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2019-05-09_PERMIT FILE - M2018051 (3)
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2019-05-09_PERMIT FILE - M2018051 (3)
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Last modified
12/27/2024 9:21:50 AM
Creation date
5/10/2019 9:45:12 AM
Metadata
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Template:
DRMS Permit Index
Permit No
M2018051
IBM Index Class Name
PERMIT FILE
Doc Date
5/9/2019
Doc Name
Objection
From
Vranesh & Raisch, LLP
To
DRMS
Email Name
PSH
Media Type
D
Archive
No
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Peter Hays <br /> May 9, 2019 <br /> Page 7 <br /> mining process water will be utilized, managed, and disposed of as part of mining <br /> operations and proposed reclamation. <br /> In addition, more information is needed on the following aspects of the proposed <br /> operations: <br /> • How deep will each "block" of mining be: during mining, post-mining, and post- <br /> reclamation. What will be deposited in each "block" during mining, post-mining, <br /> and post-reclamation? <br /> • What is the character of the "plant byproduct" that will be placed in the "blocks" <br /> after mining, and which will be utilized for "sloping the land" during <br /> reclamation? Where will this "plant byproduct" material be stored and managed <br /> prior to use for reclamation? <br /> • What are the final reclamation grades, and what does "grading to best match <br /> existing conditions" mean when the majority of the material will be removed <br /> from each "block"? <br /> • What is "adequate compaction . . . to prevent the leaching of toxic or acid- <br /> forming minerals"? What toxic and acid-forming materials could be generated? <br /> How will this compaction impact the hydraulic qualities of the aquifer? <br /> • Will the processing area be lined? <br /> • What chemicals will be used for processing? <br /> • What wastes will be generated during processing, what will the characteristics of <br /> that waste be (including leachability into the underlying soil and ground water), <br /> and where will these wastes go? <br /> • How much water will be needed to process the mined material, how much will <br /> be consumed, and how much will be wasted and where will the waste water go? <br /> • How will secondary products be defined and used, how will they be processed, <br /> what wastes will be generated, and how will those wastes be disposed? <br /> • What is the best management practice for storm water control, ground water <br /> protection, and fugitive dust mitigation, and will such practices actually protect <br /> existing resources, property rights, and operations? <br /> • What Spill Prevention Control & Countermeasure (SPCC) and Storm Water <br /> Pollution Prevention Plan (SWPPP) steps will be implemented? <br /> • What will the criteria be for allowing BMS to increase mining and/or processing <br /> to accommodate "market conditions for industrial sand"? <br />
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