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• <br />and topsoil piles will be west of Highway 9, fugitive dust will be blown into traffic using <br />that highway. Further information is necessary concerning wind velocities, expected <br />windblown dust, and specific 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 34-32-116 (7) (I). Again, because of <br />relatively high prevailing westerly winds, it can be anticipated that the conveyor operation <br />and spoil piles will cause erosion and attendant air and water pollution. <br />6. Applicant has stated in Exhibit 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 as to the soil descriptions on the affected <br />land. Both soil types 8B and 8D include the warning that any leachfield 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 table height, or how it is possible to meet profile hole requirements, <br />such that ground water will not be subject to pollution. <br />7. Applicant will necessarily encroach wetlands and intends to 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 apphcant to be in <br />violation of Section 34-32-114 (4) (C) (I). <br />8. In Exhibit E, applicant states that "Inert fill generated off the permit area <br />will also be brought into the site as backfill." Applicant previously 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 />opposed by the undersigned for the same reasons as stated in the letter from Kenrick <br />Pocius, Summit County Engineer, dated August 11, 1994 (copy attached for your <br />convenience). <br />9. The financial warranty proposed in Exhibit L appears inadequate. <br />Applicant does not indicate whether the costs used to calculate its proposed financial <br />warcanty aze curcent 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 aze <br />curcent costs, the financial warcanty 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 of 25 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 collected ground <br />water data sufficient to chazacterize the site's ambient ground water quality and submit <br />tj: c:/bolxvr <br />