 8, whichare based on pre-mining background water quality.

The evaluation of ground water restoration will beconducted on a parameter by parameter basis using theaverage quality over the production zone (i.e., themine unit average). For any a'ffected ground wateroutside the production zone,, restoration will beevaluated separately for each well. The finalacceptance level of water quality attained duringground water restoration will be based on the pre-mining class of use suitability standard, availabletechnology and other social and economic factors asdescribed in WDEQ/LQD Chapter 11, Section 5(a) (ii) (A).

4.2 Pre-Mining Background Water Quality

The pre-mining background water quality of a miningunit is based on the background water quality datacollected from wells completed in the plannedProduction Zone (i.e., MP-Wells). Background waterquality values are established on a mine unit averageand parameter by parameter basis taking into accountthe variability between sample results.

4.3 Restoration Method

The ground water restoration program consists of twostages; restoration and stability monitoring. Asdescribed in Sections 4.3.1 through 4.3.3 below, therestoration stages consist of the following phases;ground water sweep, clean water injection (e.g.,reverse osmosis treatment) and bioremediation and/orreductant addition. A supplemental selenium treatmentfacility may also be used in addition to the currentprocesses. These phases are designed to optimizerestoration equipment used in treating-gro-und-water..

. -and to minimize the, volume of ground water consumedduring the restoration process. The sequence ofactivities will be determined based on operatingexperience, waste water system capacity and theprogress of restoration in individual mine units. Thevarious phases of restoration will be selected basedupon the most efficient means to restore a mine unit.

(Revised December 18,2008) RP-6

For some mine units, certain phases of restoration maynot be selected if deemed unnecessary.

4.3.1 Ground Water Sweep

Ground water sweep consists of pumping affected groundwater within the production zone without re-injectionof water. This process causes an influx of naturalbackground quality water from the perimeter of themining unit, which sweeps the affected portion of theproduction zone. The plume of affected ground waternear the perimeter of the mining unit is also drawnfurther inside the boundaries of the mine unit. Asground water sweep continues, it becomes . lesseffective in reducing the concentrations of certainparameters. At this point, treatment and re'injectionof the ground water being removed (i.e., clean waterinjection) is necessary to accelerate the restorationprocess. Because ground water sweep is moreconsumptive than, and not as effective as, clean waterinjection, it may be used in conjunction with cleanwater injection at any, time during the restorationprocess to add flexibility and efficiency to therestoration program. It is anticipated that up to onepore volume of ground water sweep will be utilizedduring the ground water restoration process.

4.3.2 Clean Water Injection

Clean water injection involves the pumping of affectedground water'and re-injection of treated water (e.g.,reverse osmosis) or other water sources of similarquality. This restoration . technique is primarilyintended to further reduce concentrations of certainparameters such as total dissolved solids (TDS),thereby accelerating the rate of restoration. Thesource of the clean water may be from a reverseosmosis (RO) or electro dialysis reversal (EDR) typeunit, ion exchange (IX), water extracted from a miningunit that is in a more advanced sit.a.te__of _res-torat ion,-----water being exchanged with a new mining unit, or acombination of these sources. It is anticipated thatRO treatment and re-injection of permeate will be theprimary method used during the clean water injectionphase of restoration. Ground water treated by RO maybe further treated by pH adjustment and de-carbonationto remove excess carbon dioxide prior to re-injection.This process is designed to further reduce bicarbonate

(Revised December 18,2008) RP-7

concentrations in the production zone and acceleraterestoration. It is anticipated that an average offive to eight pore volumes of clean water injectionwill be utilized for each mining unit to achieveground water restoration.

