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Based on the above information, the Division has the following questions and comments: <br />a. If the report text is correct, and topsoil was only removed from stockpile <br />N and was imported to stockpiles GG, II, and JJ, why did stockpiles GG <br />and II also show a loss? <br />b. If 83.2 acre feet of topsoil were replaced, and a minimum of 31 acre feet <br />were salvaged, there should be a net depletion of only 52.2 acre feet. <br />SCCs table shows a depletion of 62.3 acre feet. At best, there are 10.1 <br />acre feet of topsoil mrsstng, with no apparent explanation. It is likely that <br />value is higher, since more than .5 feet of topsotl was salvaged on at least <br />part of the 62 acres of new disturbance. Please explain this appazent loss <br />of soil. <br />c. Please provide an estimate of the percentage of topsoil replaced on Pit A <br />and B that was removed from stockpile N, and that which was live hauled <br />from new Pit A disturbance. <br />d. Please verify whether the 1992, 1993, and 1994 volumes for stockpile KK <br />are correct. <br />e. Page 1 of the report text states that the field notes and photographs <br />regarding soil recovery thickness are on file at the Flagstaff office. Please <br />provide a brief summary of those notes, so that the Division can determine <br />the approximate depth salvaged from specific areas. <br />2. Page 4 of the report text indicates there are 407.5 acres of disturbed area requiring <br />topsoil replacement at the mine site, and 96.6 acres on the tie-across haul road. Table <br />94.1 indicates there are 519.5 and 69.7 acre feet, respectively, of soil stockpiled for those <br />areas. Page 6 of the report indicates that these stockpiled volumes are adequate to meet <br />the required replacement depths. The Division is in agreement with that assumption for <br />the tie-across haul road, but disagrees on the mine area. Multiplying 407.5 acres by 1.3 <br />feet gives a requirement of 529.75 acre feet. SCC has stockpiled only 519.5 acre feet. <br />This shows a deficit of roughly 10 acre feet. This deficit may be even greater, in that the <br />calculation above does not tnclude losses due to rehandling and compaction. Considering <br />those factors, how does SCC propose to meet the required replacement depth? <br />3. Rule 2.04.13(1)(E) states that the report shall include the location, number of acres, and <br />date of planting for all previously revegetated areas. The information provided does not <br />specify the date of planting for any revege~ated areas, so the location and number of <br />acres for each year cannot be determined. Please revise the report and Exhibit 94.2 so <br />that the required information is included. <br />4. Exhibit 94.2 shows all areas, to date, which have been seeded. By overlaying the map on <br />the same ma from the 1993 report, we were able identify areas that were seeded prior <br />to 1994. Dig~izing the remaining seeded area shows that approximately 49.25 acres were <br />seeded in 1994. The text of the report indicates 43 acres were permanently seeded. <br />Please explain this apparent discrepancy. <br />5. In totalling the topsoil available for the mine area reclamation, SCC includes soil <br />stockpiled at Pond 009 (I{IC) and along Road G (PP, QQ, RR, SS). The currently <br />approved reclamation plan does not specifically address redistribution of those stockpiles, <br />Michael Altavilla 2 April 19, 1995 <br />