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the responsibility to ensure that approved permit applications provide adequate <br />protection from adverse off-site impacts that could result from spills of toxic materials. <br />Some of the materials used in a typical hot mix asphalt batch operation are considered to <br />be toxic. Either provide a containment and disposal plan for any potential spills of toxic <br />materials from the batch plant operation for Division review, or agree to •the following <br />condition ofpermit approval. <br />CONDITION -1 <br />Prior to placing an asphalt batch plant in the permit area, D G Huskin Construction <br />Company will submit a Technical Revision to the permit addressing the batch plant plans <br />and obtain Division approval. The proposed revision will show the location of the plant <br />and include a plan for containment and disposal of any toxic material such as bulk fuel <br />and other petroleum products that could potentially spill from the facility. <br />8. This item has not been answered to the satisfaction of the Division. Your response does <br />not show the locations of the diversions mentioned in your plan or provide plans for their <br />construction. However, other aspects of your mining plan, if further refined, may satisfy <br />the Division's concerns about the potential for erosion and sedimentation. The land to be <br />mined has some significant grades and overland flow will occur during heavy <br />precipitation and snow melt events. The reclamation plan (3.1.5(7) indicates that some <br />pit areas may daylight. This appears to be especially true of Phases 2 and 3. If the <br />surface of these Phases is disturbed and no structures are in place to intercept runoff, <br />sediment could be carved to the drainage (arroyo) down slope of the affected area. In <br />addition there would be potential for erosion to occur between the affected land and the <br />azroyo, causing further sedimentation. The sediments from these two sources could <br />reach the Huerfano River, which is only a short distance away. This same problem of <br />erosion and sedimentation could occur between Phase 1 and the arroyo and the river if <br />the overburden and topsoil stockpiles (berms) aze not in place prior to start of extraction <br />activities. <br />If D G Huskin will commit to placing topsoil and overburden stockpiles along the entire <br />low edge of all the phases as the first steps of mining operations and agree to start <br />extraction of gravel at the lowest elevation of the phase and proceed up slope, the berms <br />and pits created would control erosion and sedimentation. If this approach is adopted as <br />part of the plan, the mining plan maps should be changed to show the berms for Phases 2 <br />and 3. <br />Your amended Mining Plan Map does not show the direction of mining. Please show the <br />direction of mining for each phase. This direction would be up slope, if the <br />recommendations above are added to the mining plan. Tf you do not incorporate these <br />