Draft Environmental Impact Statement for Roca Honda Mine

Regulatory Review
Chapter 3. Affected Environment and Environmental Consequences
New stationary sources of emissions may be subject to both Federal and State permitting
requirements. These requirements include, but are not limited to, New Source Review, Prevention
of Significant Deterioration, and New Source Performance Standards for selected categories of
industrial sources. The rules for NMED’s Air Quality Program Laws and Rules are found in the
New Mexico Administrative Code (NMAC). NMAC Title 20 Chapter 2 Part 7 includes emission
standards and control requirements on both a pollutant specific basis and process/equipment/
industry specific basis. NMAC Title 17 Chapter 2 also set forth the permitting requirements for
stationary emission sources and construction emissions. Given the variety and complexity of the
activities at the RHR site, case-by-case determinations would be necessary to determine if new
stationary sources of air emissions would require permitting.
National Emission Standards for Radon Emissions from Underground Uranium Mines, apply to
an underground uranium mine that (a) has mined, will mine, or is designed to mine over 100,000
tons of ore during the life of the mine, or (b) has had or will have an annual ore production rate
greater than 10,000 tons, unless it can be demonstrated...that the mine will not exceed total ore
production of 100,000 tons during the life of the mine (40 CFR 61.20). As discussed in more
detail below, RHR would comply with national standard radon-222 (40 CFR 61.22) as annual
proposed production would be greater than 10,000 tons per year.
To reduce fugitive emissions generated at the mine surface, areas belowground would be
backfilled with waste rock. However, due to the expansion of the waste rock as it is mined, some
waste rock would still be placed at the surface. Water spray would be used to reduce dust
emissions from disturbed areas of the surface where waste rock is placed. In addition, BMPs
would be required and implemented for activities associated with the proposed action. The mine
development, operation, and reclamation would be accomplished in full compliance with current
New Mexico regulatory requirements, with compliant practices and/or products. These
requirements include:
• Smoke and visible emissions (NMAC 20-2.61)
• Open burning (NMAC 20-2.60)
• Emissions from gas burning equipment (NMAC 20-2.33)
• Emissions from oil burning equipment (NMAC 20-2.34)
This listing is not all-inclusive; RHR and any contractors would comply with all applicable New
Mexico air pollution control regulations.
3.4.2.2.4 Radon-222 Emissions
The environmental consequences of radon-222 emission to the air from the proposed action are
predominantly related to human health concerns from the radiation dose resulting from breathing
radon-222 and its short-lived decay products. As discussed previously, Federal law limits the
radiation dose from radon-222 emissions from uranium mines to any member of the public at 10
mrem/yr (40 CFR 61.22). The Federal limit of 10 mrem per year is 4.7 percent of the average
effective dose from background sources of radon-222 and its short-lived decay products of 212
mrem per year to the U.S. population (NCRP, 2009).
DEIS for Roca Honda Mine, Cibola National Forest 189