Laserfiche WebLink
<br />Mr. Dick Gamewell <br />June 22, 1982 <br />Page - Seven - <br />Air Pollution Control Division <br />Comment No. 1 - "This is in response to your request to review an <br />amended radioactive materials license to the Cotter Corporation for <br />their uranium ore crusher sorter at the Schwartzwalder mine near <br />Golden, Colorado. On March 22, 1979, the Division issued an air <br />pollution emission permit (C-12,244) for part of this activity. The <br />air permit included processing of 600 tonsJday of the ore, crushing <br />it and hauling it over 7.6 miles of unpaved road. <br />We note that the amended license specified processing up to 675 tons <br />~rday of uranium ore and in addition to the crushing and hauling <br />includes such activities as stockpiling and conveying of reject <br />material and ore grade material; construction of water treatment <br />facility and impoundment ponds; and reclamation activities. Each of <br />these activities under certain conditions are subject to fugitive <br />emission permits and should be reviewed by APCD for their cumulative <br />impact on air quality in the Golden area. The area is considered <br />non-a;:~inment for particulates and accordingly a new or modified <br />source must meet specific air quality limits to be granted an eir.ission <br />permit. The activity should also be given an opportunity for the <br />public to comment on. Total application processing time is 135 days <br />from receipt of a complete application." <br />Response to Comment No. 1 - With respect to the "processing" rate <br />contained in air emission C-12,244, Cotter requests that the ore <br />"processing" rate contained in radioactive materials license be <br />changed to 600 tons/day (on an annually averaged basis) to coincide <br />with the air emissions permit. Processing in the context of an ore <br />sorter includes only ore handling activities; no chemical processing <br />in the traditional mining or metallurgical sense of the word occurs <br />at the site. <br />In addition, Cotter's air emission permit application addressed all <br />activities at the ore sorter, including crushing, hauling, and stock- <br />piling and conveying ore and waste material. Referring to the APCD's <br />emission factors for mining operations, the emissions for stockpiling <br />and conveying were determined to be zero due to the fact that the <br />fines are washed from each rock fragment and because the conveyors are <br />covered. Cotter's calculations were validated by an on-site <br />inspection of the ore sorter by representatives from the APCD. <br />It should be noted that the construction activities for the new water <br />treatment facility will affect less than one acre, which exempts this <br />activity from the APCD rules and regulations. In addition, reclamation <br />activities are not scheduled to occur for several years. At the time <br />these activities are about to be undertaken, Cotter will comply with <br />