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MMRR Quarry, M-2004-067 Response to Sept. 20, 2005 Adequacy Review October 24, 2005 Page 2 Dollar Metropolitan District (SDMD) and the Colorado Department of Transportation (CDOT) received notice on September 22, 2005. Based on this notice date, these entities will have until no later than November 3, 2005 to submit comments to the Division. Should either SDMS or CDOT submit comments to the Division, the Applicant is prepared to thoroughly address any concerns relevant to review of the Regular 112 permit application. 8. Blasting Plan. Alan Sorenson is reviewing specific Best Management Practices (BMP's) to be implemented prior to, during, and after blasting operations to minimize the generation of dust from blasting operations. Mr. Sorenson's review comments will be forwarded to you as soon as they become available. The Applicant is in receipt of the DMG (Allen Sorenson) memorandum of September 23, 2005. In that memo, the Division states that, in addition to best management practices (BMPs) already assured by the Applicant's commitments in the adequacy response of September 14, 2005, three additional BMPs must be included as commitments under the M-2004-067 permit. In summary, the Division's additional proposed BMPs are: (1) Blasting will follow prescribed burden-to-charge diameter ratios unless justified by the Applicant and approved by the Division. (2} Collar distance (stemming) will be equal to burden for initial blasts, and reduced thereafter as appropriate based on careful observation, with any stemming less than 70 percent of the burden subject to prior review and approval by the Division. (3) Hole depth-to-burden ratio shall always be greater than 1.5. The Applicant hereby commits to the three additional BMPs proposed in the September 23 Allen Sorenson memo. The complete text of the referenced BMPs, as set forth in the September 23 DMG memo, shall serve as the definitive standard for compliance with the M-2004-067 permit. Based on analysis provided by Allen Sorenson in his memo, the Applicant's previous submittals have already established compliance with additional BMPs 1 and 3. Additional BMP 2 will establish the minimum stemming requirements for the proposed quarry operation, with the option to employ measures such as blasting mats or thick dirt cover as an alternative to minimum stemming requirements. In regard to the comments of I.L. Turner, submitted to the DMG by letter dated Sept. 25, 2005, the Applicant notes that the relevant analysis under the Construction Materials Act is the mitigation of blasting effects as a source of dust. Mr. Turner's letter expresses that a wind gauge should be located at the elevation of a presumed dust plume. As established through previous correspondence, dust emissions fall under the jurisdiction of the air quality program of the Colorado Department of Public Health and Environment. Pursuant to the authority of the Construction Materials Act, the