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REV05290
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Entry Properties
Last modified
8/25/2016 1:03:47 AM
Creation date
11/21/2007 9:24:38 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1977210
IBM Index Class Name
Revision
Doc Date
5/22/1989
Doc Name
RESPONSES TO ADEQUACY LETTER FOR SNYDER QUARRY AMENDMENT FN 77-210
From
MARK A HEIFNER
To
MLR
Type & Sequence
AM3
Media Type
D
Archive
No
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<br /> <br />ITEM 10 _ On page 35, discussion is made regarding "reclamation management to be <br />done several times a year." Please be more specific. Who will do these <br />inspections? Will success be a visual standard, or will a statistical sampling <br />program be employed? <br />RE~ONSE: On page 35 it actually says that reclamation inspections will be <br />done several times a year, not reclamation management. The inspection rate during <br />the first two or three years of a newly reclaimed area is usually a minimum of once <br />a month during the growing season and a couple times during the non-growing season. <br />The only exception to this occurs after a severe thunderstorm in which case the area <br />is inspected anywhere from a few hours to a couple of days after the storm, <br />depending upon how severe the storm was. <br />These inspections will be carried out by a revegetation specialist retained by <br />Castle Concrete or hired on staff. For the most part, the assessrtient of success <br />will be done on a visual basis. That is all we believe the law calls for or was <br />intended to require. However, prior to a request for bond release it is customary <br />for Castle Concrete to conduct a quantitative analysis of the vegetation. <br />Occasionally this is done during vegetation development, especially if it is sensed <br />the vegetation is not developing as expected. Another method of monitoring <br />vegetation development uses multiple, small permanent plots which are established <br />and photographed each year for a number of years. This provides a highly detailed <br />record of vegetation composition shifts and can even record the movemciit of rocks <br />and the occurrence of micro-erosion which can affect the stability of individual <br />plants. For reclamation purposes, we feel this method, although tedious, is <br />probably the best way to record the development of vegetation an a parcel of land. <br />ITEM 11 -_ Your discussion on page 41 of the unreclaimed back walls should include, <br />in more detail, information about height, slope angle of wall face, and height of <br />backfilling. It is recommended that the unreclaimed highwall height be a maximum of <br />12 feet from the tap of the backfilled material to the tap of the wall. This is <br />recommended to more adequately comply with those sections of 34-32-116(7) that <br />address slope stability, appropriate final land use grading, and erosion control. <br />In addition, this reduced backwall height will provide for a reduced amount of <br />unreclaimed area. Also, as these benches and backfilled talus slopes will all be <br />south-facing, please design the backfilled areas for a minimum 3H:1V slopes. These <br />slopes will allow for more rapid revegetation and for less soil erosion and <br />subsequent sediment increased in run-off discharges. Please incorporate these items <br />with the mining and reclamation plans or discuss why they should not be. <br />RED: It is not possible to commit to having no more than 12 feet of <br />backwall on any one bench. This would require 18 feet of fill against the back of a <br />30 foot wall, and, as indicated in the plan, some of the walls will need to be 30 <br />feet high. Most will be lower than that; about 20 to 25 feet. At the most, about B <br />feet of fill can be placed against the backwall. Please keep in mind that the <br />purpose of placing backfill on the benches with maximum depths against the wall is <br />to accommodate revegetation and not for safety purposes. Mining regulations allow <br />walls of up to 30 feet in height and in most quarry situations 30 foot walls are <br />quite stable. Also, our original permitted plan called for producing 30 foot walls <br />with 15 foot wide benches and with vegetation growing on the benches in a sparse and <br />highly droughty growth medium. Castle Concrete could have proposed such a <br />configuration in the 1984 amendment and could have justifiably received approval. <br />However, the approach was altered to accommodate a better environment for <br />revegetatim. To backfill the benches so backwall heights are reduced to a maximum <br />STIYDEI2 N.1 fT ADE(]UACY REDS MAY 22, 1989 PACE 10 <br />
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