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r <br />f May /7, 1999 <br />information the Colorado Division of Mining and Geology would be erroneous in <br />the issuance of the 112 Muting Permit. <br />• Reclamation Plan -The reclamation plan set forth by Arkins is wholly inadequate. <br />~~ ~~ / ~~ There is no iiscussion of how plants are expected to become established (since it <br />~~~j 3 l., appears that top soil would not be stockpiled) on bare stones. No mention is <br />~, made of what techniques would be employed to achieve successful reclamation or <br />what actions would be taken if reclamation activities proved to be unsuccessfiil. <br />~ ~ • Rock Dynanucs - No where within the permit application is there any disaspon <br />N Q~ ~ ~ a ~ ~ on the effects that an operation this size may have on the underlying formations <br />~w~ q ~- ~ S p h~ and associab~ aquifers. Citizens of Lyons have the right-to-know whether this <br />type of minutig operation would decrease either the quality or quantity of well <br />i~ d r ~ v, I ~ a.N c~waters which so many depend on. <br />~.,~Q -~ ~ u~ V'"~ lr ~~ Bonding -There is no discussion on what agencies would requve bonding. The <br />Q ~Y s ~ b k ~ ° S ~ ~~own of Lyons and Boulder County must not allow an operation such as this to <br />}, S ~ b (, ~ go forth without ensuring that a monetary vehicle is in place to pay for natural <br />..~ ~ a p S resources and city/county property damaged. The citizens of Lyons and Boulder <br />~ ~ ~~ ~ r~ounty must not be placed in a position where they must carry the brunt of the <br />s e~ ~ ~ ~Q~~~k+'t financial burdens caused by a private entity. <br />I ~~ Y • Jurisdictional) Waters of the U 5. -The permtt application does not address <br />1 ~ ~ ~J~ whether an uicrease in the size of the mining operatioa would impact <br />~~' Jurisdictional) Waters of the U.S. as determined by the U.S. Arm Co of <br />~ ~ n~ eers. 7 coal repercussions to the Corpora ono this issue potentially <br />~ ~f cou enormous. <br />j-~~Q ~5 • Control of Run-off Waters -The Lyons area is subject to sudden and intense <br />J' storm events often producing enormous amounts of moisture in localized areas. <br />~. 1 ~ There is no discussion on how storm waters would be managed so that homes <br />a ~ /I 2 ~ and businessc;s would not be inundated with floods or mud slides. The potential <br />fiF.~ ~ ~ (~ 6 t exists for a large area to e~dst adjacent to homes that does not have the ability to <br />M ~Y- absorb moisture since soils have been removed. Without soil and with a lazge <br />amount of exposed stone it is likely that flooding would resuh more regularly and <br />~l h ~`j/ intensely than it currently does when storm events occur. This information must <br />l 5 a i h be included as a Stormwater Pollution Prevention Plan (4o CFR Part 122) and <br />a, _ S S e d .f. -~lt'~ available for public review. <br />~~1 P ~ y ~ Hazardous Mfaterials -The citizens of Lyons have the right-to-know if substances <br />OST~~ ~' ~ ~/ either identified as hazardous material by their nature or volume, as determined <br />_ ~/ by RCRA (4f1 CFR Part 265), would be used at the site. If hazardous materials <br />`I b', /~-/ would be used in the mining operations a Spill Contingency and Response Plan , <br />~L <br />2 <br /> <br />