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Fred Banta - 3 - March 4, 1987 <br />Permanent reclamation activities will occur in the Bear Creek, Hubbard <br />Creek and Elk Creek drainages. Serious deficiencies have been noted in <br />the reclamation plan for the respective areas. The major deficiencies <br />are listed below. <br />A. The facilities maps for all disturbed areas are not current and are <br />not acceptable for reclamation purposes. We need current maps of <br />the Elk Creek Yard Area, the Sewage Leach Field and a«~sroad~ <br />pumphouse, new water pipeline, and 200,000 gallon <br />water tank, the upper and lower Hubbard Creek facilities, the Bear <br />Creek fan and portal facilities, all degasification facilities, and <br />all roads within the mine permit boundary. <br />B. The culverts at the Elk, Bear and Hubbard Creek facilities will be <br />removed during reclamation. The permittee has not provided us with <br />designs for riprap placement along the channel sideslopes following <br />culvert removal. There are a total of 5 culverts totaling <br />approximately 1,000 feet in length. Of major concern is the 670' <br />culvert in the Elk Creek Yard Area. The operator has not provided <br />information on culvert removal, channel construction, and riprap <br />placement. <br />C. Sediment and drainage control plans during the reclamation <br />phase-they are practically non-existant. We have not yet received <br />adequate plans from the permittee. <br />D. Regrading plans should be based on design criteria that will allow <br />for long-term (greater than 10 years) stable slopes that will <br />support a cover of suitable plant growth medium. Soil will not <br />remain in place on a regraded slope that is at the angle of repose. <br />And, if the soil Slough's off, revegetation will fail and erosion <br />will occur at an accelerated rate. <br />The permittee should submit regrading plans for all areas which <br />allow for adequate revegetation success as well as long-term <br />stability. <br />E. An erosion control plan needs to be developed for the regraded <br />slopes. When bench outslopes and highwalls are reduced there may be <br />50~ slopes that are 300 feet long. Unless erosion controls such as <br />contour furrows, contour trenches, or small basins are implemented <br />there will undoubtedly be rill and gully problems. This is <br />particularly true for the Elk Creek Yard Area - a 26-acre site on a <br />south facing slope. <br />F. Post-Mining Topography Maps. These should be amended to ensure that <br />regraded slopes are consistent with surrounding areas, to the extent <br />possible, that the post-mining topography is stable and capable of <br />supporting a permanent vegetative cover. <br />G. Topsoil for Revegetation. Very little topsoil was salvaged during <br />construction of the Somerset Mine facilities. Please keep in mind <br />