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Exhibit D - Reclamation Plan (Rule 6.3.4) <br />The same types of slope stability issues discussed above pertain here. Slopes are not adequately discussed in this exhibit, <br />though they should be. Please provide more information, in the context of dump material placement, grading, drainage, <br />and setback from the creek and other drainageways. In particular, please describe how current and expected future waste <br />rock dump configuration must be changed so that the approved reclamation gradient of 3:1 maximum slope may be <br />attained. <br />Various aspects of the reclamation plan already exist in the permit file, and to which this amendment application makes <br />reference rather than reiterates them herein. It is assumed that the references are mainly those summarized in the details <br />included in the Division's October 1997 bond recalculation. If this is in error, please advise. Otherwise, those details <br />will continue to be included in the reclamation plan. <br />The plan proposes to leave surface structures on the site permanently. This may be a reasonable detail, toward a post- <br />mining land use of "general agriculture," which can include buildings on a site. The office, cabin, storage sheds, and ore <br />storage pad appear to be consistent with this future use. If the underground portals are to remain (i.e., not backfilled), <br />they must have adequate safeguarding against unauthorized entry. Lockable steel doors may afford the minimum but <br />sufficient closure, though if the operator has another proposed method, please communicate it to this office. <br />The roofed exterior milling area and the concrete pad/floor are clearly acceptable as permanent structures. However, the <br />milling equipment, both exterior and underground, are not so clearly consistent with this post-mining land use. <br />Especially when one considers potential contamination from the pulverized and concentrated mineralization of the tails <br />and slimes that may remain in the circuit. Please provide better justification for leaving the milling equipment at the site. <br />The operator does not propose a hydraulic bulkhead to stop the discharging drainage from the lower portal, and it is <br />anticipated that discharge will continue untreated in perpetuity. Currently discharge is routed through the cells and then <br />through a discharge pipe to its outfall. Stormwater and snowmelt also report currently to the pond (or should), and carry <br />sediment. Reclamation will not eliminate runon, runoff, or other surface drainage occurrences. As such, please provide <br />justification for removal of the sediment pond(s) during reclamation, or for the lack of any stormwater or sediment <br />controls. <br />If the underground disposal of the tailings or sub-grade ore is approved, various measures should be considered as <br />methods to monitor and correct conditions. For example, after it has been emplaced in the repository and allowed to <br />decant sufficiently, the bulkhead and lined pool should be completely emptied. This should be followed by a period of <br />monitoring to determine whether the crosscut is truly dry, and/or whether the sub-ore must be neutralized or amended for <br />long term placement. This office will comment more about the proposed underground tailings disposal. <br />Exhibit E - Mining and Reclamation Plan Map (Rule 6.3.5) <br />Please review Rule 6.3.5 and 6.2.1 for the map requirements. Every map must include the date prepared and the <br />signature of the qualified person preparing the map. None of the maps submitted (C.2, C.3, and E.1) include them and <br />must be resubmitted. It may be better to separate the mining features from the reclamation features, and submit at least <br />two maps instead of one. <br />The mining map shows a 20 ft x 60 ft feature, labeled as the proposed surface milling area. A nearby feature appears to <br />depict the large door to the underground milling area. But there is a 12 ft x 12 ft feature between those structures that is <br />not labeled, and it is unclear what it is, since it was presumed that the 20-foot wide surface structure was to be connected <br />directly to the cliff face above the large door. Please clarify. <br />Since the waste rock areas and the onsite and cross-site drainage patterns have changed since the (3/18/08) drafting of the