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2020-05-08_PERMIT FILE - M2020007
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2020-05-08_PERMIT FILE - M2020007
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Last modified
1/7/2025 6:18:40 AM
Creation date
5/12/2020 6:35:47 AM
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Template:
DRMS Permit Index
Permit No
M2020007
IBM Index Class Name
PERMIT FILE
Doc Date
5/8/2020
Doc Name
Adequacy Review Response
From
Environment, Inc.
To
DRMS
Email Name
ECS
Media Type
D
Archive
No
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ENVIRONMENT, INC. PAGE 1 0 <br /> L.G. EVERIST, INC. - RAGSDALE RESERVOIR ADEQUACY RESPONSE 01 <br /> MAY 6, 2020 <br /> accommodate the Federal and State requirements. They will get a clarification from the <br /> CPW and U.S. FISH AND WILDLIFE SERVICE on the raptor setback requirements, and we <br /> will send those updates to the Division under separate cover. <br /> EXHIBIT L - Reclamation Costs (Rule 6.4 . 12) : All information <br /> necessary to calculate the costs of reclamation must be submitted <br /> and broken down into the various major phases of reclamation. You <br /> must provide sufficient information to calculate the cost of <br /> reclamation that would be incurred by the state . <br /> As stated previously, the provided "snapshot" approach provided <br /> for bond calculation is not appropriate for this site . If the <br /> applicant wishes to use a phased bonding approach, they will be <br /> required to break down the bonding costs into rational "phases" <br /> of mining and site disturbance (i .e. West Side/East side, or by <br /> Phase if possible) , and present the reclamation costs for those <br /> phases . Selecting an indeterminate point in the mining process <br /> will not be acceptable unless it ' can be demonstrated that, that <br /> point represents the maximum reclamation liability for the site <br /> as a whole. Please adjust the cost for the reclamation accord- <br /> ingly. It would likely be most useful to break down the reclama- <br /> tion costs Phase as shown on the mining and reclamation plans . <br /> The bonding has been broken down by phase, as you suggested. As you know, reclama- <br /> tion occurs concurrently with the mining operation, so the "snapshot"that we submitted was <br /> a reasonable estimate for the maximum disturbance at any given time. We modeled this <br /> bond calculation approach after the recent Firestone Gravel Resource bond recalculation, <br /> which you guided us through. The table included in the revised Reclamation Cost Esti- <br /> mate, has broken out the reclamation activities needed to finish each Phase disturbed. The <br /> totals are then used to calculate the cost for each activity needed. <br /> DRMS also notes that no costs have been provided for design or <br /> installation of flood control structures in Phases 1 and 2 which <br /> are located within the flood plain as shown. Dewatering costs for <br /> areas to be wet mined, prior to backfilling should also be <br /> included. <br /> As mentioned above, no inlet/outlet structures will be built on this facility. It is not L.G. <br /> Everist's responsibility to bridge the gap between the permit area and the river's edge. So <br /> there are no bonding costs for inlet/outlet structures, because none are planned. <br /> The landowners do not want inlet/outlet structures, which is why they have not been added <br /> to the Mining and Reclamation Plans and Maps. However, if the landowners determine the <br /> need for inlet/outlet structures prior to permit release, and if the structures are added within <br /> the permit area, then a Technical Revision will be filed showing the design and layout for <br /> such inlet/outlet structures and the bond will be revised as applicable.. <br /> I have not included "dewatering costs for areas to be wet mined, prior to backfilling", as you <br /> suggested, into the bonding calculations. Material pushed into the water will tend to <br /> naturally spread out to less than 3h to 1v, the exterior slopes will already be graded 3h to 1 <br /> v so no underwater reclamation will be required even if a gravel pit lake was left. So there is <br />
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