PERMFILE49711

• Permit No: M2005066
• IBM Index Class Name: Permit File
• Doc Date: 4/6/2006
• Doc Name: Adequacy Response
• From: Banks and Gesso LLC
• To: DMG
• Media Type: D
• Archive: No

20. Please provide a reclatation plan for the four monitoring wells located on site. Please include the
depth of wells, diameter of the wells and how the wells were completed. This will assist the Division
in determining a final cost of reclamation.
21. The groundwater model prepared by the applicant did not take account of the dewatering and dry
mining of the 10-acre Phase 1 pit that will not be lined with a slurry wall. The pit will ultimately be
backfilled to approximate original contours, but with overburden and shale extracted from Phases 2
and 3. Please revise the model to include the dewatering, mining and reclamation of the Phase 1 pit.
22. Please depict the location on a map where mine water will be dischazged. If mine water is dischazged
into a ditch or other man-made structure, please provide consent to discharge water into this structure.
If water is discharged into a ditch that is unlined, it may be prone to erosion if the discharge rates
exceed the carrying capacity of the ditch. The applicant should submit documentation to the Division
for review as to the proposed maximum discharge rate into the ditch and specifications as to how
much water the ditch can carry without experiencing erosion.
23. The groundwater report does not specify the maximum drawdown of wells in the surrounding area as
a result of the slurry wall or the 10-acre pit that will not be lined. Please address this issue
accordingly.
24. The Division received comments from the Office of the State Engineer (OSE) regarding the proposed
application. According to the OSE, before a well permit can be approved the applicant must conduct
a field location of the site and document the locations of all wells within 600 feet of the permit area.
The applicant must then obtain a waiver of objection from all weA owners with wells within 600 feet
of the permit azea or request a hearing before the State Engineer. See the attached OSE letter for
further detail, Please commit to not exposing groundwater until a well permit is obtained from the
OSE. In addition, once the well permit is obtained a copy must be submitted to the Division.
25. A mare detailed review of the groundwater model will be forthcoming, and additional questions may
arise based on the review.
Rule 6.4.10 Exhibit H-Wildlife Information
26. The applicant suggests that mining in the southwestern portion of the site commence once the
burrowing owls have left for the winter. Please state the dates in which the area will be avoided and
mining will not occur in this area.
Rule 6.4.10 Exhibit J-Vegetation Information
27. Wetlands aze noted to exist on site (noted as A, B and C). Please state if the areas defined as wetlands
will be reclaimed to wetland areas and provide additional information regarding the reclamation of
[he wetlands. In particular, please state the final reclaimed slopes, depth of topsoil to be replaced and
the wetland seed mixture to be utilized,
Rule 6.4.12 Exhibit L- Reclamation Costs
28. The operator is requesting that 20% of the slurry wall liner be submitted, with the commitment that
the slurry wail will not be constructed until construction information is submitted. For an operator to
be eligible for the 20% bonding option, the Division must have a high degree of assurance that the
liner or slurry wall installed by the Operator will meet the State Engineer's performance standard.
This assurance is provided through inclusion of design documents, plans and specifications, and a .
quality assurance program as enforceable components of the reclamation permit. The factors that
must be addressed in the reclamation plan include the design of the slurry wall (including
construction plans and appropriate drawings), technical specifications, construction quality
controVconstruction quality assurance (CQA) and a final construction report including the CQA