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Ms. Paige Seville -3- December 17, 1984 <br />• <br />this road for access unless all design criteria under Rule 4.03.2 are <br />demonstrated. At present this road is a light use road which must be used <br />infrequently and restricting heavy equipment or.haul vehicles. <br />3. The west access road proposed will apparently cross an ephemeral steam <br />channel and then travel downgrade parallel with the channel. Two concerns <br />were noted with this proposed location. A culvert (with supporting designs) <br />rt ~ needs to be provided at all stream crossings. In addition, the Division <br />intends to restrict WECC from constructing the access road down the channel <br />unless need and reclamation feasibility can be demonstrated. We would <br />recommend the access road be relocated parallel but outside of the actual <br />channel. During use and after the road has been reclaimed the channel will be <br />very suseptable to erosion. The increase in runoff along with the possibility <br />of excessive erosion could affect the channel both upstream and downstream <br />from the proposed disturbance. The application should describe the stream <br />channel to be disturbed and propose a plan to protect the draw during and <br />after the life of the road. <br />4. The reclamation plan and map needs to address the backfilling and <br />grading of the access road to approximate original contour. At present, the <br />plan only calls for ripping and seeding the road. ~^} ~,a~r.~.~ <br />~~ 5. Road drainage designs need to be provided that meet the requirements of <br />Rule 4.03.2(4). Ditch design, ditch relief points, and culvert spacing <br />meeting these rules was not provided. A map and narrative along with <br />supporting .c alculations need to be provided as it was for the other access <br />roads at the mine. <br />HYDROLOGY <br />~6n` page 56 the application presents a proposeed list of parameters for <br />which water quality will be analyzed. The application states that the <br />~~ parameters are based on toxicity tests presently being conducted on the <br />waste. WECC should submit the results of the toxicity tests, justify the <br />I~ deletion of parameters as listed on our hydrology/geochemistry guidelines, and <br />~~ indicate how future waste will be monitored to verify consistent geochemistry. <br />2. To monitor ground water WECC proposes to sample well B-29 and SOM13. <br />,,,L~ These wells are located in the southwest part of the pile that may not be <br />1~ affected until later phases many years from now. The monitoring plan needs to <br />provide for a different or new well to be installed so that ground water <br />impacts can be identified early. <br />3. A water quality sampling program needs to be devised to determine the <br />leachate quality from the pile. WECC should include an underdrain design that <br />allows for periodic collection and analysis of leachate discharge from the <br />subdrains. Sampling frequency, parameters, and location sites should be <br />included in the application. <br />BONDING/RECLAMATION <br />D~ Bond needs to be revised to reflect regrading and topsoiling of the <br />w access road(s), reclaiming applicable hydrologic structures, and <br />redistributing four feet of cover. <br />