PERMFILE44359

• Permit No: M1988112
• IBM Index Class Name: Permit File
• Doc Date: 1/3/1989
• Doc Name: BATTLE MTN RESOURCES INCADEQUACY COMMENTS
• From: CAMILLE M FARRELL
• To: STEVE G RENNER
• Section_Exhibit Name: Adequacy letter
• Media Type: D
• Archive: No

68. Persuant to Minerals Rules and Regulations Number 6.1, Grading shall be
carried on so as to create a final topography appropriate to the final land
use selected in the reclamation plan. The proposed final configuration of the
west pit, i.e., 15 ft. benches and nearly vertical 15 ft. highwalls, is not
appropriate to the final land use designated as rangeland and wildlife
habitat. It appears that terrestrial animal ingress/egress is not provided as
the proposed pit perimeter configuration is 15 ft. high by 15 ft. wide walls
and benches, respectively, exceeding areal extents and depths of 300 ft. Upon
review of Figure E.3-1, it appears that approximately one-half of the west
pit, i.e., approximately 50 acres, will not receive any reclamation attention,
but will remain as pit walls and benches.
Although Battle Mountain does not expect post-mining aquifer inflows and long
term water accumulation, the Division expects the southern depression of the
west pit to accumulate precipitation inflows and possible Rito Seco
infiltration, for extended periods, and therefore characterizes it as an
impoundment. Impoundment perimeter slopes are required to be graded to slopes
no steeper 3H:1V (from 5 ft. above to 10 feet below the expected water line).
Approval of the Earth Resources, Inc. 1983 amendment was recommended by the
staff following agreement with the operator that the final pit slope
configurations would range from 1.25 to 4 horizontal to 1 vertical, and that
any slopes greater than 30 degrees, or 1.75H:1V, would be broken with a series
of terraces.
Please consider replacement of waste rock on the benched areas to acheive
slope gradients no steeper than 3H:1V, thereby changing the pit walls and
benches into land amenable to vegetation establishment, growth and beneficial
use to the final land users, livestock and wildlife, as designated by Battle
Mountain Resources, Inc., while at the same time minimizing the disturbance of
additional land by deleting the need for additional waste rock disposal areas
Please discuss, including the approximate volumes of waste rock required to
acheive these gradients.
68. Please illustrate the final pit bench and wall elevations, and how the
contours tie into the adjacent natural topography on Figures E.3-1 and F-1.
Section E.3.2 Waste Rock Disposal Areas
69. Persuant to Minerals Rules and Regulations Number 6.1, Grading shall be
carried on so as to create a final topography appropriate to the final land
use selected in the reclamation plan. The proposed final configuration of the
waste rock piles A, B, and C, i.e., 75 ft. benches with highwalls 50 ft. in
height and 90 ft. slope lengths, approaching 1.5H:1V, is not appropriate to
the final land use designated as rangeland and wildlife habitat. Slopes
steeper than approximately 4H:1V become exceedingly difficult to establish
vegetation, inhibit livestock utilization (Stoddard, Smith, and Box, 1975),
and are more susceptible to erosion and resulting sedimentation of drainages.
Reclamation of the proposed final configurations of the waste rock piles is
further hampered by the south-facing slope-aspect and coarse texured,
erodible, sub- and topsoils available for replacement, both conditions known
for moisture deficiencies and adverse impacts upon vegetation establishment
and maintained growth. Cook, Hyde, and Sims, 1974, specify that in Sagebrush
Foothill Vegetation Tvoes. "all south and west-facing slopes should not be