Laserfiche WebLink
Letter, 07 August 2019 M2013-066 Loblolly Pit Page 2 <br /> It is very difficult and costly to dewater sufficiently to drop the water level by 15 feet, which <br /> would require a special permit, only to have the water quickly refill the ponds. Water can be <br /> lowered a few feet to allow use of backhoes/trackhoes, but only for a limited time and depth. <br /> Mining is proposed to begin using a dragline rather than `hoes or loaders, to excavate materials. <br /> 3. The low"highwalls" presently are measured at 583 feet for Pond F2 and 335 feet for Pond <br /> F3, a total of 918 linear feet. There is no "highwall"for Pond F1. The average height is 6 feet <br /> and the average slope is no steeper than 1:1. We do not believe there will be more than 1,000 <br /> linear feet of this 1:1 working face at any one time, and the estimate is based on this. The areas <br /> to be sloped for this are identified as Area H in map and table, and included in grading, <br /> contouring, scarification, and seeding, in addition to the earthwork necessary for "highwall <br /> reduction." <br /> All areas to be graded and have soil placed will be scarified (ripped). As stated in Exhibit I <br /> Paragraph 5, "Soil will not be replaced on roads, industrial areas and pond areas except as <br /> landscaping."Therefore these areas will not be ripped. In the North Parcel, an estimated 12.7 <br /> acres will be ripped (see tables). <br /> As stated in Exhibit I Paragraph 5, "In areas to be reclaimed for cropland, pasture, or grazing <br /> land, soil will replaced to a depth not less than 2/3 of original depth for reclamation: minimum 18 <br /> inches. In dryland areas, minimum will be 12 inches. Depth will vary by area, but soil will be <br /> placed on backfill/subgrade that is suitable for rooting zone, and not directly on competent <br /> bedrock."This information is now added to the tables (in notes). <br /> 4. The affected area is 34.9 acres (12.7 in the north parcel and 22.2 in the south parcel). This <br /> does not include permanent and preexisting roads, wellpads, and industrial areas (non-mining). <br /> This does include 2.8 acres in the north parcel expected to be disturbed in the 2019-2024 <br /> period. In order to provide for unexpected changes in conditions, and delays in release of the <br /> south parcel, the operator commits to not more than 50 acres to be affected at any one time, <br /> plus up to 10 acres which is graded, topsoiled, and seeded, but require additional revegetation <br /> efforts. <br /> 5. The total areas to be vegetated are now shown in the notes of the tables, by seed mix. (The <br /> variations in area are based on rounding to the nearest tenth.) Seed mix is based on potential <br /> subirrigation, and does not imply a commitment to use irrigation systems. The error in the last <br /> submittal was caused by mistakenly including the industrial sites in the area to be soiled and <br /> seeded. <br /> 6. The concurrent and post-mining use of portions of the South Parcel were discussed in the <br /> original reclamation plan and other exhibits to the original application. We do not believe this to <br /> be a deviation from the current reclamation plan. However, if that is a concern, please consider <br /> this as a request for any deviations, as part of this Technical Revision now being reviewed. <br /> We do not believe that it makes sense for either environmental or economic reasons to waste <br /> resources by placing soil and seeding areas which are to be used (and continue to be used) for <br /> such purposes, which would require again removing soil and vegetation. <br /> Thank you for your assistance and time in this matter. Please let us know any further questions <br /> or concerns which the Division may have. We will provide additional information as needed for <br /> the TR. We await your review and comment. <br /> If you have any questions, please contact the undersigned at WASTELINE, Inc. at 605-939- <br />