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f <br /> Frascona, Joiner, Goodman and Greenstein, P.C. <br /> September 14, 2017 <br /> Page 4 of 5 <br /> V. Summit's application fails to demonstrate that off-site areas will not be <br /> adversely affected by blasting and fails to acknowledge historic EPA blasting <br /> violations. <br /> Rules 6.3.3(p), 6.4.4(i), and 6.5(4) require Summit to demonstrate that off-site areas will <br /> not be adversely affected by blasting during mining or reclamation operations. Exhibit D of <br /> Summit's application describes how exposed sandstone will be "drilled and shot as described in <br /> the approved Blasting Plan." but the application does not include the Blasting Plan or <br /> demonstrate that off-site areas will not be adversely affected by the same. Even if the original <br /> Mine permit includes an approved Blasting Plan, such a plan surely did not contemplate a 1,000 <br /> acre-plus expansion. Summit must revisit its Blasting Plan and demonstrate both adequate <br /> methods of safety and effectiveness prior to DRMS approving its application. <br /> Through conversation with Mr. Hanratty, this firm is aware that the Mine is subject to <br /> previous EPA blasting violations (the "EPA Violations"). Mr. Hanratty recalls that the EPA <br /> Violations placed certain restrictions on the type and frequency of blasting that can occur on the <br /> Mine. A search of the EPA's website confirms the existence of the EPA Violations, although the <br /> site does not provide any further detail. The screenshot attached hereto as Exhibit 2 highlights <br /> reference to the historic violations. The DRMS must require Summit to address the topic of the <br /> EPA Violations at the public hearing. If the EPA Violations are still in effect, Summit must <br /> provide a detailed and comprehensive explanation of how it will conduct its operation in <br /> accordance with the EPA Violations. The DRMS should strongly consider the history of EPA <br /> violations on the Mine when deciding if Summit can safely operate an expansion nearly 25 times <br /> larger than the originally permitted area. <br />