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CO DEPT HELTH HAZ 91AT Fax: 3036399833 Jul 29 2D05 13:48 P. 03 <br />Division of Minerals 8t Geology <br />July 29, 2005 <br />Page 2 <br />3. Coneeming air-monitoring issues, the regular monitoring of gross alpha/gross beta radiation, <br />as a screening procedure for filtered airborne particles is appropriate. Total suspended <br />particles and PM10 samples should be examined A monthly sampl{rtg interval is <br />appropriate. Samples with elevated measurements can be further eharacterized by isotopic <br />analysis. <br />The Permits Unit of the Water Quality Control Division offazs the following comments, since the <br />Mining Operation could require a Colorado Dischazge Permit under 5 CCR 1002-6]. <br />4. .Minimally, the operation would require a storm water permit. Under 5 CCR 1002 61.4(3) <br />".Facilities proposing a sew discharge of storm water associated with industrial activity shall <br />submit an application 180 days before that facility commences industrial activity". Tha <br />facility can access permit particulars on our website: <br />h~.pt '//www cdpi}g state co us/w /q_PermitsUriit/wgpdnmt html#ConstructionFormsGuidance <br />5. )f the facility expects to discharge process water to state waters, then they would need to apply <br />for a Colorado Discharge Permit (CDP) under 5 CCR 1002 61.4(1) and the application would <br />need to be submitted at least 180 days before commencement ofthe discharge. (See S CCR <br />1002 61.4(1)(c)). Also, the facility can Sad online guidance at: <br />6. The radioactive limit of the discharge under a discharge permit would depend on water <br />quality standards for the receiving stream segment. If the stream segment has zero low flow, <br />then the limit would be the moat restrietivo at (S CCR 1002-31.1 I(2)): <br />1. Gross Aipha < 15 pCi/L <br />2. Combined Ra226 and Ra228 < 5 pCi/L <br />3. Uranitmn < Sug/L• (new EPA rule) <br />4. Uranium would ba dependent on water hardness of receiving stream <br />segment (5 CCR 1002-31.16 Table iii). <br />5. Thorlimt 230 and 232 < 60 pCi/L <br />The Air Pollution Control Division, Stationary Sources Program (APCD S5P) has provided the <br />following responses for inclusion in this letter. <br />APCD 5SP does regulate air pollutant emissions from mineral development activities. If <br />emissions from these activities exceed certain thresholds, the owners/operators of these <br />activities are required to submit notifications of pollutant emissions to APCD SSP sad obtain <br />air quality coastruedoa permits. However,'APCD SSP's aotificatioa/permitting requirrementa <br />for quarries focus on pollutants such as particulate matter (e.g., duet) and combustion gases <br />firnn blasting operations and fuel-homing sources like stationary lrrtemal combustion <br />engines, and not on radioactive mlaetels per so. <br />