2020-06-16_PERMIT FILE - M2020007 ‎(7)‎

• Permit No: M2020007
• IBM Index Class Name: Permit File
• Doc Date: 6/16/2020
• Doc Name: Adequacy Review Response #2
• From: Environment, Inc.
• To: DRMS
• Email Name: ECS
• Media Type: D
• Archive: No

Environment, Inc. Page 3
Adequacy Response#2 June 11, 2020
M-2020-007
Plant. The concrete will be between 12 and 24 inches or larger in size, the above
water portions will be soiled and revegetated. This will be done once rough sloping
is completed in these areas and concurrent with reclamation. L.G. Everist plans to
do the armoring in 1,000 foot long sections as the slopes are in final grading. The
Bank Armoring plan explains the placement and where the unit volume of 2.35 cyds
per linear foot was determined. LGE will also commit to having 2,350 cyds of
armoring material stored within 500 feet of the areas needing armoring at all
times. The cost to install t 2,350 cyds of bank armoring is included in the
Reclamation Cost Estimate. I have revised the Mining and Reclamation Plans and
Reclamation Plan Maps to reflect these changes.
In addition, the UDFCD guidance shown in Table 2.2 Lateral Berm Top-Width (page 28) states
that the minimum berm top width for an unprotected Type A lateral berm (the berm between
Phase 1 and Phase 2) should be 250 feet. If the banks of the lateral berm are protected
according to the provided guidelines, that distance can be reduced to 100 feet.
Figure 1 shows the lateral berm configuration between Phase 1 and Phase 2. The
riverbank (blue line) was located in the field and using aerial photos. The permit
limits (white Line) and the mining highwall line (light blue) were added from the
permit maps. The highwall line is the top of the bank for each reservoir. The 150
foot river setback line (green) and 250 foot setback line (red) was added then to
determine the relationship of the river setback on the lateral berm. A 400 foot
was later added (purple) to help determine that the width of the lateral berm was
at least 250 feet wide within 400 feet of the riverbank. At the 400 foot setback
line, the lateral berm is in excess of 350 feet wide so no armoring is needed on the
berm.
DRMS could review sound arguments to modify those requirements on a site-specific basis, but
there will need to be sufficient hydrologic/engineering justification provided to do so.
Please modify the mining and reclamation plans and maps as needed to depict the appropriate
berm widths for unprotected features, or, provide the appropriate designs and show the
locations for the necessary pitside protection structures on the Reclamation Plan Map. Costs for
pitside/berm protection will also need to be included in Exhibit L.
I have revised the Mining and Reclamation Plans and Maps as discussed to show the
location of the armoring to be installed in Phases 1 & 2. I have included a cost to
install the armoring in Phase 1 with the commitment to have 2,350 cyds of concrete
rubble near the placement area. Only placement cost is included since it will not
have to be purchased.
Text remains in this exhibit requesting "..that the establishment of full revegetation will not be
required for permit acreage release if"reasonable assurance" that the development for the
approved post mining land use will continue prior to establishing permanent vegetation. An
example of"reasonable assurance" is a letter from the landowner (Cannon Land Company)