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Mr. Eric Scott <br />September 12, 2012 <br />Page Two of Three <br />currently growing on the shale stockpiles, which have the potential to <br />contaminate the Schell's property if not controlled. <br />2. Exhibit D - Mining Plan (Rule 6.4.4): <br />The Applicant's proposed Reclamation Plan proposes to backfill all mined areas <br />except the area designated for water storage; however, the plan does not provide <br />a mass balance analysis that details the amount of backfill needed to implement <br />the proposed reclamation plan and the source of the backfill material. <br />In addition, the proposed permit amendment includes an "alternate reclamation <br />scenario" which is not acceptable to the Schell's. The alternative reclamation <br />plan removes flood storage from the 100 year floodplain with the potential to <br />force flood waters on to the Schell Property. The applicant has failed to provide a <br />detailed flood study related to loss of flood storage and off -site flood impacts. <br />The reclamation plan fails to address the disposal of on -site excavated <br />construction rubble. <br />3. Rule 3.1.6 Water- General Requirements <br />"Disturbances to the prevailing hydrologic balance of the affected land and of <br />the surrounding area and to the quantity or quality of water in surface and <br />groundwater systems both during and after mining operation and during <br />reclamation shall be minimized..." <br />The applicant's permit amendment fails to adequately address possible adverse <br />impacts to groundwater quality due to leachate produced from groundwater <br />moving through the shale proposed to be used as backfill in Cell 2. <br />The amendment also fails to address safe mining setback distances between Cell <br />1 and Boulder Creek. Historically, the Division as used the Division has used the <br />`Technical Review Guidelines for Sand and Gravel Activities Within or Adjacent <br />to 100 Year Floodplains" prepared by the Urban Drainage & Flood Control <br />District to evaluate adequate mining setbacks from rivers and streams and <br />associated pit and stream side protection methods. The proposed amendment fails <br />to address measures to avoid stream capture of Boulder Creek through the pit <br />during flood events. <br />