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Kauffman/Wagner~3, Page 3 • proposal, I believe that the applicant should address this issue. The two issues that are important to address in this context are anticipated PM,o particulate matter impacts, and the percentage of silica in the potential emissions. The ideal time to deal with this technical issue would be prior to the public hearing. An alternative would be to proceed to the hearing stage in order to obtain a basic land use decision, and provide analysis prior to final approval. The final air quality related issue concerns the lime wastes. As noted in the project description, the western half of the site has been used as lime drying ponds by the sugar industry. Limestone was used in the sugar manufacturing process. The limestone was heated to create carbon dioxide gas and calcined lime (calcium oxide). Both of these products were used in the manufacturing process to purify the sugar. The waste from this process (precipitated calcium carbonate containing water and impurities from the process) was transferred to the lime ponds for drying. This material is very fine and can become windborn if not handled properly. Fortunately the lime dust can be controlled with wetting for those times it needs to be exposed. I contacted the Waste Management Division at the Colorado Department of Public Health and Environment. I spoke with Pete Laux (303) 692-3455, who indicated that their office would need to approve a Materials Management Plan for work involving the lime pit wastes. Our office can assist in coordinating this issue. Water Quality. Potential water quality impacts associated with sand and gravel operations include sediments in stormwater runoff, and chemicals associated with machinery or processing operations. In Colorado, sand and gravel mining operations are required to apply for either a Process and stormwater Discharge Permit or, if no process water will be discharged, a stormwater Discharge Permit from the Water Quality Control Division of the Colorado Department of Public Health and Environment. In this particular case process water, in the form of mine dewatering and product wash waters, are i..volved. A requirement for obtaining e Sher permit is the preparation of a stormwater management plan. These plans must include identification of potential sources of pollution (including sediment, chemicals used in the mining operation, fuels, etc.) and selection of best management practices that will be implemented to control the potential pollutants. Under the terms of a stdte permit, the applicant is required to perform routine inspections and to prepare an annual report to address compliance with the stormwater management plan. In order to more fully evaluate this issue for the public hearing, I recommend that a copy of the appropriate stormwater discharge application and stormwater management plan be submitted with the application for Planning Commission review. I would also encourage the applicant to consider a concurrent permit application submittal to the State Water Quality Control Division.