RADON VENTS 101 - Uranium Watch

RADON VENTS 101
Regulation of Uranium Mine Radon Emissions

La Sal Mountains - San Juan County, Utah
Road to Series of Radon Vents on BLM Land -
Residence (Receptor) to Right

Pandora Mine - La Sal Mines Complex

RADON AT URANIUM MINES
• Mine Safety and Health Administration (MSHA) regulates
worker health and safety, including radon gas exposure.
• Radon is a decay product of uranium; half-life of 3.8 days
• Radon decays into highly radioactive particles that can
lodge in lungs & cause cancer & other health affects.
• Radon must be removed from underground to protect
health of uranium mine workers.
• Vents part of La Sal Mines Complex that is accessible.

EPA RADON STANDARD:
40 CFR PART 61 SUBPART B
• Vents and mine openings bring fresh air into the mine
and/or exhaust radon gas and particulates from the mine.
• Dose standard for radon emissions from underground
uranium mines is 10 millirems per year.
• Standard is for mines producing over 100,000 tons of ore.
• Radon emissions measured at the vent or mine opening,
and data used to calculate dose to the nearest exposed
individuals at home, workplace, or school.

• Owner must submit annual compliance reports to the EPA
or, in Utah, the Utah Division of Air Quality.
• Utah is only state with authority over radionuclide
NESHAPS in 40 CFR Part 61; this includes mills.
• EPA retains some authority over radon NESHAPS.
• If out of compliance, owner must submit monthly
compliance reports until mine is in compliance.
• Owner is required to apply for and receive approval of
construction or modification of radon source:
40 CFR Part 61 Subpart A, §§ 61.07 and 61.08.
• Radionuclide NESHAPS promulgated in December 1989.

Track-Etch Radon Detector
Detection Method Not Approved by EPA

Beaver Shaft # 900 Vent
Private Land - Fenced
Probably to Keep Cows Out

Pandora # 2 Vent
Vent Used as Emergency Escapeway

• Other Vent Installation Authorizations
• In Utah, Div. of Oil, Gas & Mining authorization.
• US Forest Service: Authorization and public process.
• BLM: Requires authorization and public process.
• NEPA review is required for installation on federal lands.
• Installation requires land clearance, road construction,
destruction of vegetation, burial of drill cuttings.
• Small hole is drilled from top to underground mine, larger
hole drilled from below, waste rock enters mine for
removal to waste rock pile.

VENT OPERATION
What are the Problems?

• Vents emit radon, radioactive particulates, diesel fumes,
water vapor, dust, and emissions from explosives.
• Vents with fans on top are very loud. The sound travels
over a mile and can be heard in middle of La Sal.
• Radioactive particulates taken up by soil and water in
vicinity of vents.
• Ice forms on some vents in winter, requiring removal.
• No fencing for vents on public land
• No radioactive warning signs.
• Physical hazards from vents.

Pandora # 12 Vent
BLM Land - No Vent Riser - No Fence or Sign

Pandora # 5 Vent
Vent Grate Half Off - No Maintenance

Newly Installed Pandora Vent
Large USFS Area Cleared of Trees and Vegetation

Vent Installation Impacts

REGULATORY ISSUES
• Utah Div. of Air Quality (DAQ) regulatory program is a
MESS.
• Denison Mines Corp. opened Pandora Mine in 2009
without submitting required application.
• 13 La Sal Mines Complex emission sources have gone
through very flawed application and approval process.
• 18 La Sal Mines Complex emission sources have not
gone through application and approval process.
• Radon vented 1/4 mile from La Sal Elementary School.

• Denison was required to use lucas cell scintillometers
(Method A-7) to measure radon emissions, unless another
method was approved by EPA. Denison used track-etch
radon detector (Method A-6) without EPA authorization.
• EPA Notice of Violation in August 2010.
• UW recently discovered vent that Denison said was
plugged was not plugged. A new operational replacement
had been installed nearby without DAQ authorization.
• Public notice and comment not required for §§ 61.07 and
61.08 application/approval process for both Utah and EPA.
• Public can’t force enforcement via an administrative
process in Utah. I tried!

WHAT TO DO?
• Division of Air Quality
• Uranium Watch brought issue of non-compliance to Air
Quality Board.
• Proposed Rulemaking to bring Utah application/approval
under EPA Title V/Part 70 permitting program.
• Issues before May 5 Air Quality Board Meeting.
• Made allegation to EPA re DAQ program.

• EPA
• Rulemaking needed to bring EPA radionuclide NESHAP
program under Title V permit process.
• Must remove EPA area source exemption for radon
sources, or designate sources as “major sources.”
• Subpart A needs revision to improve application/
approval process.
• Subpart B needs revision. Subpart B standard should
apply to all underground uranium mines.
• Uranium mining should not be permitted near homes
and schools.

• Need for EPA Rulemaking to establish radon emission
standard for open-pit uranium mines.
• Open-pit mines proposed in Wyoming (Sheep Mt.),
Virginia (Coles Hill), and Oregon (Aurora Project).
• Need for regulatory guidance associated with
implementation of radionuclide NESHAPS program
• Need for honest, effective EPA regulatory program and
effective oversight of Utah regulatory program.
• Sarah M. Fields
Program Director
Uranium Watch
sarah@uraniumwatch.org
435-259-9450

Pandora # 5 Vent
Old Vent Fan