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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 3 <br />We are aware of no permitting requirement for as-built contours in the midst of active <br />mining. Annual reports, for example, typically cover extent of disturbance but not <br />contour detail. This is an onerous demand to generate information that will be obsolete <br />within a short time after its production. Spot elevations and slope information are <br />provided on the enclosed supplementary plan map, sufficient to verify the suitability of <br />the new proposed plant location. <br />Adequacy Comment 2 <br />The proposed relocation of the concrete plant may change current site conditions and the ability <br />to reclaim the high wall to the proposed 2.5H:1 V that is required in the reclamation plan. Please <br />provide facility dimensions and what equipment and methods will be used to remove the <br />proposed facility. Provide a reclamation plan map that shows final reclaimed slopes with <br />contours and elevations. Please address all necessary components listed in Rule 6.4.5 when <br />revising the reclamation plan. <br />The operator noted in its November 30, 2007, TR request, as well as other <br />correspondence since that time, that no substantial effect on the approved reclamation <br />plan is expected or intended. At the Division's prompting, the present review process <br />has explicitly required that the operator affirm that the concrete plant will not be a factor, <br />not present on the site, at the time of final reclamation. For these reasons, and as <br />discussed in more detail below, the operator believes the Division's Adequacy Comment <br />2 addresses permitting concerns other than Rule 6.4.5. <br />As mentioned above, a supplementary map of proposed mining conditions is included <br />for the Division's reference. This map shows facility dimensions, but it should be noted <br />that this is in no way intended to affect the approved reclamation plan. Since the <br />existing reclamation plan adequately defines a post-mining land use that does not <br />accommodate the concrete plant (as such exclusion was specifically required of the <br />operator), revision of the reclamation plan is not necessary by any criteria of which we <br />are aware. <br />The equipment and methods used to remove the concrete plant will not change with the <br />present TR request; those methods will be the same as with the existing location. In <br />general, the superstructure will be disassembled in pieces and trucked off the site for <br />either scrap or re-use on another property. Only concrete footings will remain on the <br />site. The footings and any other substructure will be recycled for backfill or buried in <br />place. In any event, no change in technique is requested or required by this TR. If the <br />Division believes a recalculation of the financial warranty is required to reflect the status <br />quo, we defer to the Division's authority under Rule 4.2.1 to initiate appropriate action. <br />At the same time, we note that the TR request can be treated and approved on its own <br />merits (for example, see the Blue Pit's Oct. 21, 1999 TR approval, noting that separate <br />action would be taken on the surety). <br />Please note that, whether the plant is located on a final grade or not, final elevations will <br />be as noted on the approved reclamation plan. Operators frequently move equipment <br />and plant facilities to temporary locations throughout the course of a mining operation. <br />The present Technical Revision request is unrelated to final reclamation contours. <br />Furthermore, the existing plant will be removed before the plant is erected again in its