PERMFILE41904

• Permit No: M2004067
• IBM Index Class Name: Permit File
• Doc Date: 8/19/2005
• Doc Name: 2nd Adequacy Response
• From: Banks and Gesso LLC
• To: DMG
• Media Type: D
• Archive: No

MMRR Quarry, M-2004-067
Response to June 30 Adequacy Review (as amended)
August 19, 2005
Page 9
21. Blasting Plan -The applicant has indicated that a blast vibration analysis and the on-going
blast monitoring plan covering all affected areas and structures will be submitted to the Division
prior to commencement of blasting. It is the Division's position that the blast vibration analysis
and blasting plan, per Rule 6.4.4(1), is an integral component of this application and must be
provided with all of outlined in Allen Sorenson's January 25, 2005 Memo (see attached copy).
The blast vibration analysis and blasting plan must also include a detailed assessment of the
possible surface and subsurface impacts, a monitoring plan that will be used to detect the
presence or absence of offsite impacts, and proposed mitigation measures that will be
implemented in the event a peak particle velocity of 0.75 ips is detected at any structure not
owned or controlled by the quarry operation, or a peak particle velocity of 0.50 ips is detected at
any older structure with plaster-on lath walls that may be within the zone of influence of quarry
blast ground vibrations.
Please see the attached report submitted by Lyman Henn, Consulting Engineers.
22. The applicant has proposed a Monitoring, Containment, and Control Plan to address the
potential for adverse impacts to human health, and the environment from uranium mineralization
resulting from quarrying activities and to ensure the operator's compliance with all applicable
Federal, State, and local regulations. During the previous review period, the Division met with
representatives from the Air Quality Control Division and Radiation Management Program of
CDPHE to discuss the concerns expressed by objector I.L. Turner in reference to uranium
mineralization from quarrying activities. As a result of our discussion, the Division believes it is
appropriate for the applicant's Monitoring, Containment, and Control Plan to address the
presence and impacts of radioactivity rather than just for uranium. The Division recommends that
you contact the appropriate CDPHE agency to assess the necessary monitoring requirements
and protocol. The attached response from CDPHE to the Division's request for information is of a
general nature and not specific to your proposed operation. You should contact CDPHE for
guidance specific to your proposed operation and then submit a revised plan to the Division for its
review.
Please see the attached report submitted by Paul Banks
23. The applicant has proposed to "collect drill cuttings from of least one (1) representative
sample point and promptly perform assay work for uranium content." In order fo ensure that your
proposal is adequate, the Division recommends that you contact the CDPHE for guidance
specific to your proposed operation regarding this issue and then submit any additional
information and revision to your proposal to the Division for its review.
Please see the attached report submitted by Paul Banks.
24. The DMG has no jurisdiction over airborne radioactive dust. The Division recommends that
you contact the CDPHE for guidance specific to your proposed operation regarding this issue.
Please keep in mind that Rule 6.3.6 requires applicants to list in its application all permits or
licenses held or to be sought in order to conduct the proposed mining operation.
Since the DMG has no jurisdiction over airborne dust, no technical review is
warranted on this subject. We also note that Rule 6.3.6 is applicable to
applications for 110 Limited Impact or 111 Special Operations, not 112 Regular
permits. This application is fully compliant with the analogous, relevant rule
(DMG Rule 6.4.13); see below.