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CO DEPT HELTH HA2 MAT fax: 3036399833 Jul 29 2005 13:49 P. OA <br />Division of Minerals & Geology <br />Iuly 29, 2005 <br />Page 3 <br />Along with many other chemical compounds aad classes of compouads, radionuclides are <br />regulated as hazardous au pollutants (FIAPs). The regulatory standards for HAPa, including <br />radionuclides, are expressed on a mass. emission rate basis sad not on the basis of <br />radioactivity levels. The notification threshold for radionuclides ranges from 50 to 250 <br />pounds per year of uncontrolled actual emissions depending on release height and the <br />distance to the property line. Air-Permit requirements specific to radionuclides would not <br />become applicable until potential emissions reached a level of ten tons per year. <br />8. In certain cases, APCD SSP has required mining operations to conduct particulate matter <br />ambient air monitoring for a period of time following the startup of the source. In these cases, <br />based on the results from predictive emissions modeling or other data reviewed during the <br />' 'permitting process, APCD SSP had concerns that the National Ambient Air Quality Standard <br />for particulate matter could be exceeded at receptors in areas adjacent to the mine. The <br />monitoring was required to demonstrate that compliance with the standard was being <br />achieved. APCD SSP does not have specific standards or guidelines for airborne <br />concentrations and ambient air monitoring of radionuclides. APCD SSP defers to the <br />recommendations made by RMU. <br />If you have any questions concerning Air Quality issues please call Roland Hea at (303) b92-3252. <br />Water Quality issues should be directed to Gary Beers at (303) 692-3524. Radiation management <br />questions should be directed to Edgar Ethington at (303) 692-3438. If you would like to set up a <br />meeting, please call me at (303) 692-3438. <br />Radiation Management Unit <br />Compliance Program <br />CC Terry Goad; AGO <br />Jefferson County Health Department <br />Sincerely, <br />