2010-02-16_PERMIT FILE - M2009076

• Permit No: M2009076
• IBM Index Class Name: PERMIT FILE
• Doc Date: 2/16/2010
• Doc Name: Adequacy Review
• From: DRMS
• To: Venture Resources, Inc.
• Email Name: ACS
• Media Type: D
• Archive: No

Letter to Ryan J. McHale 4 February 16, 2010
Permit Application Adequacy Review File No M-2009-076
and a cost for execution of the removal must be provided. It has been the direct experience of the DMRS
that trailers and other equipment, chemicals, including those in unopened packages, fuel, unused and waste
oil, antifreeze, etc. left at sites that are subject to bond forfeiture are worthless and are frequently creating a
hazard or nuisance. Therefore, the cost analysis must be predicated on disposal at a permitted dump. A plan
and estimated costs for grading, placement of plant growth media, and revegetation for the mobile mill site
must also be provided.
d. Venture Resources states that any mill feed rock at the mobile mill site will be consumed in the mill prior to
the commencement of reclamation. It has been the direct experience of the DRMS that mines that go to
bond forfeiture are frequently subject to disorderly termination by the operators. Therefore, sufficient bond
must be posted assuming there will be mill feed in the crusher feed pile and bin, and in the crushed rock bin
(287 tons total), and that there will be concentrates (48 cy) stored on site at the time of forfeiture. A plan
and estimated costs for removal and proper disposal of these materials must be provided.
12. Exhibit D states that pre-existing mine waste rock piles that are not disturbed during the course of Venture
Resources operations will not be subject to reclamation requirements. DRMS agrees with this position.
However, for partially excavated waste rock piles, if any were to remain at the termination of operations, the
excavated area must be reclaimed. A plan for this reclamation must be provided with an estimate for the cost
to execute the plan. The plan and costs must be predicated on an enforceable limitation to the area of the waste
rock piles that will be under excavation at any time during the course of operations.
13. Exhibit D states that a 1:5 ratio, by volume of class A biosolids and wood chips will be applied as a plant
growth medium to the tailing impoundment. This volume of wood is unacceptable in plant growth medium
because it will consume and tie up the plant available nitrogen, and because it is likely that wood or some
similar bulking agent will have already been incorporated into the biosolids during composting. As discussed
previously, the NRCS soil survey for this location indicates that there is salvageable soil available. The DRMS
will require that the soil be salvaged from the disturbed areas; it is acceptable to salvage and combine all soil
horizons. The salvaged soil can then be spread and top dressed with class A biosolids to create a superior plant
growth medium. The amount of biosolids amendment to be used should be based on soil testing to target three
percent organic content in the amended soil. For cost estimation and bonding purposes, biosolids at forty tons
per acre is appropriate. Provide a plan for soil salvage and stockpiling, and a plan and estimated costs for
amending the stockpiled soil with biosolids and placement into the areas to be reclaimed. DRMS will require
that the unit cost for biosolids at $50 per ton delivered be input to the estimate.
14. The DRMS accepts the phased approach to bonding described in Exhibit D. Considerable additional
information, as described in this letter, is needed before the DRMS can prepare an independent cost estimate
for this project. Two issues to be addressed relative to the Venture Resources estimate are the cost of reseeding
previously reclaimed areas where vegetation has not sufficiently established, and the cost for weed control
measures that are likely to be necessary. For cost estimation and bonding purposes, assuming that fifty percent
of the previously reclaimed area will require reseeding is appropriate, and a weed control cost at $200.00 per
acre over the entire affected acreage is required.
15. Exhibit F states that no well permits are required; Venture Resources must contact the Office of the State
Engineer to ascertain if permits are required for the monitoring wells. Exhibit F states that no effluent
discharge permit is required; Venture Resources must contact the Water Quality Control Division (WQCD) to
ascertain if a storm water permit is required. Exhibit F does not list a Department of the Army Permit for work