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monitor for "uranium," I believe they should change the text and agree to <br />monitor/sample for "radioactivity," depending of course on CDPHE's <br />recommendation. <br />3. The operator's stated that a "preliminary geologic assessment prior to <br />operations will provide [no] useful answers regarding the potential effect of <br />mining on any mineralized uranium." It may be necessary to collect <br />background radiation monitoring; however, we should await a response <br />from CDPHE. <br />4. The operator proposed to "obtain drill cuttings from at least one <br />representative sample point and promptly perform assay work for uranium <br />content. <br />We have asked the CDPHE to advise whether monitoring blast hole <br />cuttings prior to blasting would be an advisable way to monitor. I would <br />anticipate that measuring radiation from drill cuttings from each blast hole <br />may be most useful and expedient. Analysis via scintillometer rather than <br />chemical analysis is to be considered by CDPHE. Depending on CDPHE <br />input, it may be necessary to run chemical analyses on highly radioactive <br />samples, based on scintillometer readings, but the particulars of that need <br />await CDPHE response. <br />5. The operator promised to contact the division if "uranium ore" or "a <br />concentrated deposit that would yield marketable uranium ore" is <br />detected. This is not an acceptable monitoring practice. Uranium ores <br />can easily escape visual recognition, and DMG cannot depend on such <br />observations Moreover, the definition of "ore" is temporal and depends <br />on market conditions. Toxicity is not so defined, monitoring must consider <br />toxicity rather than uranium grade or ore determinations. <br />6. The operator proposes to monitor for "airborne and waterborne uranium." <br />While this may seem advisable, by monitoring cuttings (or drill holes) prior <br />to blasting, and having a blast mitigation plan in place to handle <br />anomalously radioactive blast dust may be the best way to control off site <br />contamination. Again, we need to wait on CDPHE's response to guide in <br />measuring radioactive level and determining what levels require blast <br />intervention. <br />7. The operator proposes to monitor particulate and dissolved uranium at the <br />discharge points of sediment ponds. This may not be necessary, or it may <br />be necessary instead to monitor radioactivity. Again, we should wait on <br />the CDPHE response. <br />8. The operator notes that there are no "ambient air quality standards that <br />would provide a measurable benchmark for uranium dust safety at the <br />