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<br /> <br />C~ <br /> <br />Letter to Joseph de Raismes 8 Mav 3. 1995 <br />Mineral Rules and Regulations of the Mined Land Reclamation Board <br />require "adequate compaction". Adequate compaction i:e specifically <br />required in the Rules "for stability". The Board has recognized, at <br />the time of March 23, 1994 rule-making, that slopes such as those <br />proposed for reclamation of the Jenkins Pit are inherently stable. <br />The Statement of Basis and Purpose from that rule-making session <br />states: <br />If only shallow, non-impounding fills are proposed in the <br />mining and reclamation plans fora particular mine, such as <br />would be the case for backfilled or cut and fill :elopes at many <br />gravel pits, and if there are no cut slopes ~~r high-walls <br />proposed to remain at the site after reclamation, it is <br />unlikely that the Office would require the appliceent to prepare <br />quantitative engineering slope stability analyses'. <br />The slopes proposed for the Jenkins Site are shallow, low, and <br />primarily composed of gravelly soils. It is the Division's view <br />that such slopes will be stable regardless of the degree of <br />compactive effort applied, hence specification of a degree of <br />compactive effort is unnecessary. <br />Item number 8 of your list of concerns further states that no <br />provisions have been made for protection against erosion. The <br />Division disagrees. One of the best management I~ractices for <br />protection against erosion is vegetation establishment. The seed <br />mix to be planted at the site this spring includes 5 pounds per acre <br />of Regreen (a sterile hybrid), which is a quickly estakelishinq cover <br />crop that will hold the soil and prevent erosion. <br />Also in your item number 8, a concern is expressed wine weed control <br />at the site. As you point out, weed control is a requirement of the <br />Mineral Rules. The operator will be required to control noxious <br />weeds, as well as any other weeds that seriously threaten continued <br />development of desired vegetation. The Division wi:Ll include an <br />appropriate cost for weed control into the amount of required bond <br />for the site. The concern is expressed that spreading of topsoil <br />will significantly increase the knapweed problem. Sins;e knapweed is <br />pervasive throughout the site, it is difficult to visualize how <br />movement of soil could exacerbate the problem. In fact, site <br />grading and topsoil spreading may temporarily suppresse the knapweed <br />allowing desired vegetation to better establish. <br />11. In item number 9 of your list of concerns, you emphasize that the <br />Division should have required soil analysis of ttie stockpiled <br />material, and salinity testing of clay deposits. The Division will <br />be working with the operator to determine an appr~~priate soils <br />testing protocol, and will require soil amendments ae necessary in <br />areas were the spring seeding is less successful. Soil testing <br />completed to date suggest no significant concerns with variability <br />