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2019-09-30_REVISION - M1988108
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2019-09-30_REVISION - M1988108
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Last modified
1/6/2025 4:29:33 AM
Creation date
10/1/2019 1:47:16 PM
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Template:
DRMS Permit Index
Permit No
M1988108
IBM Index Class Name
REVISION
Doc Date
9/30/2019
Doc Name
Adequacy Review Response #3
From
Arcosa Lightweight
To
DRMS
Type & Sequence
AM3
Email Name
ECS
Media Type
D
Archive
No
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ARCOSA <br /> and <br /> (v) Topsoiling - specify anticipated minimum depth or range of depths for those <br /> areas where topsoil will be replaced. <br /> The post-mining land use specified for this permit is rangeland, however the proposed final <br /> slope of the quarry area is 5H.-3V. This is notably steeper than the slopes typically allowed for <br /> rangeland. The act states that "if the operator's choice of reclamation is for range, the affected <br /> land shall be restored to slopes commensurate with the proposed land use that shall not be too <br /> steep to be traversed by livestock. " Rule 3.1.5(7) also states that "In all cases where a lake or <br /> pond is produced as a portion of the reclamation plan, all slopes, unless otherwise approved by <br /> the Board or Office shall be no steeper than 2H.•I V.... " <br /> DRMS also notes that post-mining slopes this steep are prone to excessive erosion, and very <br /> difficult to revegetate. The proposed drill seeding and mulching of the slopes will also be <br /> difficult or impossible at that slope. Please provide adequate justification that a post mining <br /> slope of 5H.-3V as proposed is appropriate and stable, or modify all reclaimed slopes to be no <br /> steeper than 2H.•I V. <br /> The current reclamation plan states that the processing plant will remain after mining <br /> operations cease. This would require that the plant area be designated with a post-mining land <br /> use of industrial/commercial, not rangeland, and it will need to be identified on the reclamation <br /> map as such. Also please provide proof that this industrial/commercial land use would be in <br /> compliance with local land use regulations/requirements such as zoning and building codes. <br /> The reclamation plan provided states that soil amendments may be required to revegetate in <br /> areas where topsoil is not available. Please state what kind of testing/amendments will be <br /> utilized in these areas, and provide the appropriate costs in the reclamation bond estimate. <br /> What will be the final size of the proposed pond in the base of the pit area? How will water <br /> rights issues for the pond be addressed, is there an existing permanent augmentation plan for <br /> this proposed water body? Given that the excavation is in an area of low permeability, will the <br /> excavated area within the shale be tested to determine if it meets the SEO standards for a lined <br /> reservoir to eliminate the issue of groundwater exposure during and after mining? How will the <br /> quarry area manage precipitation/seepage after reclamation? Per SEO regulations all <br /> precipitation captured by the pit during and after mining needs to be returned to the pre- <br /> existing drainage system within 72 hours. DRMS is also required to bond operators to eliminate <br /> the liability of exposed groundwater through backfill, or construction of an approved liner, if a <br /> permanent augmentation plan is not approved. The operator may also commit water rights <br /> sufficient to address exposed groundwater to SEO to address bonding liability until the <br /> permanent augmentation plan is approved please address. <br /> Arcosa's Response: <br /> The reclamation plan has been updated to address these comments and clarify references to <br /> Exhibit F. A revised Exhibit E is provided in Attachment 7. The Reclamation Plan Map Exhibit <br /> F-1 has been revised and is provided in Attachment 7. A focused map of the quarry area <br /> reclamation is provided as Exhibit F-2 which is provided in Attachment 7. <br /> Please note: <br /> 1. Construction Materials Rule 3.1.5 (7) indicates maximum slope configurations shall not <br />
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