2016-01-21_PERMIT FILE - M1982121

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Objection to DRMS' Surety Increase Request January 14, 2016 Page 2 of 5 It is noteworthy that the first two documents that comprise the Reclamation Plan for the Ca1X Quarry are lengthy, and detailed, and are entirely qualitative — not quantitative — in the recitations of the several subparts of the "Reclamation Plan". In the first identified document, the five principal tenets of the MLRD-approved Reclamation Plan for the Mid -Continent Quarry were summarized as follows: "Postmining backfilling of crusher, screen and product stockpile areas ... will insure [sic] adequate compaction for stability." "All highwalls will be scaled and stabilized." "All backfilling and grading will be completed as soon as feasible after ... mining .. . "Topsoil will be removed, segregated, stockpiled and protects [sic] from ... erosion." "When topsoil is replaced it will be done in as even a manner as possible." It is also noteworthy that the first three tasks under the Reclamation Plan are ongoing activities — and, indeed, if Ca1X did not attend to these obligations continuously, it is predictable that either or both of MSHA or DRMS would order us to cease and desist. Nowhere in the 1983 document does it specify what quantity of topsoil was removed, as overburden, from any of the Mid -Continent Quarry production benches. In the 1989 Amendment to the Reclamation Plan, there were several, more -detailed observations about the five principal tenets of reclamation at the Mid -Continent Quarry: "Scaling of the highwalls will be accomplished to remove any materials that might fall and endanger people or animals that might be on one of the [downslope] benches. This should not be an extensive operation since it is accomplished continuously during mining to insure [sic] the safety of the miners." "The benches and highwalls are excavated in solid rock, so the only backfilling and grading that can be accomplished will consist of pushing any loose materials on the benches up against the highwall." [This, too, was described as a continuous operation.] "With minimal topsoil available, the most practical revegetation program within the actual quarry area will be to establish individual ecosystems on the benches that will support native grasses and shrubs." [Emphasis supplied.] As was the case with the 1983 instrument, the MLRD-approved 1989 Amendment did not specify what quantity of topsoil might be available for the establishment of individual ecosystems on the various production benches within the Mid -Continent Quarry.