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<br />M-95-005/Final Adequacy <br />12/11/95 <br />page 2 <br />Exhibit D - Minino Plan Mao - You have still included a plan with <br />four phases, though the locations are different. Though the phases <br />are not well defined by boundary or years of operation, their <br />depicted locations seem to clarify the progression of the mining <br />through the total permit area. It seems as though there may be <br />activity in more than one phase at once, though the total acreage <br />will not exceed 20 acres. You have committed to a total <br />disturbance of 20 acres, which is to consist of different amounts <br />of acres of major, moderate and minor disturbance. Disturbance <br />includes all areas used for roads, stockpiling and equipment. This <br />20-acre limit implies at least two things: 1) you may not expand <br />your operation beyond 20 acres in any way until some of your <br />disturbance is fully reclaimed (ie., to the point of being <br />completely revegetated, not just seeded); and, 2) until some of the <br />disturbed acreage has reclamation commenced upon it, it should have <br />a bond sufficient to reclaim it as major disturbance. You verbally <br />commited to the following number of acres of disturbance within <br />your stated 20-acre total: 8 acres major, 8 acres moderate, and 4 <br />acres minor. I will therefore require a bond for reclaiming your <br />20 acres of disturbance according to the amounts you specified. <br />Your total disturbance must also never exceed those levels at any <br />time, which will be verified from time to time from inspections. <br />I understand that the buffer strip around the perimeter of the <br />permit will have no activity on it. You verbally clarified to me <br />that the buffer strip is actually a "setback" outside of the permit <br />boundary. It pertains to the western and northern permit <br />boundaries, as follows: the western permit boundary line is set <br />back from the property line by 30 feet, and the irregular northern <br />permit boundary line is set back (to the south) from the <br />topographic rim of the mesa. If this is correct, please confirm <br />this, and ensure that these details are shown correctly on your <br />permit maps. <br />The mining phase map, as submitted, is not adequate to depict more <br />than the general locations of the phases. Its scale is about <br />1":1280', which is too small to show any detail. The depiction of <br />the separate phases shows gaps of 60 to 200 feet between them <br />(according to the map scale), though that may have been done <br />inadvertently. It does not show the permit boundary, but only the <br />DuCray property boundary. Another mining map must be submitted, <br />with a larger scale, a clearly marked permit boundary, the buffer <br />strips, roads, areas which will not be disturbed, any <br />sediment/runoff control berms, and locations of power poles. <br />Exhibit F - Reclamation Plan - You submitted a diagram of cross <br />section A-A, which looks clear except for the 10-foot earth berm at <br />the bottom of the slope. Where is that structure located? Is it <br />a structure to remain after reclamation? Is it an impoundment or <br />