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David Berry <br />-5- June 20, 1996 <br />24. BRL obtained a letter from the NRCS office regarding prime <br />farmlands. The local NRCS office found two soil map units <br />within the permit area which meet the requirements for Prime <br />Farmland if they are irrigated. These soils are the Potts <br />Loam (60) and the Work Loam (82). Both soil map units are <br />located south of Highway 133 and below the Fire Mountain Canal <br />and Deer Trail Ditch which is outside of the area of proposed <br />disturbance. The NRCS did not consider the slope of the land <br />in making their prime farmland determination. <br />Enclosed is the letter from the NRCS to be incorporated into <br />Volume III, Exhibit 14. Also enclosed is revised page 2.04-58 <br />which changes the discussion of prime farmland based on the <br />NRCS letter. <br />25. The DMG provides a lengthy discussion of the importance of <br />adequately addressing the stability of the proposed <br />facilities. BRL has hired Morrison Knudsen to prepare a <br />geotechnical investigation of the proposed disturbed area and <br />to incorporate the results of the investigation into a <br />detailed site design. This work will be complete around <br />September 1, 1996 and will be submitted to the DMG as soon as <br />possible thereafter. <br />26. BRL proposes to construct the haul road along the railroad bed <br />without a sediment control facility. The DMG asks BRL to <br />specify which alternative sediment control devices and <br />techniques will be implemented and at what specific locations. <br />The rules do not require that drainage from haul roads be <br />routed to sediment ponds. Rule 4.03.1(4)(iv) requires that <br />haul roads not within the disturbed area be constructed to <br />minimize erosion, resultant siltation, and disturbance to the <br />prevailing hydrological balance. Since the haul road along <br />the railroad bed is adjacent to a material storage yard, <br />alternative sediment control devices will be utilized for <br />drainage from the road. Enclosed is revised page 2.05-32 <br />which explains the alternative sedimentation control <br />techniques to be utilized for the haul road. <br />The DMG further asks BRL to provide detail concerning the <br />existing water conveyances along and under old state Highway <br />133 to demonstrate that changes within the mine permit area, <br />which affect water retention and routing, will not overload <br />the existing ditches and culverts and compromise old State <br />Highway 133. BRL assumes the storm event which would be used <br />to analyze this question would be the 10 year 24 hour event <br />since nearly the entire site is designed based on that storm <br />event. BRL submits that it has improved the drainage system <br />as it relates to old State Highway 133. Run-off generated <br />from the 10 year event from B-Gulch is contained in Pond B. <br />Run-off generated from the 10 year event from C-Gulch is <br />contained in Pond C. Run-off generated from the 10 year event <br />