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Division of Minerals & Geology <br />July 29, 2005 <br />Page 2 <br />3. Concerning air-monitoring issues, the regulaz 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 sampling interval is <br />appropriate. Samples with elevated measurements can be further characterized by isotopic <br />analysis. <br />The Permits Unit of the Water Quality Control Division offers the following comments, since the <br />Mining Operation could require a Colorado Dischazge Permit under 5 CCR 1002-61. <br />4. Minimally, the operation would require a storm water permit. Under 5 CCR 1002 61.4(3) <br />"Facilities proposing a new dischazge of storm water associated with industrial activity shall <br />submit an application 180 days before that facility commences industrial activity". The <br />facility can access permit particulazs on our website: <br />httn://www.cdohe.state.co.us/wg/PennitsUniUwgcdpmt. htm]#ConstructionF ormsGuidance <br />5. If the facility expects to discharge process water to state waters, then they would need to apply <br />for a Colorado Dischazge Permit (CDP) under 5 CCR 1002 61.4(1) and the application would <br />need to be submitted at least 180 days before commencement of the dischazge. (See 5 CCR <br />1002 61.4(1)(c)). Also, the facility can find online guidance at: <br />http://www.cdphestate. co.us/wq/PermitsUnit/wq cdpmt.html#Industrial%20and%20Domestic. <br />6. The radioactive limit of the dischazge under a dischazge 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 most restrictive at (5 CCR 1002-31.11(2)): <br />1. Gross Alpha < 15 pCi/L <br />2. Combined Ra226 and Ra228 < 5 pCi/L <br />3. Uranium < Sug/L (new EPA rule) <br />4. Uranium would be dependent on water hardness of receiving stream <br />segment (5 CCR 1002-31.16 Table iii). <br />5. Thorium 230 and 232 < 60 pCi/L <br />The Air Pollution Control Division, Stationary Sources Program (APCD SSP) has provided the <br />following responses for inclusion in this letter: <br />7. APCD SSP 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 and obtain <br />air quality construction permits. However, APCD SSP's notification/permitting requirements <br />for quames focus on pollutants such as particulate matter (e.g., dust) and combustion gases <br />from blasting operations and fuel-burning sources like stationary internal combustion <br />engines, and not on radioactive minerals per se. <br />