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09i16i96 16:21 DES a 303 832 8106 <br />--_ N0.059 D02 <br />• <br />and topsoil piles will be west of Highway 9, fugitive dust will be blown into ttadc using <br />that highway. Further information is necessary concerning wind velocities, expected <br />windblown dust, and speafic methods to be utilized to attempt to control dust and to <br />maintain air quality. Until this issue is adequately addressed, the permit application should <br />be denied. <br />5. The permit application should be denied until applicant provides <br />information as to how it will comply with Section 3432-1 l6 (?) (n. Again, because of <br />relatively high prevailing westerly winds, it can be anticipated that the conveyor operation <br />end spoil piles will cause erosion and attendant air and water pollution. <br />6. Apphcant has stated in Ezhibit G that surface or groundwater systems will <br />not be affected (p. G 1). However, applicant intends to install a septic system for its <br />office on the mine site. Exhibit I includes notes es to the soil descriptions on the affetted <br />land. Both soil types 8B and 8D include the warning that any leachSeld should be <br />carefully designed to eliminate the hazard of groundwater pollution. Applicant does not <br />indicate how the field will be built, whether percolation tests have been done, the integrity <br />of the field, the water tab]e height, or how it is poasrble to meet pro5le hole requirements, <br />such that ground water will not be subject to pollution <br />7. Applicant will necessarily encroach wedands and intends m replace same <br />on approximately a 1:1 basis. Such a replacement ratio appears substantially less than the <br />cognizant governmental body would otherwise require thus causing applicant to be in <br />violation of Section 34-32-114 (4) (C) (1). <br />8, In Exhibit E, applicant states thaz "Inert fill generated off the permit area <br />will also be brought into the site as backfill." Applicant previowly sought a revision to its <br />Love Pit Permit M•82-164 to allow such disposal and, after opposition by Summit <br />County, withdrew such request. The disposal request contained in Exhibit E (p. E-2) is <br />opposcd by the undersigned for the same reasons as stated in the letter from Keorick <br />Pocius, Summit Couttry Engineer, dated August 11, 1994 (copy attached for yotu <br />wnvenience). <br />9. The financial warranty proposed in Exhibit L appears inadequate. <br />Applicant does not indicate whether the costs used to calculate its proposed finantdal <br />warranty are current costs or anticipated costs at reclamation, which could be 50 years <br />hence, the end point of the permit applicant has requested. If the estimated costs are <br />current costs, the financial warranty needs to be adjusted upwards. Further, the <br />reasonableness of the estimated costs must be verified, <br />10. Exhibit G indicates that a detention time of25 to 40 hours will be <br />"targeted" for release of impounded water (see p. G 1). Is such a retention time adequate <br />to assure no degradation of ground water quality? Mineral Rules and Regulations, Rule 1, <br />sub section 1.1 (5) requires that an `Applicant shall use available or wllected ground <br />water data sufficient to characterise tlto site's ambient ground water quality and submit <br />tj: cJbobcvr <br />