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the creek. In addition, the Mining Plan indicates that tailings will be returned to the mine <br />shaft in slurry form, so it is unclear what tailings will need to be stored near the mill <br />building. <br />Stormwater Issues <br />The ILC indicates that storm water will be routed off this site through a culvert to what <br />appears to be land controlled by CDOT — and then to the creek. Our Site Development <br />Department believes there is space on land under Empress's control to detain stormwater. <br />Given the nature of the proposed activity, we would recommend BMPs to handle <br />stormwater on site be required. <br />In addition, the storm water plan would not meet requirements of our Site Development <br />department. We would like to see rate and direction of flow. We would also request <br />disclosure of the type of storm event for which the system is designed. <br />Handling of Explosives <br />Exhibit C — Mining Plan, Section B indicates that this will be an underground facility for <br />which explosives will be utilized, but Section II A does not list explosives, nor does the <br />plan disclose how they will be handled and secured. <br />Reclamation Plan <br />There is lack of clarity about the ponds that are /will be constructed on the property. If the <br />ponds will hold mine water, we request that they not be allowed to remain. <br />Specific Roads to be Used <br />Exhibit A indicates that approximately 100 mines or mining claims are involved in this <br />project. The maps do not indicate where these claims are located in relationship to the <br />Stanley Mine buildings or the tunnels and shafts diagrammed in Exhibit B. The applicant <br />has not demonstrated how this will be an entirely underground operation. Section G of <br />the Mining Plan indicates that the applicant "believe(s) that all roads ... are already in <br />place." A map of the roads that will be used should be included so the County will be <br />able to determine if the roads are indeed in place, and if they are public roads subject to <br />County maintenance. <br />The fact that so many mining claims may be involved in this operation also raises a <br />concern regarding the size of the affected area. Is the affected area actually less than 10 <br />t <br />acres? <br />Other Activities? <br />The Site Plan includes a building designated as a smelter. We would be interested in <br />knowing if this is an activity that will also take place on this property, and if so, will <br />CDPHE be evaluating air quality impacts. <br />Local Permitting Issues <br />It should be noted that if buildings are to be added to the site, demolished or remodeled, <br />Clear Creek County Building Permits will be required. <br />