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Response to Feb. 6, 2008 DRMS Adequacy Comments <br />Blue Pit, M-1981-207, TR-06 <br />11 February 2008 <br />Page 2 <br />conversations, the operator understands the Division's desire for detailed technical <br />documentation about the operation in general, but we hesitate to engage in a much- <br />expanded scope of review given the limitations of the TR request. The operator has <br />stated that it would be willing to engage in a larger examination of issues at the Blue Pit <br />site, but we urge that such a process would be more appropriate and comprehensive if <br />initiated outside the current TR request. <br />Adequacy Comment 1 <br />Please provide a revised mining plan and a mining plan map that describe and detail the <br />proposed changes to the site and the planned progression of the mining to take place. Please <br />define where the overburden and topsoil stockpiles will be located. The mine plan map must <br />detail he current contour lines and elevations present at the site. Please address all necessary <br />components listed in Rule 6.4.4 when revising the mine plan. <br />With regard to the Division's Adequacy Comment 1 in the February 6 letter, a detailed <br />topographic survey of conditions at the site will involve significant time and substantial <br />expense, further delaying the review process and providing information that is not <br />specifically relevant to technical regulation of the TR request. Notably, the narrative <br />information required by Rule 6.4.4 does not cover plant equipment; the identification of <br />plant equipment as an adjunct to operations is typically given on the Division's <br />application form and on the mining plan map insofar as necessary to perform bond <br />calculations. The operator provided a plan map with the November 30, 2008, request, <br />and a supplementary map detailing plant equipment and location is provided with this <br />letter (see further discussion below). <br />While Rule 6.4.4 does cover the progression of sequenced mining, it is unclear what <br />additional detail is required in reference to the Division's comment. The original mining <br />plan showed a sequence of mining progressing from the southern pit (Mine Area 1) to <br />the northern pit (Mine Area 2) and finishing with the central area (Mine Area 3), with the <br />plant site moved once mining progresses to the central area. The operator's mining <br />sequence request is a logical outgrowth of moving the plant before Mining Area 2 is <br />excavated. The November 30, 2007, submittal of TR-06 noted that the central area <br />would be next in the mining sequence, simply changing the sequence from 1 > 2 > 3 to 1 <br />> 3 > 2. Thus, the TR adjusts the original sequencing plan, but the TR submittal and <br />existing sources of information. should be adequate to comply with Rule 6.4.4(e)(iii). In <br />any case, nothing about the proposed plant relocation would prevent the operator from <br />adhering to the original sequence, though the operator is improving efficiency and <br />reducing reclamation liability by proposing to eliminate two-pit sequencing. <br />Rule 6.4.4 does not specify any standards for the presentation of stockpile information. <br />Again, stockpile information is typically shown on the mine plan map to the extent <br />necessary for bond calculation purposes. In the present case, the TR request does not <br />generate the need for any new information. Topsoil is stockpiled on the site in <br />essentially the same manner shown on the 1999 Technical Revision. Overburden is not <br />stockpiled but rather is immediately incorporated into backfill, ultimately with the <br />objective of building out reclamation slopes. Neither of these practices is implicated in <br />any way by the request to relocate the concrete plant.