4.3.3 Bioremediation/Reductant Addition

If certain parameters remain elevated duringrestoration efforts, the use of bioremediation (i.e.,bioreduction) and/or reductant addition will beevaluated and utilized as appropriate on individualmine units or a per pattern basis. The use ofbioremediation and/or introduction of chemicalreductants into the formation has been demonstrated tobe effective in reversing the effect of the ISRprocess and immobilizing redox sensitive parameterssuch as iron, manganese, selenium and uranium.Bioremediation is the use of naturally occurringbacteria and the addition of nutrients such as sugarsand alcohols that stimulates the bacterial growth.Chemical reductants typically consist of a sulfurcompound such as gaseous hydrogen sulfide (H2 S) ordilute solutions of sodium hydrosulfide (NaHS) orsodium sulfide (Na2S). Regardless of the reductantchosen for use, a comprehensive safety plan will beimplemented. Bioremediation and/or reductant additionmay be used before, during or after the clean waterinjection phase of ground water restoration.Regulatory approval will be obtained prior toinitiating any experimental bioremediation and/orreductant addition practices not previously approvedby the LQD.

4.3.4 Selenium Treatment Facility

During restoration the solution extracted duringground water sweep, treated by ion exchange, 'anddischarged as reverse osmosis concentrate contains

- ----------- e ------- ions The supplemental seleniumfacility will operate to treat solutions which have anelevated selenium content. The process will remove theselenium, allowing the clean stream to be dischargedinto surface pond SR-2 for eventual disposal bysurface irrigation.

(Revised December 18,2008) RP-8

After removal of the uranium oxide (U308) and radium,the feed waste stream is pumped into the seleniumremoval circuit. The process circuit consists ofplacing the waste stream into selenium removal columnswhere the selenium is precipitated out of solution andcaptured in a sand media. The proposed Satellite No.2 Selenium Treatment Facility will process remediationwater currently being sent from Satellite No. 2 andSatellite No. 3 to the SR-2 pond that supplies asurface irrigator. The new plant will provideselenium removal to a target concentration not toexceed average selenium levels of 0.1 mg/L prior toOct 31, 2009. The new plant will include a radiumremoval circuit that may potentially replace radiumremoval currently being done in Satellite No. 2 andSatellite No. 3.

Waste/remediation water will first, be treated forradium using a barium chloride solution that willprecipitate radium. The radium compound precipitatewill be concentrated via gravity settling and thenconcentrated in a filter cake. The filter cake willbe sent to a properly designated landfill.

Following radium removal, the remediation stream willbe processed in selenium removal columns. The spentmedia of the column will be discharged to sand washingequipment and the precipitate will be concentrated viagravity settling and then concentrated in a filtercake. The filter cake will be sent to a' properlydesignated landfill.

The washed sand media will be recharged with iron toreestablish the 5:1 volume ratio and then put back inthe selenium removal column for further processing.

4.4 Ground Water Restoration Schedule

The schedule for ground water restoration is providedin Attachment 1. Ground water restoration activitiescommence--once- the-- ura nlurif i--- -partic-1ar- mine-uniitis recovered. The duration of restoration activitieswill vary according to the size of the mine unit, theporosity and permeability of the production zone, andthe extent to which the ground water has beenaffected. The schedule of restoration recognizes thatit is necessary to isolate restoration from productionactivities. If restoration areas are not isolated,mining solutions could potentially flow into areas?

(Revised December 18,2008) RP-9

undergoing restoration thus reducing the effectivenessof restoration efforts.

The duration of ground water restoration for each mineunit is affected by many factors. The two mostcritical factors are the practical extraction rate andpore volume. The practical extraction rate is thatrate which creates a cone of depression such thatmining solutions from mine units in active productiondo not flow into mine units undergoing restoration.Attachment 2 identifies the practical extraction raterange and pore volume (including flare factor) of eachmine unit. The schedule for each mine unit is basedon one pore volume of ground water sweep and eightpore volumes of water being extracted, treated and re-injected during clean water injection.,

