Laserfiche WebLink
Letter: Response to adequacy review, Permit Application M-2008-010 4/25/2008 page 3 <br />of its components), hydraulic fluid, lubricants, anti-freeze, propane, <br />battery acid, and many other common compounds. <br />We can find no requirement to provide a list of those materials in the <br />Mineral Rules and Regulations, or any indication in your request of any <br />de minimus exemptions, and we have not found any indication that the <br />Division has regulated such or required an amendment or technical <br />revision to a permit to allow such common compounds to be stored <br />and used on-site. <br />To the best of our recollection, we cannot recall being required to <br />provide such information in past applications under the current or <br />previous versions of the rules. In addition, many of these chemicals <br />are regulated by other agencies, including CDPHE, CDOLE, the <br />CEPC, and various federal agencies. We can generate such a list if the <br />Division requires it. However, we believe that the Operator's <br />commitment to comply with all applicable regulations of other agencies <br />to prevent surface and ground water pollution (in Exhibit M, and in <br />Exhibit G, item 8) are clear statements which meet the requirements of <br />the Mineral Rules and Regulations and the policy letter. <br />Please note that we do not have a "Section 3.1.6(1) in the Mining Plan, <br />Exhibit D. Could you please elaborate on this reference? <br />It is the Operator's intent to have various substances which may be <br />considered, under various regulations, to be hazardous materials or <br />substances on site, to be stored and used as appropriate, and the <br />Operator understands that any spills of any materials must be dealt <br />with as required by applicable regulations and by the Mineral Rules <br />and Regulations, including reporting to the Division. <br />Furthermore, it is the Operator's intent to provide secondary <br />containments and/or other safeguards against leaks and spills of <br />hazardous materials, including fuels, which are adequate to contain the <br />potential spill or leak of the contents of a tank and prevent <br />contamination of surface or ground water, in accordance with <br />applicable local, state, and federal laws and regulation, and the <br />requirements of the landowner. When secondary containments are <br />used, they will be designed in accordance with regulatory requirements <br />and sound engineering design, of a large enough volume to contain <br />the leak or spill. Since the exact equipment to be used for mining, <br />production of asphalt, production of ready-mixed concrete, and other <br />related activities is not known at this time, we cannot specifically <br />identify quantities and sizes of tanks. However, standard design <br />parameters for containments and generally applicable to all containers <br />of 55 gallons or larger (except tanks integral to equipment) are a <br />