2019-06-17_REVISION - M2001038 ‎(6)‎

• Permit No: M2001038
• IBM Index Class Name: Revision
• Doc Date: 6/17/2019
• Doc Name: Adequacy Review Response
• From: Environment, Inc.
• To: DRMS
• Type & Sequence: AM1
• Email Name: JLE
• Media Type: D
• Archive: No

Albert Frei and Sons, Inc. Page 3
AFS.-Bennett Pit - M-2001-038 June 17, 2019
with finer material, re-soiled and seeded. How fast this happens depends on how much material
is available and this mine is not operated as an inert fill facility.
8. Please approximate the volume of inert fill to be used at the site given the revised mining and
reclamation plan?
At this time Albert Frei and Sons, Inc. estimates that 600,000 yards t of inert material would
be accepted at the mine.
9. The current inert fill plan indicates the permanent slopes will be no steeper than a 3H:1 V ratio.
With AMO1, the applicant is proposing final reclamation slopes of 2H:1 V ratio. Please provide a
general engineering plan stating how the material will be placed and stabilized in a manner to
avoid unacceptable settling and voids.
Recent inter company discussions have lead to a decision to retain the 3h to lv sloping plan
around the area to be mined and remove references to 2h to lv from the permit amendment. I
have attached a revised Exhibit C-1-Mining Plan and Map Exhibit F - Reclamation Plan Map
showing the 3h to lv slopes and corrected Pages 5, 8, 9, 53, & 61 to remove any reference to 2:1 .
10. Page 10 and 11 of the reclamation plan state that a U.S. Army Corp of Engineers Permit will be
obtained if wetlands or waters of the U.S. will be affected during the mining operation. Exhibit
G and Exhibit M state that there are not wetlands or waters of the U.S. at the site. While on the
pre-operation inspection, Ben Frei indicated a wetlands evaluation may be conducted at the site.
If wetlands are identified within the permit area, please update the Exhibit C map to depict their
location. If wetlands are identified, within the proposed mine area, please develop a protection
plan for these wetlands until the required U.S. Army Corp Permits are in place if necessary.
A copy of the finalized environmental assessment report that was done for the mine area by ERO
Resources is attached for the file. It reports that there are no wetlands or Waters of the U.S.
in the permit area. Therefore, no U.S. Army Corps of Engineers permit will be required. The
statement on Pages 10 and 11 was placed there to explain that a permit would be obtained if
required. A copy of the ERO letter to eh U.S. Fish and Wildlife Service requesting concurrence
on the lack of endangered species at the mine is attached. Once the USFWS confirmation letter
is received a copy will be delivered to the Division for the file.
Rule 6.4.7, Exhibit G—Water Information
11. Page 14 of the Exhibit G states that off-site runoff is/or will be diverted around the disturbed
area. Please revise the Exhibit C-1 Map to depict the diversion structures used to accomplish
this. Please describe and provide a cross section of the diversion structures.
These diversion structures will be simple dirt ditches placed along the up gradient side of the
mine's perimeter with the material from the ditch being placed along the pit side of the ditch.
Usually a motor grader is used to create the ditch/berm. Their intent is to keep off site surface