4.5 Restoration Water Balance

The waste water disposal requirements needed tosupport production and restoration operations areprovided in Attachment 3. The water balance indicateswhen PRI is required to increase waste water disposalcapacities based on the extraction rates and schedulepresent in Attachment 1. At the Highland UraniumProject, waste water disposal includes evaporation andland application (PSR-2, Irrigator 2), deep wellinjection (Morton 1-20 and Vollman 33-27, which mayrequire workover'), and/or other approved treatmentmethods (i.e., selenium removal treatment). As *shownin Attachment 3, the average monthly inflow to PSR-2is approximately 180 gpm. Operating experience hasshown that the rate of land application andevaporation during the summer months sufficientlyreduces the water level in PSR-2 to' allow forcontinuous inflow to PSR-2 during the winter monthswhen land application is not realized. The waterbalance also factors in an approximate 1% operationalbleed for excursion control with 1% to 5% additionaldisposal capacity remaining for excursiQn, retrieval-..........

..- __.... rIn-the-- event that the water quality is unsuitable forirrigation, alternative waste water disposal methodsinclude existing disposal wells, new disposal wells asneeded and approved, and/or other approved treatmentmethods (i.e., selenium removal treatment). PRI iscommitted to ensuring waste water disposal capacitiesmeet or exceed those required to meet the restorationschedule.

(Revised December 18,2008) RP-1o

4.6 Operational Monitoring

At the start' of restoration, the MP-Wells, which areused to determine pre-mining background water qualityfor each mine unit, are sampled and analyzed for theground water restoration monitoring parameters inTable 1 to characterize an "end of injection" waterquality average for each mine unit. To track theprogress of restoration, the MP-Wells, in areas whereactive restoration activities are occurring, will besampled and analyzed for conductivity, chloride anduranium once every two months during periods of activerestoration. In the event that unforeseen conditions(such as snowstorms, flooding, equipment malfunction)occur, the WDEQ will be contacted if the well (s)cannot be monitored within seven days of the regularlyscheduled sampling date. Depending on the results ofinitial sampling at the beginning of restoration,other specific parameters, such as selenium, may betracked during restoration to evaluate the need forbioremediation/reductant addition, pH control, etc.

The monitor ring wells (M-Wells), overlying aquiferwells (MO or MS-Wells), and underlyng aquifer wells(MU or MD-Wells) are sampled once every two months andanalyzed for the excursion parameters; chloride, totalalkalinity, and conductivity. Water levels are alsoobtained at these wells prior to sampling.

(Revised December 18,2008) RP-11 /Y

Table 1

Ground Water Restoration Monitoring Parameters

Alkalinity

Ammonium

Arsenic

Barium

Bicarbonate

Boron

Cadmium

Calcium

Carbonate

Chloride

Chromium

Copper

Electrical conductivity @25 degrees C

Fluoride

.Iron

Lead

Magnesium

Manganese

Mercury

Molybdenum

Nickel

Nitrate

pH

Potassium

Radium-226

Selenium

-Sodium-------

Sulfate

Total Dissolved Solids

Uranium

Vanadium

(Revised December 18,2008) RP-12

4.7 Stability Monitoring

Following concurrence from the WDEQ that restorationhas been achieved in the mining unit and unlessotherwise approved by LQD, a one-year stability periodis assessed to demonstrate that the restorationstandard has been adequately maintained. Thefollowing restoration stability monitoring program isperformed during the stability period:

1. The monitor ring wells (M-Wells) are sampled onceevery two months and analyzed for the uppercontrol limit (UCL) parameters, 'chloride, totalalkalinity and conductivity; and

2. Five samples will be collected from the MP-Wellsduring the stability period. A sample will becollected at the beginning, and then a samplewill be collected quarterly thereafter during thestability period. LQD and/or CR may determinethat additional stability sampling rounds wouldbe necessary. Samples will be analyzed for theparameters in Table 1.

In the event that unforeseen conditions (such assnowstorms, flooding, equipment malfunction) occur,the WDEQ will be contacted if any of the M-Wells orMP-Wells cannot be monitored within seven days of theregularly scheduled sampling date.

