PERMFILE45799

• Permit No: M2004067
• IBM Index Class Name: Permit File
• Doc Date: 11/21/2005
• Doc Name: Exhibit 162
• From: City of Black Hawk
• To: DMG
• Media Type: D
• Archive: No

whether monitoring blast hole cuttings prior to blasting would be an advisable
way to monitor. We anticipate that measuring radiation from drill hole cuttings from each blast hole may
be mosf useful and expedient. The Division will forward the CDH recommendations to the applicant as
soon as they become available.
24. The applicant has proposed to monitor for "airborne and waterborne uranium." The Division
acknowledges this may seem advisable; however, monitoring cuttings (or drill holes) prior to blasting and
having a blast mitigation plan in place to handle anomalously radioactive blast dust may be the most
effective method to control offsite contamination. As a result, the Division has requested the CDH to
provide a recommendation for measuring radioactive levels at the quarry and determining what ]evel(s)
require blast intervention. The Division will forward the CDH rewramendations to the applicant as soon as
they become available.
25. The applicant has indicated that the operator will contact the Division immediately if any monitoring
result or field observation indicates that uranium ore is present on the site as a substantial resource. This is
pot an acceptable monitoring practice. The Division's concern is mobilization of dust bearing radioactive
minerals in concentrations that might adversely affect receptors offsite. Monitoring must consider toxicity
rather than uranium grade or ore detemilnations. Please respond
26. The applicant has committed to monitor for the presence of uranium in runoff from the site. The
Division is currently in the midst of consultation with representatives of the Colorado Department of
Health & the Environment to clarify suggested monitoring parameters and action levels. The Division will
forwazd this information to the applicant as soon as it becomes available.
• 27. The applicant has proposed to monitor particulate and dissolved uranium in all waters concentrated on
the site at a point of dischazge for compliance with the radioactivity standazd of 40 pCi/L or natural
background, whichever is higher. This criteria precludes measurement of other radioactive materials. It
may be more effective for the applicanUoperator to evaluate blast hole cuttings for radioactivity, and have a
mitigation plan should high levels appeaz. The Division has consulted with the CDH on this matter and
will forwazd their recommendations to the applicant as soon as they become available.
28. The applicant has discussed a variety of mitigation measures including pre-moistening of rock and
other dust suppression techniques. Please verify if the operator will be storing toxic and/or hazazdous
materials on site that will be used as a mitigation measure. If so, please explain the storage and control
methods to be used
29. The applicant has noted that there are no "ambient air quality standards that would provide a
measurable benchmark for uranium dust safety at the MM1tR Quarry." Based on our discussions with
CDH representatives, there aze health advisories for radioactivity. The applicant should be prepazed to
monitor and intervene at some level of radioactivity. Please respond.
30. The applicant has stated that a "preliminary geologic assessment prior to operations will provide [no]
useful answers regazding the potential effect of mining on any mineralized uranium. It appeazs that it may
be necessary for the applicanbopentor to collect, at a minimum, a 1-time representative sampling of
ambient background radiation levels from the rocks at the site; however, we are awaiting guidance from
the CDH specialists on this matter and will forwazd their comments to the applicant as soon as they
become available.
31. FueU0i1 Storage The applicant has specified that fuel and oil needed for equipment will be stored on
site and that primary containment will be an engineered impoundment enclosing the tank site, with a