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4. No Affidavit Regarding the Importation of Material <br />There appears to be no affidavit on file from the operator prior to the importation of inert material"" as <br />required by the May 12, 2004 Adequacy Response, 6.4.4 Exhibit D Mining Plan" "'. <br />Further, wood is not an inert material and should importation, disposal, stockpiling and recycling of non <br />inert material occur at this site it is likely that the site would come under the jurisdiction of the <br />Hazardous and Solid Waste Division of CDPHE not the Division of Minerals and Geology "' °. The <br />importation of non inert material combined with the ability of an operator to stockpile it for the life of <br />the pit (20 -40 years) calls into question whether the pit should be regulated as a disposal site. <br />Photos from inspections show the stockpiling of debris in the old pit area. And satellite photos <br />10/22/2013 show a collection of tires, junk and what appears to be a 55 gallon drum on the south <br />border of the disturbed area. See Exhibit D. The storage of these items is inconsistent with the <br />permitted usage of the property and proper disposal of the items should be accounted for with disposal <br />records. <br />The approved permit does not provide that salt may be imported and processed into a salt sand mix. <br />Processing of materials in the operation is described as "Material will be crushed and screened using a <br />portable plant with screens and crushers." In addition, the application states that the anticipated end <br />use of the primary commodities to be mined is "construction materials ". Salt has been imported into <br />the pit, mixed with sand and sold to public agencies for application to roads. <br />In addition, careful consideration should be given as to whether a 112 permit allows the importation and <br />disposal of snow from parking lots, roads, driveways and other surfaces as debris laden snow is not an <br />inert material and seems beyond the Division's jurisdiction. <br />