2018-12-19_REVISION - M2006081

• Permit No: M2006081
• IBM Index Class Name: REVISION
• Doc Date: 12/19/2018
• Doc Name: Adequacy Review Response
• From: Gagliano Engineering
• To: DRMS
• Email Name: ERR
• Media Type: D
• Archive: No

at least 6" of topsoil is replaced. Please address this discrepancy and either
commit to implementing the NRCS recommendations or submit an appropriate
technical justification for the deviation in the plan. 6.4.5 (2) has been revised to
specify 6" of topsoil.
9. Within Exhibit F, under the 3.1.12 Signs & Markers subsection, the Applicant
states this is a 112 operation, therefore the permit boundary and the affected
boundary are not the same. However, the application materials appear to not show
a difference in affected and permitted areas. Please clarify this application's
permit boundary and affected lands boundary are one in the same and revise the
subsection 3.1.12 within Exhibit F. The operator/applicant is proposing a
floating bond to cover a portion of the site to allow mining and reclamation
to be ongoing. Permit boundaries will be monumented as well as phase
boundaries. The entire permit boundary is potentially affected.
10. Within Exhibit F, under subsection 6.5.4(e)(i), the Applicant describes the
concurrent reclamation process whereby the Operator advances the mining
operation into Phase 2 while starting reclamation on the mined-out Phase 1. In
this process, the Division should hold appropriate financial warranty for both
Phase 1 and Phase 2, however, the Exhibit L materials only include the Phase 1
reclamation costs. Please clarify and update Exhibit L to also include Phase 2
reclamation costs. Exhibit L updated to include Phases 1 & 2.
EXHIBIT L— Reclamation Costs (Rule 6.4.12):
i I. The Division will calculate a cost estimate after applicable adequacy items are
addressed. The Applicant will be provided copy of the cost estimate for review
before the decision date. Acknowledged
EXHIBIT R - Proof of Filing with County Clerk and Recorder (Rule 6.4.18):
12. Any changes or additions to the application on file in our office must also be
reflected in the public review copy. Please submit proof that the public review
copy has been updated with a copy of the response to this adequacy letter.
PENDING
EXHIBIT S - Permanent Man-Made Structures (Rule 6.4.19):
13. The Applicant lists the only structures on the affected lands or within 200 feet of
the affected lands are the landowner's ranch fences. The Applicant is the
landowner, therefore, no structure agreements are necessary.However, based on
application materials, site inspections, and review of a Google Earth aerial, the
Division has identified there are at least three additional structures. Please review
the site and identify all permanent man-made structures within 200 feet of the
affected lands. The Applicant will need to comply with Rule 6.4.19 for US
page 3 of 4 file(JA2017\=BigGORMS-permit\Comments\BigG-adequacy-response-2018.doc)