2023-02-24_PERMIT FILE - M2022013 ‎(3)‎

• Permit No: M2022013
• IBM Index Class Name: Permit File
• Doc Date: 2/24/2023
• Doc Name Note: Cover Letter
• Doc Name: Adequacy Review Response #3
• From: Raptor Materials, LLC
• To: DRMS
• Email Name: RDZ
• Email Name: MAC
• Email Name: LDS
• Media Type: D
• Archive: No

development of an economically sound and stable extraction materials industry, and the
orderly development of the state's natural resources, by providing options to address the
setback proposed based on guidelines from district in which the proposed project is not located
to something more reasonable. To that extent, Raptor has modified the relevant sections of the
application to reflect the nominal 400-foot setback and is performing an alternate analysis on
the possibility of riverside berm failure using an alternate methodology using HEC-RAS and the
incorporated DL Breach module. Raptor Materials intends after permit approval to present the
results of this ongoing engineering evaluation as a Technical Revision to obtain relief from what
we are confident are extremely conservative and resource wasteful setbacks while still
providing more than adequate protection for the adjacent rivers.
The following documents were included in our supplemental response on second adequacy on
February 02, 2023:
- Updated 112 Form
- Updated Exhibit D- Extraction Plan
- Updated Exhibit E- Reclamation Plan
- Updated Exhibit G -Water Information
- Updated Exhibit I/J -Soils Information
- Updated Exhibit L- Reclamation Costs
- Updated Exhibit Cl Map- Existing Conditions
- Updated Exhibit C2 Map- Extraction Plan
- Updated Exhibit F Map- Reclamation Plan
- Updated Exhibit G Map-Water Information
- Updated Exhibit 1/J Map-Soils and Vegetation
- Updated Exhibit L Map- Financial Warranty
[Files did not include Updated Exhibit G Map - Water Information]
Raptor Materials received Third Adequacy Reviews dated 09 February, 10 February and 14
February, 2023. The items requiring a response in our third adequacy response are addressed
by exception. Raptor's responses below follow the comments from the adequacy review and
are highlighted in blue font for clarity.
6.4.7 Exhibit G - Water Information
Item 46) To ensure that the Two Rivers project does not impact the hydrologic balance of the
rivers, the application needs to include a water quality monitoring plan, specifically for the
alluvium. The groundwater monitoring plan should be developed in accordance with Rule
3.1.7(7)(b) and should include a Quality Assurance Project Plan (QAPP) for the collection of
groundwater samples. The plan should provide mitigation steps if there is an exceedance at a
groundwater or surface water monitoring location. Potential impacts to quality and/or quantity
the nearby domestic wells should also be addressed. A copy of the Division's Groundwater
Monitoring and Protection Technical Bulletin has been included as an enclosure to this letter for
your reference.