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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 most useful and expedient. The Division will forwazd 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 level(s) require blast intervention. The Division will forward the CDH recommendations 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 not 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 detemvnations. 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 appear. 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 hazardous 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 standazds that would provide a measurable benchmazk for uranium dust safety at the MMRR 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 applicant/operator to collect, at a minimum, a 1-time representative sampling of ambient background radiation levels from the rocks at the site; however, we aze 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