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2016-01-26_REVISION - C1981014
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2016-01-26_REVISION - C1981014
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Entry Properties
Last modified
8/24/2016 6:15:11 PM
Creation date
1/27/2016 10:07:56 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981014
IBM Index Class Name
Revision
Doc Date
1/26/2016
Doc Name
Comments on Erosion and Sediment Reports
From
Daryle Mergen
To
DRMS
Type & Sequence
SL3
Email Name
RDZ
JRS
Media Type
D
Archive
No
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amount of sediment. The sediment report describes the reclamation in terms of erosion and <br />vegetation growth as problem free, self -healing areas that produce less erosion than the adjacent <br />non -mined lands while failing to observe obvious erosion, signs of concentrated runoff, and great <br />amounts of sediment yield. <br />The sediment report has failed to demonstrate any true sediment analyses, failed to adequately <br />compare reclaimed and non -mined lands (or pre and post mine conditions), failed to use the best <br />available information, incorrectly and selectively applied vegetation cover in the model <br />demonstrations, failed to provide, discuss, or demonstrate RUSLE model assumptions, or <br />violations of these assumptions, which resulted in a conclusion that cannot be defended based on <br />the data and the explanation provided in the report. Statements like "Specific to the LS factor, it <br />is not appropriate to use different slope values for the non -mined area as compared to the <br />reclaimed area" (from DRMS adequacy review response) are in great error and cannot be <br />supported or defended. In addition, no model uncertainty, validation of the RUSLE model were <br />discussed in the January 13, 2016 sediment report. <br />The two objectives in the January 13, 2016 sediment report state the reason for the report were <br />to: 1. Develop a model to determine if the sediment yield from the existing reclaimed condition <br />is comparable or better than the non -mined condition (or pre and post mine conditions—these are <br />two different situations—which one is it or is it both?), and 2. Demonstrate that the reclaimed <br />area does not contribute excess suspended solids to streamflow as compared to a similar non - <br />mined area. None of the sediment reports satisfy either of these two objectives nor does it <br />provide evidence as stated in the conclusion that the requirements of Rule 3.03.1(3)(b), as <br />included in Mr. Gorham's January 13, 2016 revised sediment report, were adequately satisfied. <br />In addition, there is little mention of the RUSLE model assumptions, each variable in the model <br />listed lacks adequate citations (which RUSLE version is being used?), and explanations for <br />selecting certain values (R -factor, K -factor, and P -factor) were lacking, other than referencing <br />these values were used in the original Permit Application. Just because these values were in the <br />Permit Application does not justify their use then nor today. In addition, the Addendum included <br />two demonstrations that selected specific portions of the permit area with the greatest vegetation <br />cover. Included in the Addendum were additional assumptions without any accompanying <br />support material, such as mention of sediment ponds (which should not be considered long- <br />term), that vegetation will continue to improve (the south -facing slope of the RDA may already <br />be in decline in terms of vegetation cover), observations of no sign of erosion beyond what is <br />occurring in adjacent areas and even extend this unsupported generalization that there is less <br />erosion in many places (now claimed a fact) and does not provide evidence of self -healing. <br />As an example, the Addendum states it is a supporting analysis specific to the length slope (LS) <br />factor and the sediment demonstration for the mine site. The demonstration only examines the <br />RDA and surrounding area, not the mine site as a whole (46% of the reclaimed area). By <br />specifically selecting the RDA, Mr. Gorham chose a best case scenario in which to demonstrate <br />LS. The reclaimed RDA happens to have the greatest recorded vegetation cover compared to <br />any other reclaimed land or to any of the three reference areas. In addition, averaging the gentle <br />slope of the top of the RDA and the steep slopes of the RDA also provides best model results for <br />this area, as does averaging all model output values. <br />
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