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Memorandum in Response to Notice of Determination of Designation Mining Operation (DMO); DRMS File Numbers <br />M-1977-416, M-1978-039 HR, M-1977-285, M-1980-055 HR, M-1981-021 and M-1977-032. <br />NESHAPS Report <br />Denison monitors radon concentrations emitted from the ventilation holes at the mines as <br />part of the Environmental Protection Agency's (EPA) National Emissions Standards for <br />Hazardous Air Pollutants (NESHAPS) program and will be providing the EPA with a <br />routine report on this prior to March 31St 2008. This report will use the monthly data to <br />determine an annual emission rate estimate which, in conjunction with information about <br />local receptors, is input into the EPA's Comply-R computer model. This model is then <br />compared against the 10 millirem per year standard applicable to the nearest resident to <br />determine compliance or the need for further radon control. Test and model runs <br />~~,-: <br />conducted when these mines operated previously were compliant~w~ith. the NESHAP <br />exposure limit. No mine ventilation is currently occurring at;rth`e Van ~4 mine; however, <br />once mining operations resume, the same process will be followed. Denison will provide <br />,:r:F ~=~:.. <br />a copy of this report to the Division. ~~~~~~ ~'=~~~`~ <br />_-., <br />Phase 2 Preparation of the EPP <br />f z ~~ <br />The information gathered in Phase 1 will be used in the preparation of the EPPs in Phase <br />2. Rule 6.4.20 outlines Exhibit T -Designated Mirmg Operation Environmental <br />~:. <br />Protection Plan, and benison's proposed response to each~section of that plan is provided <br />below: ~ ~; <br />t~~.~ <br />Section 6.4.20 (1) - A description of how Denison will ensure compliance with the <br />provisions of the Act and Rules to protect all; ar`"eas,1that have the potential to be <br />affected by acid-forming or toxic produemgnatenals~will be provided. No <br />designated chemicals`-are}used on slte, therefore an Emergency Response Plan will <br />~, <br />not be required; rThe Dlvlson of Wildlife was recently consulted for the Topaz and <br />Sunday mines 'as pLart;of recent (fall of 2007) amendments to these permits. <br />Recommendations from this~agency-for the protection of wildlife are included in the <br />amended~~permtsffor these~sites, and this~mformation could be reiterated or referenced <br />in the~`EPP. Recent wildlife surveys have also been completed in the area for <br />submission to the BLNI,as partyof~an updated NEPA process for these mines. This <br />inforination and BLM`;bi'gloglstyrecommendations could also be provided to the <br />~~::,, <br />Divisional,-requested. Because of the close proximity of the Sunday and Topaz <br />mines to t1eWest Sunday, Denison anticipates that the information obtained on <br />wildlife for tles~etwonmmes would apply to the West Sunday mine. <br />Section 6.4.20 (2)'``=~ Denison believes that the existing maps the Division has on file <br />are sufficient to meet the requirements of an EPP, and will be incorporated into the <br />EPP. <br />Section 6.4.20 (3) -Denison will provide to the Division a list of monitoring <br />requirements of other agencies as follows: <br />• Colorado Department of Public Health and Environment (CDPHE) inspection <br />and reporting requirements for the Stormwater Management Plan and permit. <br />6 <br />