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9 , <br /> DRMS SUPPLEMENTAL REPORT:Concerns in re COMPLIANCE RE BENCHING within HIGHWALL <br /> 12/6/18 MLRB 1978-208 Shaffers Crossing <br /> compliance,and the Division staff inspector indicated concerns that in order to do so, it would be <br /> necessary to lay back the highwall from the existing mined the bench spacing(width)as indicated on the <br /> approved pians(2006)that the Operator would have to deciine the angie (attitude)of the highwaii, <br /> laying it back from its existing angle of repose and in doing so,given the offset distance between the <br /> crest of the highwall and the adjacent parcel,that the inspector was concerned that this action would <br /> impinge on the parcel, disturbing lands that were outside the approved permit boundaries. <br /> Tus in order to do so, Operator would necessarily have to engage in pursuing a 112 permit process. <br /> Operator was provided with a 60 day periods within which to remedy this issue to the satisfaction of <br /> division staff. <br /> Operator was notified that the permit application process would be triggered on a 100 day window <br /> upon revocation of bond by Board members,or by the application process having been triggered by the <br /> Appiicant%Operator. <br /> RESPONSE BY OPERATOR <br /> The Operator(Elk Creek Sand&Gravel LLC) hereby provides the following response to the Notice of <br /> inspection concerns as provided by written report to the Operator on 3/13/18 <br /> 1. The Operator denies that it was mining out of compliance with the approved mine plan and <br /> moreover indicates that the benches are in fact in place and in compliance with the reclamation <br /> plans as provided to the Division,and by and through their recommendation,as approved by <br /> the Board in 2006(see 2006 ODP Grading and Erosion Control Plans (3 pages BEI &Assoc., Inc., <br /> 2006) , Reclamation Plans(Falcon Surveying) an 3D wire mesh rendering (Falcon Surveying) <br /> together with Post Mining Rendering (Falcon Surveying, 2006)and Site Plan and Drainage Plans <br /> (Purrington Engineering 2006/2007). <br /> 2. Operator contends that it was mining in compliance with approved Plan and as such that the <br /> bench configuration exists. <br /> 3. Operator further contends that benches not only exist in appliance with a approved mine plan <br /> but are further,confirming to innovative specialty techniques employed by Operator in that <br /> Operator has engaged in 'staggered' blasting techniques,some alternating decoupled shots and <br /> other mechanisms during the drilling and blasting of the final row of drill holes (blast holes) <br /> closest to the toes of the exposed highwall face and that such mechanism is an innovative <br /> techniques developed specifically for this lithology locally here at this Quarry in order to present <br /> a finish highwall at the final pit limits configuration which achieves a more natural prance,a 'so <br /> fend' appearance, relative to the more traditional 'harsh and unnatural design characterized by <br /> the decoupled prespht shot. <br /> 4. Operator finally submits that in the event that Inspector/Division determines that the Operator <br /> has,without admitting fault,failed to conform to the final pit list configuration as stipulated, <br /> that it is mining in a lithology which based on its geological and geotechnical characteristic, <br /> conforms to a geometry which can support an over steepened sub vertical highwall <br /> mechanically and thus request that should the Division find it is non-compliant,that the Division <br />