|
Staff Notes for Adequacy 5, CN -01 12
<br />May Day Idaho Mine Complex, M- 1981 -185
<br />As discussed during the June 29, 2011 meeting, the expanded boundary of affected
<br />lands must include all 9.9 acres of the existing permit. Additionally, all affected lands of
<br />the existing permit must be addressed by the reclamation plan and financial warranty
<br />proposed under CN -01.
<br />Figure D -1 of Attachment D -2 and Figure F -1 show portions of the existing mine bench
<br />and highwall located outside of the new boundary of affected lands. Figure F -1, May
<br />Day 1 Reclamation Topography, clarifies the portions of affected lands, which are
<br />located outside of the new boundary and will not be reclaimed under CN -01.
<br />4. Inconsistent Boundary of Affected Lands
<br />Pursuant to Rules 6.2.1(2), 6.4.3, 6.4.4, and 6.4.6, the application must provide accurate
<br />maps which identify and outline the affected lands of the proposed operation. As
<br />explained below, there were numerous and substantial contradictions in the application
<br />regarding the boundary of affected lands.
<br />a. On page 4 of Exhibit A, Legal Description, the application indicates a 50 foot wide
<br />corridor of affected lands for all access roads. The boundary of affected lands shown
<br />on Figures C -1, C -2, C -3, C -4, C -5, C -6, C -7, D -5, G -1, 1 -1, U -1 and SWMP -1
<br />consistently delineate the same 50 foot wide road corridor for all access roads and
<br />are in agreement with Exhibit A. All of the maps which agree with Exhibit A and
<br />listed in this paragraph were stamped and signed by a Certified Professional
<br />Geologist.
<br />b. On Figures D -1, D -2, D -1 of Attachment D -2, D -1 of Attachment D -3, D -1 of
<br />Attachment D -4, F -1, F -2, F -3, F -4, and F -5A, the corridor of affected lands for the
<br />access roads are consistently delineated at approximately 100 feet wide. All of the
<br />maps listed in this paragraph were in conflict with Exhibit A and contradicted the
<br />maps listed above in paragraph 4.a. Figures F -1, F -2, F -3, F -4 and F5 -A were
<br />stamped, signed and dated by a Colorado Registered Professional Engineer.
<br />c. Attachment D -1 of Exhibit D included approximately 26 engineer drawings prepared
<br />by CLC Associates. According to CLC drawings C4.11, C4.12, C4.13, C4.14, C4.21,
<br />C4.22, C4.23, and C7.00, the corridor of affected lands for the roads is variable and
<br />ranges from approximately 44 feet to 1,800 feet wide. The engineer drawings
<br />appeared to be in conflict with Exhibit A and the other maps of the application which
<br />delineate a different boundary of affected land for the same road segments. All of
<br />the engineer drawings from CLC Associates were stamped, signed and dated by
<br />Colorado Registered Professional Engineer.
<br />
|