2003-12-18_REVISION - M1977416 - Laserfiche WebLink

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Bob Oswald Re: Carnation Mine, Permit M-1977-416 Response to December 10, 2003 Comments Page 2 of 3 3. OK for main access road crossing site to remain unreclaimed, with other "onsite roads" to be reclaimed according to the plan. Do you foresee the need for vehicle barriers (earthen, oversize rock, fences) to prevent unauthorized access to the "onsite roads "? Response: In the case of the Carnation Mine, portions of the St. Jude Mine (Permit M-1978- 039HR) access road is on both the Carnation Mine Permit and the St. Jude Mine Permit. In the current circumstances, closure and blocking of the St. Jude access road, most likely with an earthen berm and boulders, would be indicated. However, the Operator will solicit input from the Division and the BLM as to the effectiveness of "final" road closures and blockages given the proliferation of 4WD vehicles and All Terrain Vehicles on public lands. More site damage may result due to persistent efforts of site visitors to access "closed" sites than would occur if the roads were stabilized, but left accessible. The Operator proposes to defer on this question until final reclamation is imminent to draw upon the collective experience of the involved agencies. 4. OK for culvert to remain during reclamation for access. Will it be removed as part of final reclamation? Response: The Operator proposes that the culvert under the St. Jude Mine access road be left in place permanently. Removal of the culvert and regrading and reclamation of the disturbed segment of this road will create additional disturbance. 5. Okfor various other earthen runoff control structures to remain. Response: No response. 6. Agree that 2:1 throughout is OK for maximum slope. Also agree that certain slopes are steeper than 2:1, but are nevertheless stable and/or are inaccessible to reclamation eguipment, may remain as is for final reclamation. The allowance for the variance to the 2:1 maximum gradient will be limited, however, to a minority of slopes considered reclaimed. Response: The Operator acknowledges the Division's viewpoint; allowances for slope gradients steeper than 2:1 are expected to be exceptions, but do provide a logical alternative to creating additional disturbance for limited benefit in certain circumstances. 7. It is understood that there is a scarci>y of topsoil salvaged for reclamation use, and that seeding will occur on subsoil or other medium present onsite. Every effort should be made to salvage additional topsoil from further areas of the site which may be affected, and possibly from sediment collection areas if sediment transport "delivers" topsoil-type material to the site. If revegetation is not satisfactory for identifiable reasons, additional inputs may be necessary, such as reseeding, fertilizer application, surface roughening, topsoil application, etc. Response: Acknowledged.