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depend on, among other factors, the porosity /permeability of the sandstone and the degree of fracturing of the surrounding geology. None of the above physical and geophysical chemistry issues have ever been discussed publicly by BLR or its consultant, nor considered in this application. The Division implicitly recognized the potential for environmental harm in its response to the first modification request by BLR by its requirement for hydrological studies of the site and its surrounding area. These studies were never done since the company withdrew its request. There appears to be a serious contradiction between the Form 2 application and Mr. Siglin's cover letter with respect to the installation of monitoring wells to detect any excursion of radiologically contaminated water. Whereas the cover letter refers to one monitoring well to be constructed down gradient from the bore hole, section 12F of the application refers vaguely to clusters of monitoring wells with little information about their proposed location or purpose. Since it is acknowledged that the entire Tallahassee watershed (with approximately 600 large rural residential parcels -- more than one -third of which are currently occupied) hosts four to five aquifers supplying drinking water to many more than 100 domestic water wells; and since the U.S. Geological Survey, Pueblo Office hydrologist confirmed to TAC that there has never been a mapping of them, there is reason to be concerned that there is considerable cross - communication among the aquifers and to the many local springs and streams. The potential for irreversible contamination of the sole local source of drinking water, for the local residents as well as livestock and wildlife, cannot be ignored -- even for the limited activity as described in the modification request. TAC respectfully requests that BLR be required to conduct comprehensive hydrological and geohydrological studies for the entire watershed prior to Division approval of the requested activity. The utilization of Underground Bore Hole Mining as an in -situ uranium mining process is not currently contemplated in the Hard Rock /Metal Mining Rules. BLR's proposed application is a case of first impression, not only for Colorado but for the United States uranium mining industry in general. The introduction of an highly oxidizing water solution to the underground ore body is similar to In -Situ Leach Solution Uranium Recovery (ISL or ISR) and must require UBHM to be scrutinized very carefully for its potential to do the same environmental harm to the groundwater that led to recent changes to the MLRA and strengthened protective rules in the Mining Rules, as well as to the newly proposed EPA rules. ISL is subject to concurrent jurisdiction of DRMS and CDPHE as both a mining and milling activity. TAC believes that UBHM should also be subject to CDPHE jurisdiction -- which has not yet considered the issue. The NRC has defined the dividing line between uranium mining and milling in its Health Physics Position 184. In HPPOS 184 it states that mining ends and milling begins when the gross appearance and chemical nature of the ore changes, leading to a changed radiological environment which has the potential to impact the health and safety of workers and others. TAC's position is that the introduction of high pressure water underground and the initial fragmentation of the ore body is hydraulic mining -- in -situ mining subject to DRMS jurisdiction. Once the ore 3