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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 />conducted when these mines operated previously were compliant with the NESHAP <br />exposure limit. No mine ventilation is currently occurring at the Van 4 mine; however, <br />once mining operations resume, the same process will be followed. Denison will provide <br />a copy of this report to the Division. <br />Phase 2 Preparation of the EPP <br />The information gathered in Phase 1 will be used in- he preparation of the EPPs in Phase <br />2. Rule 6.4.20 outlines Exhibit T -Designated Mining Operation Environmental <br />Protection Plan, and benison's proposed response to each section of that plan is provided <br />below: <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 areas that have the potential to be <br />affected by acid-forming or toxic producing- materials :will be provided. No <br />designated chemicals are~used on site; therefore an Emergency Response Plan will <br />not be required. The Division of Wildlife was recently consulted for the Topaz and <br />Sunday mines as part 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~:permits for these sites, and'this information could be reiterated or referenced <br />in the EPP. Recent wildlife surveys have also been completed in the area for <br />submission to the BLM as part of'an updated NEPA process for these mines. This <br />information and BLM biologist recommendations could also be provided to the <br />Division as requested. Because of the close proximity of the Sunday and Topaz <br />mines to the West Sunday, Denison anticipates that the information obtained on <br />wildlife for these:-two mines 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 />