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Environment,Inc. Page 4 <br /> Ellicott Sand& Gravel LLC -M-2017-063 <br /> Adequacy response 01 <br /> to impossible. Pursuant to Rule 3.1.9(1)please discuss why a below grade stockpile is <br /> preferred under these circumstances. <br /> Initially that was to avoid placing an impediment to flood water flows across the surface <br /> and place them close to where they were needed for reclamation. But it never occurred to <br /> me that it might be a problem. I have revised the Map Exhibit C-1 - Mining Plan Map to <br /> show the soil piles will be placed around the perimeter of the excavated area. If they are <br /> located in the 100 year flood plane it will be on a temporary basis when the plan is to <br /> respread the soil on areas that are ready for resoiling in the near future and the piles will <br /> be aligned parallel to the ephemeral drainage. <br /> 7. Buildings: The first paragraph on page 8 discusses a shop and maintenance building. No <br /> mention of demolition/removal of these buildings is included in either the reclamation plan <br /> (Exhibit E, Rule 6.4.5(2)©) or the reclamation cost estimate (Exhibit L). If these buildings <br /> are to remain, please provide justification; otherwise include their demolition/removal in both <br /> Exhibits E and L (Rules 3.1.11 and 6.4.12). <br /> No buildings are planned at this time. A temporary portable scale house and scale will be <br /> installed on the entrance but no additional buildings will be needed at this time. That <br /> option was added in case at sometime in the future they were needed or desired, they <br /> could be installed. Should this occur, a Technical Revision will be filed prior to <br /> constructing them to show their temporary or permanent location and then deal with the <br /> bond increase to remove them if that is appropriate. <br /> 8. Ephemeral Drainages: The second paragraph on page 8 states the ephemeral drainages will <br /> not be disturbed by mining. Map C-1 shows mining to extend very near the Black Squirrel <br /> Creek and Big Spring Creek drainages. Furthermore, most of the mining is planned to be <br /> within the delineated 100-year floodplains. The DRMS is concerned that a 100-year flood <br /> event would erode the highwall next to the stream and as the pit is deeper than the stream <br /> invert, the stream would be captured by the pit and have not way to drain back into the <br /> drainage system. Pursuant to Rule 3.1.6, please describe how stream capture, considered <br /> disturbance to the drainage and the hydrologic balance, is to be avoided. <br /> It can't be avoided, only minimized during an unusual condition flood event. Under normal <br /> conditions there is no impact. As discussed in question 2, the propose mitigation is to <br /> install armoring along both side of the 150 foot wide berm adjacent to channel to protect <br /> the integrity of that bank. This is done so when the 100 year event ends the stream bed <br /> will remain intact and the location of the channel will not be diverted into the excavated <br /> area. The holes will drain naturally due to the nature of the sand strata along the creek <br /> and the fact that the water table is below the bottom of the mined area. <br /> 9. Area Discrepancy: The total area at the bottom of the third column in the"Estimated Mining <br /> Timetable" (p. 9) is listed as 733.87 acres, 0.17 acres greater than the 733.7 acres used <br />