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emissions (Curies) anticipated. The emission factor can be used to estimate the annual radon emissions, <br />which then can be used as a source term for the COMPLY-R model runs. Any discharge that will result <br />in increased emissions, including venting a mine that has been left stagnant and the other conditions <br />specified above, should be included in the emissions estimate in your supplemental application. <br />Alternately or additionally, Energy Fuels may wish to present additional research to supplement the <br />development of a source term. If 40 CFR Part 60 Appendix B Method A-7 ("Method A-7") data will be <br />used as part of the development of a COMPLY-R source term to estimate emissions from the <br />Whirlwind Mine for this application, the concerns outlined in EPA's July 21, 2010 letter to Denison <br />Mines (attached) must be addressed. If Energy Fuels chooses to use Method A-7 as a radon detection <br />method when in operation, you must submit a separate application to EPA requesting approval for use <br />of that method. As you are aware, Method A-7 has not been approved by EPA as an alternate method <br />for radon-222 analysis at the Whirlwind Mine and EPA approval is required prior to use. <br />EPA is also requesting more detail regarding the operating plan, specifically with regards to the <br />number of hours each day and days per year the mine will be venting. This information is important in <br />determining the frequency in which Energy Fuels will be venting stagnant air from the mine workings <br />and in estimating annual radon-222 emissions. We also suggest that Energy Fuels contact Utah <br />Department of Environmental Quality regarding timing and compliance with these regulations for vents <br />that will be located in Utah. We also request that Energy Fuels provide us with a timeline on the <br />various phases of construction planned at the Whirlwind Mine and specify for which construction <br />phase(s) this application is for. <br />If you have any questions, or for further discussion, please contact Dr. Angelique Diaz of my <br />staff at (303) 312-6344 or diaz.angelique@epa.gov. <br />Sincerely., <br />- - 1?(V ?,? <br />Stephen S. Tuber <br />Assistant Regional Administrator <br />Office of Partnerships and Regulatory Assistance <br />Enclosure <br />cc: J. Morris, Utah Division of Air Quality <br />R. Means, Colorado Division of Reclamation, Mining and Safety <br />C. Pray, Colorado Air Pollution Control Division <br />S. Gerwe, Grand Junction Bureau of Land Management <br />2