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-2- <br /> II . VIOLATIONS OF STATE AND COUNTY REGULATIONS AT THE <br /> CALAVERAS RIVER PROJECT SITE <br /> Some examples of Stockton Sand and Gravel ' s violations <br /> of State and County Regulations are described below. Documentation <br /> of these violations is contained in the files of several public <br /> agencies, and the authors would be happy to provide further <br /> documentation upon request. <br /> A. Dumping and Burying of Trash <br /> Hundreds of tons of trash and junk including demolition <br /> debris, worn out tires, broken equipment parts, scrap iron, broken <br /> cables and belts, junk cars and trucks, chunks of asphalt and <br /> cement, tree stumps, smashed culvert pipe, skeleton-ized draglines, <br /> bulldozers, and other sorts of heavy equipment, even household <br /> garbage, has been dumped and scattered over much of the Calaveras <br /> River site. This is in clear violation of many State and County <br /> regulations including the Standard Conditions--All Excavations <br /> provision #4-c, a condition of Stockton Sand and Gravel ' s current <br /> operating Permit EP-80-2, and previous Permits. According to <br /> the 1974 Environmental Impact Report page 45 , <br /> "asphalt. . . should not be allowed to become ' fill ' <br /> anywhere since petrochemicals do leach out of asphalt <br /> and contaminate surface and probably ground water <br /> as well . " [emphasis contained in original document] <br /> Hundreds of tons of asphalt and other potentially dangerous <br /> materials have been dumped into the Calaveras River channel by <br /> Stockton Sand and Gravel . <br /> Despite the hazards to the health of downstream water <br /> users and to the fish and wildlife populations, despite letters <br /> from the Planning Department and despite regular and frequent <br /> requests from the property owners, the dumping continues. When <br /> the property owners demanded under threat of eviction that the <br /> junk be removed, Mr. Merian either moved it to another location <br /> on the project site or buried it in the river channel. <br /> B. Levee Width Violation <br /> The 1974 Environmental Impact Report, the most recent <br /> E. I . R. on the Calaveras River Project, states <br /> "Any Permit renewal must consider protection of the <br /> river bed through some practical engineering procedure. " <br /> The responsible agencies developed a plan toward that end that <br /> became condition #7 of EP-80-2 , requiring levees with a 50 foot <br />