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<br />M-97-071 <br />Page 5 <br /> <br />may be available through the NRCS range site descriptions of the azea. <br />(2) The relationship of types of vegetation to the existing topography must also be shown on <br />the map contained in Exhibit C. Once again, this information should be available from <br />the NRCS. <br />6.4.11 EXHIBIT K-Climate <br />No Comment. <br />6.4.12 EXHIBIT L- Reclamation Costs <br />There are several details about the proposed mining and reclamation plans which will need to be <br />clarified before the Division can conduct a thorough review of the reclamation cost estimate. <br />Some of these items include: <br />(1) What will the fmal topography of the reclaimed area be, including bank and pit floor <br />gradients? <br />(2) How much overburden and topsoil will be replaced over the mined out area? 10,000 <br />cubic yards of topsoil is only enough soil to cover 92 acres approximately 1 inch deep. If <br />the entire area was top soiled with an average depth of six inches it would take <br />approximately 75,000 cubic yazds of soil. Please clarify the overburden and topsoil <br />salvage and handling procedures for this mining operation. <br />(3) Where will the topsoil and overburden stockpiles be located? This is very important to <br />determine exactly what the haul distances are for replacing these materials. <br />(3) How much area will be disturbed before reclamation begins? In other words, what will <br />the worst case disturbance be before any reclamation begins? The Division's <br />understanding is that mining and reclamation will occur in 12 acre blocks as depicted in <br />Exhibit C. However, many of the proposed reclamation costs are for the entire 92 acres. <br />A suggestion for clarification and cost containment would be to limit the operation to <br />disturbing no more than two l2 acre blocks at any given time. If the mine were operated <br />within this size limitation, the Division would only be required to hold bond for 24 acres <br />instead of 92, thereby significantly reducing the overall reclamation liability of the site. In <br />this scenario, the bond would "float" with the disturbed portions of the mine, and areas <br />that had been mined out and reclaimed would be released from any further reclamation <br />liability, providing that they had been adequately reclaimed. Please clarify how the <br />mining and reclamation plan will be implemented. <br />Once these areas are clarified, the Division will be able to verify your projected reclamation costs <br />