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<br />November 6, 1991 <br />Page 7 <br /> <br />Particulate Control Plan as approved by the Colorado Department of <br />Health on April 18, 1991. <br />There is no legitimate factual basis to support the objector's <br />proposed abatement measures. The approved Fugitive Particulate <br />Control Plan requires SMC to ensure proper loading of the haul <br />trucks and the MLRD's investigation indicated compliance with this <br />requirement. SMC maintains an ongoing employee education and <br />monitoring program in an effort to ensure continued compliance in <br />this regard. As a redundant measure, the Health Department imposed <br />an additional clean-up requirement in the event of spillage which, <br />as evidenced in the videos presented at the October 16 hearing, is <br />scrupulously adhered to in the course of normal operations. The <br />total haul distance is exceedingly short (approximately 3,000 feet) <br />and the loaded haul trucks cannot exceed 20 mph due to the short <br />distance and the grades involved. Given the low speeds and <br />appropriate loading, fugitive emissions from the loaded haul trucks <br />is simply not a problem and the Board has no evidence in the record <br />which suggests that such additional measures are necessary or <br />appropriate and none was required by the Department of Health in <br />the approved Fugitive Particulate Control Plan. <br />2. The Board should render a final decision affirming the MLRD's <br />determination that SMC's application for TR-08 complies fully <br />with the applicable reuulations and is therefore approved. <br />