4.8 Well Plugging and Abandonment

Well plugging and surface reclamation will beinitiated once the regulatory agencies concur that theground water has been adequately restored andstabilized. All production, injection and monitorwells are abandoned in accordance with WDEQ-LQDNoncoal Rules and Regulations, Chapter 11, Section 8to prevent adverse impacts to ground water quality.Wells will be plugged and abandoned in accordance withthe following minimum requirements.

1. Wells are pluigged.. withi pplugging---mat-e-r-ial-s.---.cons-isst-i-ng-..of neat cement slurry, sand-cement grout, concrete, orbentonite chips.

2. To ensure proper placement of plugging material andprevent the movement of fluids into or betweenunauthorized zones or water-bearing strata, pluggingmaterials are pumped from the bottom of the well to

(Revised December 31,2008) RP-13 jV,

5ý 31j q9

the top of the well casing. The well is left open fora minimum of two days to allow settling of theplugging material, then the well is topped off towithin three feet of the land surface. The wellcasing is cut off to a depth of approximately two tothree feet and a cement or concrete plug is placed inthe top of the well casing at a minimum of two feetbelow the land surface. If cement is used to plug thewell within three feet of the land surface, a plug isnot required.

3. For abandoned monitor wells located within the monitorwell ring surrounding each mine unit, a plate isplaced on top of the plugging materials identifyingthe permit number, well number, and date of plugging.

4. The hole above the top of the plugging material isbackfilled to match the surrounding land surface.

5. To ensure the locations of abandoned wells areadequately identified, the boundaries of each mineunit and the location of the monitor well ring aroundeach mine unit are recorded as a deed notice withConverse County.

In the event that a well has artesian flow, inaddition to the above methodology, a concrete orcement plug will be placed within the well tocompletely seal off the artesian aquifer in accordancewith the rules and regulations of the Wyoming StateEngineer's Office.

5. BONDING

5.1 General

CR will establish and maintain suretyarrangements with the WDEQ covering the costs ofground water restoration, facilitydecommissioning, and surface _rec lamat.ion for. -the--....f-ft-d .areas- -and .....fafcilities involved. Thissurety (bond) estimate will be reviewed andadjusted annually and included as part of theAnnual Report.

(Revised December 18,2008) RP-14 3/

Attachment 1

HUP Restoration Schedule (Projected)

.~Il

07/03/08HUP RESTORATION SCHEDULE (PRC)

9.0 PV: 1 GWS + 8 ROGWS at 275 gpm

RO at 1100 extraction, 275 gpm bleedMU K 50

MU J59

mu 150

mu H ý

ONWNMk '\

49

02

- ~ N *\ '

MINN, \\

MU F 1iý

MU Dext 50

MUE"5

MU C 75

LegendSlProducdon/Prerestoration*GW$EROWMcieim

'MZ\\'

M UD 0\I I v I I I I .

ý008 2013 2018 2023 2028 2033

Table 1-1

Attachment 2

Highland Uranium Project

Mine Unit Extraction Rates and Pore Volumes

(YI*j.

<7X,,O

Highland Uranium Project

Mine Unit Extraction Rates' and Pore Volumes

MineUnit

GWS ExtractionRate ( GPM)

Ground WaterSweep PoreVolume(gallons)

Clean WaterInjectionPore Volume(gallons)

HUP MU-C 37.5 - 100 714,648,176HUP MU-D 25 - 70 2, 1167, 933 169,343,460HUP MU-D 25 - 70 16,358,760 130,870,080ExtHUP MU-E 25 - 70 78,331,196 626,649,566HUP MU-F 50 - 140 202,848,624 1,622,788,992HUP MU-H.. 25- -70 81,139,450. -649,115,597HUP MU-I 25 - 70 67,497,380 539,979,038HUP MU-J 50 - 70 66,817,020 534,536,160HUP MU-K 50 - 70 80,784,000 646,272,000

