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May /7, /999 <br />information the Colorado Division of Mining and Geology would be erroneous in <br />the issuance of the 112 Mining Permit. <br />• Reclamation Plan -The reclamation plan set forth by Arkins is wholly inadequate. <br />There is no discussion of how plants are expected to become established (since it <br />appears that top soil would not be stockpiled) on baze 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 unsuccessful. <br />Rock Dynamics - No where within the permit application is there any discussion <br />on the effects that an operation this size may have on the underlying formations <br />and associated aquifers. Citizens of Lyons have the right-to-know whether this <br />type of mining operation would decrease either the quality or quantity of well <br />waters which so many depend on. <br />Bonding -There is no discussion on what agencies would require bonding. The <br />Town of Lyons and Boulder County must not allow an operation such as this to <br />go forth without ensuring that a monetary vehicle is in place to pay for natural <br />resources and city/county property damaged. The citizens of Lyons and Boulder <br />County must not be placed in a position where they must carry the brunt of the <br />5nancial burdens caused by a private entity. <br />Jurisdictional Waters of the U.S. -The permit application does not address <br />whether an increase in the size of the mining operation would impact <br />Jurisdictional Waters of the U.S. as determined by the U.S. Arny Corp of <br />Engineers. The financial repercussions to the Corporation of this issue potentially <br />could be enormous. <br />Control of Run-off Waters -The Lyons area is subject to sudden and intense <br />storm events often producing enormous amounts of moisture in localized azeas. <br />There is no discussion on how storm waters would be managed so that homes <br />and businesses would not be inundated with floods or mud slides. The potential <br />exists for a large azea to exist adjacent to homes that does not have the ability to <br />absorb moisture since soils have been removed. Without soil and with a large <br />amount of exposed stone it is likely that flooding would result more regularly and <br />intensely than it currently does when storm events occur. This information must <br />be included as a Stormwater Pollution Prevention Plan (40 CFR Part 122) and <br />available for public review. <br />• Hazardous Materials -The citizens of Lyons have the right-to-know if substances <br />either identified as hazardous material by their nature or volume, as determined <br />by RCRA (40 CFR Part 265), would be used at the site. if hazardous materials <br />would be used in the mining operations a Spill Contingency and Response Plan <br />2 <br />