<br />Your initial reclamation cost estimate looks fairly good, since it appears that most major tasks are included. Please
<br />be aware that my estimate will include all mobilization costs (as yours does), debris removal or disposal, and also
<br />contractor's profit and overhead and State contract administration. I will send the estimate under separate cover,
<br />after we have addressed the small concerns in this letter.
<br />Exhibit E -Mining and Reclamation Plan Maw
<br />The maps look nearly adequate overall, since they appear to contain the minimum required items. However, given
<br />the topography, land ownership boundaries and all existing disturbance, I feel that additional information is needed,
<br />as listed below.
<br />The Mining Map is not printed at the stated scale of 1"= 200'. It appears that it was reduced by about IO%,
<br />making the actual scale about 1" = 222'. Please commenC. (The Reclamation Map scale is accurate.)
<br />The aerial photo background on the Mining Map is helpful, but shows no features or symbols which aid in
<br />determining slope gradients, direction of surface flows, surface gradients of roads and benches, stormwater runoff
<br />berms, culverts, outlets or aprons, discharge water location(s), and pond location(s). Please provide these,
<br />preferably on a revised map, though they may be provided by narrative added to the exhibit.
<br />The Mining Map does not contain any topographic information. At aminimum, awell-chosen cross-section should
<br />be provided, which depicts the main waste rock slope, toe stabilization and sediment pond.
<br />The Reclamation Map likewise does not include topographic information, though the Rules require that the gradient
<br />of all reclaimed slopes be provided, sufficient to describe the post-mining topography. At a minimum, all drainage
<br />paths, runoff control and discharge locations, road and bench slopes, gradient of swales and dump slopes, etc.,
<br />should be depicted or described. Again, across-section ofthe site would be valuable.
<br />Exhibit G - Leal Riehtto Enter
<br />The information provided will require afollow-up submittal at some point prior to commencing operations. For the
<br />London Lode Claim #4411, the documentation of exercising the Option to Lease lands owned by OMYA, Inc. must
<br />be provided. Please ensure that it includes language sufficient to demonstrate the right-of-entry for mining and
<br />reclamation. Regarding the White Marble Placer Claim #46218, I am still investigating the right-of~ntry based on
<br />an imminent "Order for Possession". For now, the legal basis of a reasonable expectation that you vvill own the
<br />property is probably sufficient. For both claims, when final paperwork is obtained, please provide copies to this
<br />office. "Final" should be understood to mean either conclusive right to enter by means of the lease or ownership, or
<br />denial of the right to enter by lack of a valid lease or ownership. (Please be aware that loss of right-of--entry, at any
<br />time during the life ofthe mine, may constitute a violation ofthe permit conditions.)
<br />Exhibit L -Permanent Man-made Structures
<br />The single statement given should have additional information submitted, which details how the statement can be
<br />accepted. Some of this information was solicited elsewhere in this letter., but need be provided only once Please
<br />provide the basis of the statement either by 1) describing the stabilizing activities to be carried out at the toe or
<br />elsewhere on the waste dump slope, plus methods of stable placement of all new material; or 2) documentation
<br />based on certification by an engineer, which should include an identified safety factor; or 3) any other suitable
<br />documentation. This is deemed necessary due to the existing and future nature ofthe slopes and materials, and due
<br />to the need for adequate examination of these factors for the protection ofthe operator and adjoining landowners.
<br />(If your response appears to answer the stability questions related to structures and adjoining lands, it will suffice in
<br />lieu of a more detailed "geotechnical stability" exlubit, which would otherwise be required pursuant to Rule 6.5.)
<br />Ocher Items
<br />I have received copy ofthe newspaper clipping, and it appears to contain all items accurately. Please ensure [hat a
<br />notarized affidavit from the publisher is obtained and submitted prior to the decision date. I did not receive any
<br />
|