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Adequacy Response <br />Page 2 of 4 <br />Whits River City Pit <br />Permit No. M-2006-084 <br />Response: As requested, we have responded directly to the Colorado Historical <br />Society (CHS) to resolve this issue. We provided the CHS with additional <br />information regarding the specific location of the proposed mining operation and <br />the current site conditions. Based on the information provided, the CHS has <br />determined that the proposed mining operation will have no effect on site <br />SRB2662. A copy of the letter indicating this is enclosed for your records. <br />4. Within the Mining and Reclamation Plans it is noted that there is shale bedding. <br />Please commit to preventing disturbance to the shale by keeping a 2 foot depth of <br />natural materials over the bedrock. It is understood that exposure will happen from <br />time to time and limiting exposure of shale to air will reduce the likelihood of <br />increased selenium. <br />Response: The applicant hereby commits to leaving two feet of natural material <br />on top of the bedrock to avoid exposing the underlying bedrock to air, thereby <br />reducing the likelihood of selenium leaching from the bedrock. <br />5. Please verify that selenium will or will not be monitored as part of the NPDES permit. <br />Response: Monitoring of selenium is not required as part of the NPDES permit, <br />therefore no monitoring of selenium will take place. <br />6. In the Mine Plan it is noted that 200 gpm will be pumped into the adjacent wetlands to <br />prevent the area from drying out. Please clarify when it is anticipated that pumping <br />will begin and also if there is a plan in place to monitor that 200 gpm will be sufficient <br />to protect the wetlands. <br />Response: Pumping will begin after approximately 2/3 of Phase 2 has been <br />mined, which is estimated to be approximately two years after mining <br />commences. Currently there is no plan to monitor whether 200 gpm will be <br />sufficient to protect the wetlands; it is the opinion of Greg Lewicki and Associates <br />that 200 gpm will be sufficient to protect the adjacent wetlands based on our <br />experience with the Piceance Pit, DRMS Permit No. M-2001-077, which is less <br />than two miles away and operating under similar conditions without impacting <br />the wetlands. <br />It is noted that the operator will mine vertical up to the buffer zone and then 2:1 to the <br />disturbance edge. Please commit to marking the disturbance edge which is mostly 30 <br />feet within the permit boundaries. Also, the operator needs to delineate the buffer <br />zone where 2:1 sloping must begin. <br />Response: The applicant hereby commits to marking the boundaries of the <br />disturbed area and the boundary where the 2:1 slope will begin. <br />8. Please cornrnit to seeding the topsoil and overburden piles with the approved dry <br />rangeland mix upon placement along the permit edge. <br />