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<br />Mr. James Dillie <br />Adequacy Letter, Apache Mine Permit No. M78-009 <br />Page 7 <br />Item 7 You did not submit a new Exhibit E, Reclamation Plan, so, in effect, you <br />do not intend to change any of the required reclamation. As approved, <br />you plan to eliminate a couple of the existing holding ponds in Stage 2A <br />area during mining operations and you, currently, do not plan to <br />construct new ponds. How do you intend to contro% minimize or prevent <br />downstream sedimentation problems before the planned vegetative cover <br />becomes dense enough to prevent erosion in the drainage system? <br />There is a corrugated culvert under the access road east of the central <br />disturbed area which conveys water flow from the upstream holding <br />pond to the main drainage system. Is the culvert under the access road <br />sufficiently sized to carry all the ezpeMed flow? Flow wil! eventually <br />increase because the upstream holding ponds wil! be removed <br />A draft Reclamation Plan (Exhibit E) has been provided to the Division, as part of the <br />response to a Permit Disturbance Variance in July 1999. Exhibit E has been further <br />modified with respect to the reclamation seed mix. All these changes have been <br />incorporated into the attached replacement pages for the permit amendment. <br />Specifically, Page 11 of Exhibit E was changed as follows in response to Permit <br />Disturbance Vaziance in July 1999. <br />As outlined in the mining plan, backfilling and slope regrading will be part <br />of the clay stockpiling process after the initial individual stockpiles of soil and <br />overburden have been created. The total volume in the soil stockpiles will not <br />exceed 38;AAA 26,000 cubic yards; overburden piles will not exceed 30,000 cubic <br />yards. <br />As backfilling and slope grading are completed, recoiling will take place <br />using soils as they become available from the next mining area. This <br />accomplishes cone-move method for replacing both soil and overburden. <br />A total disturbed azea at any one time will not exceed 3A 85 acres. Of that <br />3A 85 acres, no more than 33 40 acres will need partial backfilling and recoiling; <br />any disturbed acreage on the remaining 43 45 acres will have been backfilled and <br />recoiled and in the final stages of reclamation. Of the 45 acres, 20 acres will <br />have been seeded, leaving 25 acres for seed and fertilizer. <br />Additionally, Page 16 of Exhibit E was changed as follows in response to Permit <br />Disturbance Variance in July 1999. <br />Reclamation Timetable. The reclamation phases are an ongoing part <br />of the clay stockpiling process. As mentioned earlier there will always be less <br />than 3A 85 acres of disturbed land. As mining is completed in Stage~3 the final. <br />