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r~ F1r. John T. Ungefug - 4 - March 11, 1986 ~2. Does the evidence of an NPDES permit for this site mean that the mining dewatering discharge is covered by the permit? 3. Enclosed please find a copy of the review letter for this application from the Division of Water Resources. I have also received your letter to that Division of t4arch 6, 1986 requesting assistance in this matter. I suggest that you continue to attempt to resolve this matter with the Division of Water Resources. At this point, lack of such a resolution will not delay approval of your permit by our Board, given your continuing attempts to comply with Division of Water Resources concerns. Exhibit H - Wildlife Information 1. Given the end use of this site of wildlife habitat, I note that the Division of Wildlife shares my concern for an undisturbed setback from the Arkansas River. Once again, I suggest that you commit to such a 100' undisturbed setback. Exhibit L -Reclamation Costs 1. The costs you have given for the activities mentioned seem reasonable. However, you have omitted several reclamation activities that are major cost items. a. Minor grading, ripping prior to topsoil placement, etc. - Even if the major grading is included as part of the mining of the site, these costs of ground preparation prior to topsoil replacement must be included for the maximum disturbed acreage. b. Topsoil replacement costs - The maximum disturbed acreage in the pit area will require 6" of topsoil replacement (807 cu. yd./acre), and the five acres of plant area will require 4" of topsoil replacement (538 cu. yd./acre). Typical costs for topsoil replacement (using costs for typical earthmoving equipment given in, for example, the Cat Handbook) are $.80 to $1.00 per cubic yard replaced. Topsoil replacement costs should be calculated on a per cubic yard basis. I suggest you revise your reclamation costs and add these items in for the appropriate acreage (i. e., all 5 plant site acres and perhaps one half of the pit acreage). These items will raise your total required financial warranty significantly. You may wish to more closely stage your operation to reduce this potential amount. Please call me if I can clarify any parts of this letter. Sincerely, ~~~~~~~ P4ark S. Loye Senior Reclamation Specialist MSL/vj r Enclosure(s) A7n7 r.