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MMRR Cluarry, M-2004-067 Response to Sept. 7 Adequacy Review September 12, 2005 Page 3 Also, it is the Division's expectation that the applicant/operator develop a blasting method or blasting pattern such that radioactivity levels in blasting dust will not exceed applicable radiation levels in the blast dust at their permit boundary. Therefore, the Division suggests that the Applicant provide a plan that minimizes, to the extent possible, the potential for generation and transport of radioactive dust. Such plan must include Best Management Practices (BMP's) to be implemented prior to, during, and after blasting operations. Please respond. The Division has acknowledged that air emissions permitting is the province of the Colorado Department of Public Health Environment (CDPHE). Specifically, as the Division correctly noted in its August 2, 2005 adequacy supplement, "The DMG has no jurisdiction over airborne radioactive dust." Based on discussion of this adequacy comment with the DMG, it appears that the Division is attempting to differentiate its permitting considerations from air emissions permitting based on control of the source, rather than the effects on other properties. This distinction, however, is difficult to define, if it exists at all in practice. The Division's comment in the most recent adequacy letter references effects at the permit/property boundary, which is practically the same as the regulatory concern of a state air emissions permit. And, like the DMG, an air emissions permit is also concerned with control of dust sources. To the extent that there will be air emissions of concern at the proposed quarry site, CDPHE has adequate jurisdiction to compel air quality mitigation measures, which the Division may be duplicating preemptively in this case. Also, we note that this comment appears to presume that quarry blasting will generate radioactive dust. However, based on geologic evidence and asite- specific survey of radioactivity levels in native rock, the assumption that radioactive dust will be generated, especially as a justification for extensive prophylactic mitigation measures, is highly questionable. Available evidence indicates that there is no significant or unusual source of radioactivity in rock on the proposed quarry site. Based on concerns regarding radioactivity, the applicant has agreed to a monitoring program, with mitigation appropriate to the results of monitoring. However, until there is evidence of aradiation-related risk, there is no reasonable basis to implement measures specifically intended to mitigate radioactive dust. The applicant and its consultants are unaware of BMPs that specifically address sources of radioactive dust from quarry blasting. Some mitigation techniques are suggested for general dust control. For example, in persistent dry conditions, it may be appropriate to pre-wet the fall zone for rock. The operator will also monitor wind conditions and adjust the blast schedule to avoid blasting at times when it is likely that blasting could generate a dust plume that would be dispersed by wind to inhabited structures in the vicinity. Generally, no blasting will occur when prevailing westerly winds averaging over 20 mph are encountered on the site.