1 Mine unit extraction rates based on Conceptual

Approach to Restoration of Wellfields at Smith Ranch/HUP

by Robert Lewis dated July 30, 2008

( ~/',

Attachment 3

Projected HUP Water Disposal Balance

4

ATTACHMENT 32003 PRGI6cTK KW'WW tuokpnd Ieknce

SummatyAWERAE-(GPM)9PV- I GWS + 8 RO

20111 2 01I M131 2014 201.5 20161 20171 2 1 8 201 2021) 2022) 204) 20241 2025• 2027 2028 202)2001233 j Volme (gal Iwo200I 20M9 MW1HUP SAT- 2 *l1pro 20 20

IX pm:d 305 301 201 201 201 20 1 201 20120 ~I~rriT -4-9-RO Bleed 581 - I - I - I - I I - I - I - I . i . i . i -

HUP SAT-3S, prod_ 40 40 40 40 40 40 40 40 401 40 40 .401 40 30 ..

HUP C0ThlIdknw - 20 2020 2 20 20 2020 0 20 20

MUDGWS 44RD Blee 50 33 ".I•;

MUM5 -s5-C W -- -

FRODlad 46 50 50 50 "So , . . -

FM O Bleed 7 59M 1 100 300 so50 -_O__ __ __43_- i. ,; -Mr "•iUP WS -- 9 50 .5 10 0 7 - ,•'-- , - - ;,•:• ;

7.9A20,00627.4,M00

1.624.20.00G080,000

m32mmm99.2800

540.00,X0

S35.60.X0'M08U00

21.167.933169-W4ASC89.331=02

724.•46,17678,331.196

626",W.9616.358756

130.17•m00202.84&624

81.139•,45

649.115.39167A97.38,

646.817M2.

646.7L=05

RO Bleed 42 50 ,ý ,•s0 501 50 23! - I -GSWI - I 5

I , F~ROBleedESm£0 Bleed

s0 ; so LýJNoI so1 I s 10 -_ • -_I --'--.4-- -4 i -4 -

-~ I -+ - .48I-~-I -ý, "as FT-., -A -:

bv5ROBleed . I - I - I - 1 50 - 01 5,ns so 1 :1

P~quken-fL i ' S] 381ý3141 330I 355j 8J39 372n~. mI 3 1 'al... __M__ IJl r__1_5__1*MIJ.FbcvddbdM 5ma.n dwesnb~mhhtfwra~

1Wm,.800 0 0 0 0 j 0 0 0 0

93270 0 0 0 0 00 0 0 0 0 0 0 0-2 e8• 1 80 340 3. 10 0 3800 0 4 0 1• •W:t.le.: 20• • 2 0 20 20 20 20 20 20 2 0 10 0-1 0 0 0 0 0

raelHUPe RO u a.

.Dow w ta 40 V" W 1 .. 45- -45. 45 45 45 45 45 45 45 45 45 454 45 45 45 45 4 45 45 45 45 45Ome Wpo Ad Voom 33-27 - 75 75 75 75 7 75 75 75 75 75 7A 75 75 75 75 75 75 75 75 715bop0a p oW WagD-5 .75 751 75 75 5 75 75 751 751 75 75 751 75 75 751 75 75 751 75~7 751

HIP RM Feed Reiptremoft 356, 30 0 54 4 544 6W 600 78 832 1.0= M2 S32 00 332 20 4IM 384 200 200 Ml0 20 -52

S5AT2 500140 400 400 400 40 400 M 400 400 40 400 40 4 440 400 400 4W0 40 400 400 400 400 400 40

COi 400

AddMo~HU P RO Sptems2 0T1400 400 400 40 4 400 400 400 400. 400 4 400 400

9T0 3 m4 40 4 400 400 400 400 M 400 4RD Tlrevmte Cap xty I qholage 44 100 500 216 596 656 00 600 432 368 200 372 348 400 68 200 16 200 200 200 200 348

Rev~id •/'OMSR HUP Dbpawd RaqWrwnwft 9 PVARO Rej._ V

7' 49