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<br />Mr. James Dillie <br />Adequacy Letter, Apache Mine Permit No. M78-009 <br />Page 3 <br />comp/lance with this requirement since it does not appear that these <br />areas have been disturbed However, the plan does state that "mining in <br />Stage 3 will not begin until aU clays are removed from Stages lA andlor <br />lB. " The operator does not appear to be in comp/lance with this <br />requirement because mining began in the southern portion of the north <br />clay deposit which is located in Stage 3. /n addition, the north central <br />mining disturbance appears to extend into Stage 3. Please address this <br />situation. If the Division is correct, the applicant must revise the Mining <br />Plan to reflect the exact method and direction of the mining operation. <br />A new Mining Plan (Exhibit D) has been provided to the Division, as part of the response <br />to a Permit Disturbance Variance in July 1999. Exhibit D, unchanged from the draft <br />version, has been incorporated into the attached replacement pages for the permit <br />amendment. Specifically, Page 7 of Exhibit D was changed as follows in response to this <br />comment. <br />.. hauled to the brick plant. Hauling operations normally occur intermittently on <br />a yeaz-round basis. <br />West pit mining (~k4Aj continues in Stage lA, proceeding south. <br />Mining will continue in Stage lA for approximately 20 to 25 years. North pit <br />mining (~1A~-A~) is in Stage 3, preceding north. Mining in Stage 3 will <br />continue for S to 12 years. <br />Mining in Stage 2A will not begin until e4'1 +eest the majority of the useable <br />clays in the eastern portion of Stage lA are removed €renr£~ege-1~~. Mining in <br />Stage 2A will continue for 7 to 12 years and then proceed to the western <br />portion of Stage lA. Likewise mining in Stage 2B will not begin until al} west <br />the majority of the useable clays io the eastcre northern portion of Stage 3 <br />are removed £rex~-Stage-~B. Mining in Stage 2B will continue for 15 to 20 <br />years, then proceed to Stage lb and then back to the eastern portion of Stage <br />3. <br />ex~er~li~ <br />The stockpiling process for each type of clay will begin with the removal and <br />storage of topsoil from the first area ... <br />Item 4 The approved Mining Plan states that "dust generated during the <br />stockpiling and hauling process will be controlled effectively by water <br />spraying." Because of your recent comments, you need to clarify <br />exactly how you intend to control, or minimize, the dust problem. You <br />told the Galbreaths, at the /nformal Conference, that RBC sprays <br />chemicals on the roads to control dust Hawever, the approved permit <br />states that water from the existing water bars will be used for dust <br />