PERMFILE113419

• Permit No: C1981039
• IBM Index Class Name: Permit File
• Doc Name: MLRD 4/25/91
• Section_Exhibit Name: Reclamation Project Binder
• Media Type: D
• Archive: No

Mr. Brent Anderson
- 2 -

April 25, 1991
III.1. The landowner, Bogle Farms, requested retention of the pit access
roads in a letter forwarded to the Division on June 26, 1990. No
further action is required on this item. The Division understands
that Rockcastle would like to reclaim Pond 3, leave Ponds 2 and 5/6
as permanent impoundments, and delay consideration of Pond 4's
status until later. The sedimentology demonstration for the
removal of Pond 3 must be rerun per the Division's April 2~, 1991
adequacy letter. At this time the Division has not received the
permanent impoundment documentation as requested in our adequacy
letter of October 23, 1990 to allow the retention of Ponds 2 and
5/6. The Division would like to see the engineering documentation
for permanent impoundment status Rules (4.05.9 (1)(c) and (e)) for
Pond 4 to facilitate the future decision on retention or
reclamation.
IV .1. Rockcastle submitted reports on October 4, 1990 and February 6,
1991 to address the stability at Pits 5 and 6. The Division does
not accept the stability engineering package presented to date.
First, the Division needs to have a post-mining topography map of
these pits to use in evaluating the proposed solutions. Second,
all engineered structures must be designed to handle the 100-year,
24-hour event. Third, the Division's October 23, 1990 adequacy
letter did not accept the retention of the undisturbed drainage
• diversions. The Division continues to maintain this position as
indicated in the April 24, 1991 adequacy letter. Removal of these
diversions will increase the contributing watershed and result in
additional flow through and around the pit, which the February 6,
1991 design did not incorporate. In summary, the Division awaits
considerable additional information before releasing Rockcastle
from liability for completion of these engineering studies.
Furthermore, we are unable to release any more bond until the
engineering designs are accepted and a cost is assigned to their
completion, or the designs are implemented;
IV .2. Rockcastle prepared submittals dated October 4 and December 4, 1990
and completed road buttressing activities on Slide No. 3 in
November, 1990, according to the November 30, 1990 Bond Reduction
Request. The Division will evaluate the results of this job as
part of the next bond reduction inspection. The Division accepted ~
the engineering analyses found in the December 4, 1990 submittal.
Prior to construction, however, we do want to see a plan map
showing the area to be affected for the slide 1 and 4 remediation
as well as across-section of the proposed drains and a specific
description of the rock material to be used in their fabrication,
per our January 15, 1991 adequacy letter;
IV .3. and
IV .4. Rockcastle prepared submittals dated October 8, 1990 and
. February 6, 1991 to address these items. The Division has prepared
an adequacy letter, dated April 24, 1990, addressing our needs
related to the revegetation demonstration at Pit 3, NOV C-89-034,
the proposed drainage system and small area exemptions;