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Follow-up Adequacy Review (AM-11) – Elliott Russell <br />October 18, 2016 <br />Page 3 of 5 <br /> <br /> <br />23. Response to Adequacy Item 23 is inadequate. <br /> <br />The response to Adequacy Item 23, states that the footprint of the Squaw Gulch Overburden <br />Storage Area will not be increased. In accordance with Rule 6.4.5(f)(i), please explain how the <br />Squaw Gulch Overburden Storage Area footprint will not be increased by grading the outslopes <br />to a flatter slope of 2.5H:1V. Note, the height of the Squaw Gulch Overburden Storage Area <br />cannot be increased as approved. <br /> <br />25. Response to Adequacy Item 25 is inadequate. <br /> <br />See Follow-up Adequacy Item 14 above. <br /> <br />26. Response to Adequacy Item 26 is inadequate. <br /> <br />The response to Adequacy Item 26, as well as the Surface Mine Backfill Areas section of the <br />Project Description (Volume I), addresses the variance of steepness within the overall 2.5H:1V <br />slope of the Main Cresson backfill. However, these do not address the other backfilled portions <br />of the mining operation. Please specify the proposed steepest section of the overall 2.5H:1V <br />slope of each of the backfilled mine areas or clarify that the statement regarding the Main <br />Cresson backfilled area is the same for all backfilled mine areas. <br /> <br />31. Response to Adequacy Item 31 is inadequate. <br /> <br />Please provide details why culverts, which will require inspection and maintenance, are proposed <br />to remain on reclaimed affected lands. Based on the response to Adequacy Item 33, the Division <br />understands that the Applicant my revise the Reclamation Plan to allow certain road corridors to <br />remain after reclamation (most-likely including any associated culverts). The Division suggests <br />the Applicant remove all culverts on the reclaimed lands and if necessary, construct appropriate <br />drainages to convey stromwater OR explain who, besides the mine, will be responsible for <br />culvert maintenance after closure. <br /> <br />36. Response to Adequacy Item 36 is inadequate. <br /> <br />Please provide the standard reclamation practices as discussed in the applicant response to <br />Adequacy Item 36. <br /> <br />6.4.8 Exhibit H – Wildlife Information <br /> <br />39. Response to Adequacy Item 39 is inadequate. <br /> <br />Pursuant to Rule 3.1.8(1), please clarify that the High Grade Mill is also considered a process <br />facility and is covered under section “2.2 Active Leaching or Process Facilities” in the Wildlife <br />Protection Plan. <br /> <br />