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MMRR Quarry, M-2004-067 <br />Response to Sept. 7 Adequacy Review <br />September 12, 2005 <br />Page 5 <br />22. The Applicant has proposed a Monitoring, Containment, and Control Plan to address the <br />potential for adverse impacts to human health, and the environment from radiation resulting from <br />quarrying activities and to ensure the operator's compliance with all applicable Federal, State, <br />and local regulations. The Applicant has also stated that they will apply fora CDPS discharge <br />permit at the appropriate time (prior to any discharge from the mining operation). The Division <br />requests that the Applicant commit to providing written demonstration of an approved CDPS <br />discharge permit from the Colorado Water Quality Control Division prior to any offsite discharge <br />or prior to the initiation of any blasting and quarry activities, whichever comes first. Please <br />respond. <br />The Applicant will provide written demonstration of an approved CDPS discharge <br />permit prior to any offsite discharge and prior to the initiation of any blasting and <br />quarry activities at the MMRR Quarry. <br />26. The Applicant has committed to monitor all on-site water holding structures for radioactivity, <br />and has proposed that if exceedances of WQCD water quality standards occur for three <br />consecutive monitoring periods that the Applicant will analyze the source of the exceedances and <br />remove the source rock to the quarry reclamation process. The Division requests that the <br />Applicant commit to the following measures: If an exceedance of an agreed upon WQCD water <br />quality radiation standard occurs, the ApplicanUOperator will immediately re-sample the effluent <br />to confirm whether an exceedance has occurred, and if the 2"d analysis affirms that an <br />exceedance of an agreed upon WQCD water quality radiation standard has occurred, then the <br />Applicant will submit to the Division a mitigation plan within 10 working days of the confirmed <br />exceedance. Please respond. <br />In the event of a data point in excess of the applicable water quality standard for <br />radiation, procedures for re-sampling and mitigation shall follow the Division's <br />framework response, as outlined in the comment above. <br />40. In conformance with Rule 6.4.12(1), the Division has calculated a total reclamation cost of <br />$903,800. Included in this estimate is an itemized cost for backfilling and grading shot rock at the <br />base of the highwall and bench sequence from a 1:1 slope to a 3:1 slope at a cost of $0.313/cy of <br />shot rock. This itemized cost eliminates the need for an itemized cost to transport the shot rock <br />to the waste rock disposal area for final reclamation. Please see the attached reclamation cost <br />estimate. Please advise the Division if any of the acreages used in the estimate need to be <br />revised. <br />Acreages incorporated into the calculation of the Division's reclamation cost <br />estimate appear to be reasonably accurate. The total cost of $903,800 for <br />reclamation from a condition of maximum disturbance is sufficiently apprehensive <br />of potential costs to ensure that the Applicant's financial warranty will cover any <br />contingency under the reclamation statutes and regulations. <br />