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REV100645
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REV100645
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Entry Properties
Last modified
8/25/2016 1:11:07 AM
Creation date
11/22/2007 12:37:30 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1978305
IBM Index Class Name
Revision
Doc Date
12/4/2000
Doc Name
DICKERSON PIT PN M-78-305 CONVERSION APPLICATION CN01 4TH ADEQUACY REVIEW LETTER
From
DMG
To
GUNNISON GRAVEL
Type & Sequence
CN1
Media Type
D
Archive
No
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<br />Item 20 of the SUP states that adequate sediment control structures will be maintained. Your plan explains the <br />types and locations of such structures, which are felt to be adequate at this time. This issue will also be monitored <br />by DMG, as discussed above regarding roadway erosion. <br />Exhibit E -Reclamation Plan <br />You included a seed mix provided by the NRCS, but have also stated that you will follow the approved seed mix <br />already existing in the file. i will use the existing seed mix in my estimation of the costs of Phase I. Please clarify <br />if the same existing seed mix will be used for the portions to be revegetated in Phase II. <br />Certain aspects of the NPS-required reclamation plan have been dictated in the SUP, and some of them affect the <br />bond amount. As long as you must comply with the SUP to continue operating there, DMG must ensure that the <br />more stringent standard is enforced and bonded for. Some of the SUP deals with items that are administrative or <br />procedural, which DMG will probably not become involved with. Other items involve physical issues, such as <br />erosion, slopes, topsoil depths, etc„ which DMG will monitor. It would be best if you would commit to the more <br />stringent standards under this application, so that the two plans conform. This will help ensure that double bonding <br />or re-performing a task does not become necessary. Wherever applicable, I have discussed these items below. If <br />you disagree with this reasoning or any of these items, please let me know. <br />For Phase I, your topsoil replacement should be to the minimum depth required by NPS (six inches), and not the <br />four-inch depth you committed to earlier in this application. [f we require and bond for four inches of topsoil <br />replacement, then NPS will probably bond for an extra two inches. This could be viewed as a separate task, but one <br />which, if performed after the first four inches were seeded, could result in an entire second seeding cost. Please <br />clarify if the four-inch topsoil replacement depth is to remain as the reclamation specification for Phase i. <br />Item 21 of the SUP requires that topsoil be salvaged in amounts sufficient to replace asix-inch layer over reclaimed <br />surfaces. DMG can approve the use of suitable fine material (such as fines, granite sands, or subsoil) as part of the <br />"topsoil" to be replaced, but that constituent may not satisfy the NPS. Please clarify if the material to be replaced <br />as growth medium is to consist of topsoil only or if fines or sands will be also used. <br />A bulleted paragraph under item 2l of the SUP states that the powerline will be rerouted or stabilized to allow slope <br />reduction. DMG agrees that this will be required at some time between now and the end of Phase I reclamation. <br />This task is required, since reducing the existing highwall to final gradient will effectively remove the pedestal <br />upon which the pole now sits. Stabilization of the line might only have to include resetting a pole down on the pit <br />floor, however, and not a full realignment of the line. For now, 1 will consider one pole to be reset, in line with the <br />current alignment, as the existing reclamation liability. <br />A similar bullet under item 21 of the SUP requires that noxious weeds be controlled under a plan approved by NPS <br />personnel. If noxious weed control is identified by DMG in the future as being required, you should ensure that the <br />plan you submit is also approved by NPS, simply to streamline that issue. If we require a plan, we will suggest that <br />you consult with a local weed control expert or the county authority in formulating it. We will review it for its <br />adequacy, but we might not actually require proof of its approval by NPS. <br />The SUP also states that a minimum bond amount of $38,500 must be posted, according to a cost estimate <br />performed by NPS. I have not seen that estimate, though I have a copy of an earlier one performed by NPS which <br />indicated a total bond required in the amount of $52,530. 1 will assign cost figures to all of the outstanding tasks <br />associated with Phase 1, as the bond amount to be posted for the reclamation required under your DMG permit. <br />That estimate will be mailed to you separately from this letter. The better your responses to all remaining mining <br />and reclamation questions, the better our bond estimate. It appears as though if, for any reason, the bond amount <br />required to be posted with DMG is less than the amount required by NPS, they may require that you post an <br />additional bond with them. This is beyond ourjurisdiction. <br />
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