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From: Doc. ~ RECEIVED Division of Minerals and Geology Department of Natural Resources MAY 2 4 2005 1313 Sherman St. Rm. 215 Denver, Colorado 80203 pivision ~f Mine[els and Geology Attn: T.A, Schreiner Certified Mail-Return Receipt Reauested May 20, 2005 RE: MMRR Quarry, M-2004-067 Response by Banks and Gesso, LLC to DMG Adequacy Review (March 23, 2005) The Banks and Gesso, LLC submittal was reviewed recently by the writer at the Gilpin County Courthouse. Copies of the complete response and accompanying maps were then obtained. The following observations/comments are made concerning only parts of this material: Pages 6-11 Uranium Mineralization. 1) P.6, para. 6: "We reviewed the DMG record for another rock quarry located in a relatively similar position on the fringe of this belt of uranium mineralization and found no evidence of technical review, operations standards, reclamation standards, or enforcement activity stemming from a concern that uranium would be released from that site." (emphasis mine) Does this lack of investigatory activity some ten years ago imply that no problem might exist8 2) P. 7, para. 2: I am pleased to note that Banks and Gesso have chosen Option 2 -one of three options proposed by the DMG in their Jan. 21, 2005 Adequacy Review Commentary. 3) P. 7, para. 5: Drill Cuttings - ..."operator will obtain drill cuttings from at least one representative sample point" (emphasis added). Given the discrete nature of known radioactive mineral occurrences in the general area (see below), it would be very unlikely that a representative sample of the volume of rock about to be shot at end of shift could be represented by one or two holes. A reading of the literature* describing the various occurrences in the three- county area of the proposed quarry provides descriptions of mineralization in veins, dikes, shear zones - as generally cross-cutting, planar, discontinuous, tabular. As "six foot thick vugs in pegmatites". As veins cutting schists, mineralization in pods and lenses, iron-stained shear zones, and in faults and breccias. Again-one or two or three holes would not constitute an adequate test. *Radioactive Mineral Occurrences of Colorado, Bulletin 40. Nelson-Moore, Collins and Hornbaker, Colorado Geological Survey, 1978, 1058 p.