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AUGUST 8, 2011 <br />MAY DAY MINE CLASS II - SUBMITTAL 2 REVIEW <br />PAGE 4 OF 15 <br />The most recent submittal indicates the applicant will take emergency vehicles off the access road <br />by providing an Emergency Management and Response Plan that includes an alternative mine <br />rescue team dedicated to responding to emergencies at the mine site and getting injured workers to <br />the county road where the local fire district, Fort Lewis Mesa, could begin providing services. This <br />plan needs to be provided and accepted by the County Office of Emergency Management, County <br />Planning Department, and Fort Lewis Mesa Fire District. <br />Other issues that remain to be addressed include handling of sanitary sewage at the mine site and <br />delivery of construction material, fuel, and chemical deliveries to the mine site. <br />B. Variance to County Road Standards <br />La Plata County Land Use Code (LPLUC) has only one set of road standards that apply to all <br />projects. For any road grades of greater than 8 -10% or less than 18 -24 feet in width (depending on <br />the project), a variance is needed. Because it is technically infeasible for the proposed access roads <br />to meet those standards, the proposed project will meet one of the primary criteria for a variance. <br />While solely the Board of Adjustment makes the decision regarding a variance, engineering staff <br />would support a variance based on the items outlined in planning engineering's letter dated May <br />20, 2011. <br />As the road is central to the Class II permit that is the subject of this review, key components of <br />the May 20, 2011 review are incorporated into this memorandum. <br />C. Stormwater, Drainage, and Mine - Associated Runoff <br />Disturbance of the mine site and access road areas will increase stormwater runoff, potentially <br />impacting the downstream La Plata River and adjoining wetlands. Because disturbance at the mine <br />site is integrally related to mine operations, the County anticipates the State (DRMS and WQCD) <br />will address critical runoff issues at the mine sites. It is understood the EPA is also working with <br />the applicant to resolve violations within US Waters near the mine site. The County is looking to <br />the aforementioned entities to address the following issues at and near the mine sites: <br />1. Assuring independence /separation of process water and augmentation water <br />2. Assured quality of discharged augmentation water <br />3. Handling, treatment, and discharge /fate of process water <br />4. Handling and management of tailings waste <br />5. Spill control prevention for oil, fuel, and chemicals at the mine site <br />6. Avoidance of land disturbance that could increase risk of rockfall, avalanche, debris flow, <br />and landslides <br />7. Overall erosion prevention and correct use of sediment runoff controls <br />County review of stormwater and drainage has focused on the mine access road, encompassing the <br />new unpermitted portion west of the La Plata River and the historic portion east of the La Plata <br />River. Primary concerns are sediment runoff and the potential for oil, fuel, and chemical spills <br />during transport. <br />Concerns with sediment runoff are primarily related to the new, unpermitted portion of the access <br />road. Specifically: <br />PLANNING DEPARTMENT • 970.382.6263. • 1060 E. 2ND AVE. • DURANGO, COLORADO • 81301 <br />