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Letter to Ryan J. McHale 4 September 8, 2010 <br />Second Adequacy Review File No. M-2009-076 <br />b. For revised Exhibit B, the description of vegetation and soil characteristics must be more detailed and <br />inaccuracies must be corrected. The percent cover for grass and woody stemmed communities must <br />be estimated. Exhibit B continues to state that there is zero to two inches of poor topsoil at the site. <br />This statement is not supported by the Natural Resource Conservation Service (MRCS) Soil Survey; has <br />Venture Resources conducted site specific investigations to support this description of the soil within <br />the area of affected land? If so, provide a report of the investigation and results. If not, the NRCS <br />survey soil description will prevail for the purposes of Exhibit B. <br />c. Venture Resources' Adequacy Review Comment letter, at item no. three, describes thirty percent of the <br />prrJpnged affected area as bPinor covered with historical mine waste rock damps. Also in item three, <br />Venture Resources commits to "do our best in salvaging any native mineral, Cathedral soil for <br />reclamation." It is the direct experience of DRMS that soil salvaged from under waste dumps can be <br />used effectively for reclamation. However, these soils must be stockpiled separately from other <br />salvaged soil and must be tested for pH and nutrients, and found suitable for reclamation prior to being <br />put to that use. Provide a commitment to salvage the soil from the historic waste dump areas in <br />accordance with these criteria. DRMS notes that this requirement is consistent with the <br />recommendations NRCS provided to Venture Resources. Also, provide a clarification that the soil <br />salvage effort will include collection of all A, AB, and Bw horizon soil; blending of the different <br />horizons during salvage and stockpiling is acceptable. This requirement differs from the NRCS <br />recommendation, but given the need to include organic amendment (straw/biosolids), DRMS has <br />determined that this is the best approach for reclamation soil building for Hukill Gulch. <br />d. Venture Resources states that abandoned mine waste rock and/or ore may be imported for processing <br />from other locations. Recognizing that this is not likely to occur under a limited approval Venture <br />Resources might be seeking at this time, DRMS concurs that rigorous waste stream geochemical <br />characterization prior to importation is not universally necessary, nor is a permit modification, <br />considering the lined tailing impoundment to be installed. DRMS will require notice, similar to the <br />notice required under Rule 3.1.5(9), prior to importation of any mill feed from outside the area of <br />affected land. The notice must include a general description of the material to be imported, location <br />information and DRMS permit number for the source of the material, the volume of material to be <br />imported, the approximate dates importation will commence and end, however, such dates shall not <br />be an enforceable condition. If the DRMS does not respond to the notice within thirty days, the <br />Operator may proceed with importation in conformance with all other terms and conditions of the <br />permit and any applicable federal, state, or local laws and regulations. If DRMS were to approve mill <br />tailing as impoundment fill, geotechnical characterization of imported mill feed may be required. <br />e. It will be necessary to install a fence or other exclusion measures to prevent wildlife damage to the <br />liner. Describe the measures to be employed and include, as necessary, estimated costs to remove <br />fencing, etc. at the time of reclamation. <br />f. DRMS will require a cost to install geogrid onto the tailing bench be incorporated into the estimated <br />reclamation costs for establishing the amount of required bond. Geogrid is likely to be needed to <br />support reclamation soil and the equipment used to distribute the soil.