2020-07-30_REVISION - M2016080 (9)

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proposing this pond to be excavated into the groundwater table,please submit clarification from DWR that the currently approved SWSP covers the excavation of the recirculation pond down into groundwater or commit to obtaining a revised approval from DWR. The current approved SWSP covers all exposed water surface on the property containing the Trout Valley Ranch operation. The recirculation pond, freshwater pond, and any other exposed water surfaces at the mine will have to be maintained in line with the SWSP. Currently,the recirculation pond is still above groundwater, and this is reflected in the approved SWSP. Brannan will amend the SWSP (it is up for renewal in October 2020) in advance of excavation into groundwater as required by CDWR. Item 4: TR-01 states the Operator has water rights which allow for water exposure within and outside the affected area boundary. Understanding there are several ponds exposed just east of the permit boundary,please provide the acreage of the total maximum water exposure within the permit boundary allowed under the current decree. The current decree allows for a total water exposure of 40 acres across the property and is not limited by the permit boundary. At the time of the decree, 3.8 acres of water exposure was available for the operation beyond what was already exposed, as 36.2 acres of water exposure already existed on the property. Roughly 24 acres of water exposure are outside of the permit area currently. Brannan will maintain accounting of the water surface exposure to maintain compliance with their SWSP. Item 5: The original permit discussed sediment fines from the wash plant would be mucked out of the recirculation pond and stockpiled for use as a substitute for topsoil during reclamation. Please address where the required amount ofgrowth media will now come from as TR-01 is proposing to excavate the recirculation pond deep enough that buildup of sediment within the pond over time will not necessitate clean out and once filled in with sediment, a new excavation will be needed to maintain the capacity of the recirculation pond. The wash plant muck and other fines will be used to backfill the recirculation pond to above the water table. This process will leave a backfilled ground surface made of the same substitute topsoil material (sediment fines) as already listed in the approved permit.1 In dredge areas, this final substitute topsoil material surface will be directly revegetated. In non-dredge & non-lake ' Trout Valley Ranch DRMS permit page E-1:"Processing fines will be used as substitute topsoil in the dredge pile areas." Trout Valley Ranch TR July 2020 2 Gn;;t cwicl.�anA �swcialr�,1'1 L(