National Emission Standards for Hazardous Pollutants (NESHAP) for Radon Emissions from Operating Mill Tailings (Renewal)

On May 2, 2014, EPA proposed revisions to the radon emission standards for 40 CFR Part 61, Subpart W. Included in the proposed revisions is a requirement that owners and operators of uranium recovery facilities maintain specific records pertaining to the design, construction and operation of the uranium tailings impoundments, both conventional and nonconventional, and heap leach piles. These records will be retained at the facility and contain information regarding the approved design of the impoundments and/or heap leach pile, including but not limited to, all tests performed that prove the liner is compatible with the material(s) being placed on the liner. For nonconventional impoundments this requirement also includes records showing compliance with the requirement to continuously maintain one meter of liquid in the impoundment. For heap leach piles, this requirement includes records showing that the 30% moisture content (by weight) of the pile is continuously maintained. Apart from the design documents, which are required for the application submitted under Subpart A of 40 CFR part 61, records regarding the inspections to determine the one meter liquid requirement for nonconventional ponds and the records showing compliance with the 30% moisture level in heap leach piles are new requirements for collection of information that is not covered under the existing ICR for NESHAPs, EPA Number 1100.13, OMB Number 2060-0191. Information collected is used by EPA to ensure that public health continues to be protected from the hazards of airborne radionuclides by compliance with these standards. If the information were not collected, it is unlikely that a violation of these standards would be identified and, thus, there would be no corrective action initiated to bring the facilities back into compliance. Compliance is demonstrated through inspection testing and/or moisture content calculation. All facilities are required to maintain their records for 5 years. The rationale for the 5 year record keeping requirement is from the Code of Federal Regulations (CFR), 40 CFR Part 61, Section 61.255. In some cases, they also report their results to EPA.

The latest form for National Emission Standards for Hazardous Pollutants (NESHAP) for Radon Emissions from Operating Mill Tailings (Renewal) expires 2020-12-31 and can be found here.