2010-08-27_REVISION - M1996052 ‎(3)‎

• Permit No: M1996052
• IBM Index Class Name: REVISION
• Doc Date: 8/27/2010
• Doc Name: Adequacy Response #2
• From: Environment, Inc.
• To: DRMS
• Type & Sequence: AM1
• Email Name: ECS
• Media Type: D
• Archive: No

ENVIRONMENT, INC. - - PAGE4
ADEQUACY RESPONSE #Z.. - - -
L.G. EVERIST, INC. - FIRESTONE GRAVEL RESOURCE
AUGUST 25, 201 O
affect property owned by L.G. Everist, Inc., since surrounding
properties are higher then the top of the liner. If needed, a
surface groundwater collection ditch can be constructed along
the south side of the site to intercept and regulate the
mounding. The bottom of the ditch will be placed at the
maximum historic groundwater elevation we have observed during,
monitoring. Water collecting in this ditch will be directed
into the seep ditch outlet on the east side of the mined area
and allowed to return to the river.
Are there any downstream users of the "Seep Ditch" that have filed for water rights that would be impacted by
its removal on-site? Will removal of the "Seep Ditch" on-site impact irrigation return flows?
There are no records of water rights listed in SEO's records
for the "Seep Ditch". The seep ditch flows from the L.G.
Everist mine site to an adjacent mine site, and then
disappears. The adjacent mine site does not need extra water
crossing their land, and as said above, the property owners
never filed for water rights on the seep ditch. Since.
irrigation on this site will end as mining progresses there
will be no irrigation runoff from the land so the ditch is not
needed. If needed, a replacement ditch can be constructed
along the southern perimeter of the liner in Stage 5 over to
where the ditch has historically crossed under WCR 17.
Exhibit L - Reclamation Costs (Rule 6.4.12)
The revised reclamation estimate provided is much better than most, and the Division will accept the proposed
method of dewatering cost calculation/estimate. The changes proposed to the reclamation plan (clay liners,
primary/secondary scenarios) may require some modifications to the estimate breakdown to facilitate a phased
approach. The statements in the submitted adequacy letter that "resumption of mining is delayed for the next
couple of years" and "We do not believe it is necessary to post a large just before we come out of temporary
cessation" also will require some clarification, By Rule, bond to cover reclamation of the existing disturbance
(including the existing scale house, stockpile removal, draining and resloping/lining of existing excavation,
exposed surface water, revegetation, weed control, etc.) should be in place now -regardless of the site's temporary
cessation status. This site has an existing posted bond of $49,450 and is currently under-bonded. In addition, the
bond revision due to the expansion of activities in this amendment will be due within 365 days from the date the
Division approves the amendment unless the bond is phased appropriately and stated as an enforceable condition
in the amendment application.
To address these issues, the Division requires at a minimum (and as a suggested first phase of a phased
approach), adjusting the existing bond as appropriate to reclaim the existing disturbances. The second phase of
this approach could be to post adequate bond to cover the first phase of renewed mining activities as outlined in
this amendment immediately prior to bringing the site out of temporary cessation.
Let's calculate the bond for the first two phases as the
Division suggests, so that L.G. Everist can take the site out
of temporary cessation sooner, rather than later. L.G.
Everist will post the calculated increase in bond prior to
bringing the site out of Temporary Cessation. Later, as
mining progresses into new areas, we can submit a,Technical
Revision to adjust the bond accordingly. Attached is a bond,