2009-06-08_REVISION - M1997032 (25)

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4.0 COMPLIANCE PLAN AI JD RECORD-KEEPING REQUIREMENTS • 40 CFR 61.01 specifies that the owner or of a stationary source subject to a NESHAP may be required to obtain a Title V operating permit if the facility is a major source for HAPs. There is not yet a federal definition of "major" for radionuclidesources since radionuclide emissions are not measured in terms of mass (EPA 1994, EPA 2000). The Van 4 Mine is a minor source of both criteria pollutants and HAPs in terms of mass-based emissions; therefore, a Title V operating permit will not be required for these mines to demonstrate compliance with tli? Underground Uranium Mine NESHAP. This document presents a compliance plan for demonstrating NESHAP. Denison will comply with all appl also comply with any new requirement that Permits. As prescribed by 40 CFR 61, Subpart B, Deni procedures described in 40 CFR 61 Appendix Underground Uranium Mine Vents"). Specifi Sections 1.1.1 ("Continuous Measurement") with the Underground Uranium Mine requirements of 40 CFR 61, Subpart B. Denison will ; effective during the term of the Construction will conduct Rn-222 testing in accordance with the Method 115, Section 1 ("Radon-222 Emissions from ly, Denison proposes to test Rn-222 emissions per 1.2 ("Test Methods and Procedures"). Section 1.1.1 specifies that the Rn-222 concentration shall be continuously measured at each mine vent whenever the mine ventilation system is operational. Weekl} Rn-222 emission rates will be calculated and recorded for each week utilizing monthly radon concentrati Denison will begin testing emissions from the prescribed in 40 CFR 61.13. Method 115 also measured at least four (4) times per year. Den data and quarterly ventilation rate measurements. rt holes within 90 days after initial mine startup, as that each mine vent exhaust flow rate must be will comply with this requirement. Method 115, Section 1.2 specifies test methc Appendix A, Method 1), and velocity and vc Two options are presented for analysis of Rr B, Method 114). Denison proposes to use N commercially-available, alpha track Rn-222 monthly basis throughout the report year. D requirements at other operational mines. Rai the end of each month, a new radon detector detectors will be sent to a qualified off-site 1, to be used to determine velocity traverses (40 CFR 60 flow rates (40 CFR 60 Appendix A, Method 2). (Method A-6 or Method A-7 of 40 CFR 61 Appendix )d A-7 to analyze Rn-222. Denison will use ctors to continuously collect Rn-222 emissions on a on has used this methodology to fulfill similar EPA detectors will be placed in the mine vent air streams. At be placed in each mine vent air stream and spent radon atorv to be read. • w?ra - us p:nniuing\ wlorado\- 4\air p-iisunday min s c-pli:mcc plan_draft.dm 4-1