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2012-08-21_REVISION - M1980244 (32)
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2012-08-21_REVISION - M1980244 (32)
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Entry Properties
Last modified
8/24/2016 5:05:39 PM
Creation date
8/27/2012 11:12:49 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1980244
IBM Index Class Name
Revision
Doc Date
8/21/2012
Doc Name
APPLICATION RESPONSE TO ADEQUACY REVIEW
From
CC&V
To
DRMS
Type & Sequence
AM10
Email Name
TC1
Media Type
D
Archive
No
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RESPONSE. CC &V is committed to develop as part of the ISO -14001 certified Environmental Management <br />System at the Cresson Project by September 1, 2013 a Weed Control Plan. This plan will include a post- <br />treatment monitoringplan to determine control effectiveness. <br />e) A commitment the Weed Control Plan will be implemented for the life of the permit. <br />RESPONSE. : CC &V is committed to develop as part of the ISO -14001 certified Environmental <br />Management System at the Cresson Project by September 1, 2013 a Weed Control Plan. This plan will <br />include a statement that CC &V's commitment that the Weed Control Plan will be implemented for the life of <br />the project. <br />23. There is no mention in the Reclamation Plan of how the water treatment ponds at the terminus of the <br />Carlton Tunnel will be reclaimed. Please specify how the Operator intends to reclaim this area. <br />RESPONSE: Prior amendment applications reviewed and approved for the Cresson Project have not <br />planned in the Reclamation Plan to conduct reclamation activities at the water treatment ponds at the <br />terminus of the Carlton Tunnel, thus there is no discussion of that reclamation activities presented within this <br />application. CC &V is uncertain of the basis for the Division's question. CC &V has committed in the <br />financial warranty calculation offor the MLE2 Project for annual maintenance cost of $7,500 during the post <br />closure monitoring period for maintenance of the pond, ditches and miscellaneous site maintenance at the <br />site. CC &V is committed that when the water treatment ponds are no longer needed, water from the Carlton <br />Tunnel will be directed to Four Mile Creek and the ponds will be reshaped to serve as wildlife and livestock <br />watering holes and salvaged growth medium material currently stabilized at the site will be spread back over <br />the area at a minimum of 6" where needed and the area will be seeded utilizing reclamation practices <br />presented in the application. <br />24. Section 12.4.5 of the Reclamation Plan states the fill material which will be placed onto the haul roads <br />typically contains soil. Any haul road that will be revegetated should receive a cover of topsoil to ensure <br />the establishment of a diverse and long lasting vegetative cover. Please commit to replacing topsoil over the <br />haul roads in the same manner in which topsoil will be replaced over other disturbed areas. <br />RESPONSE: CC &V is committed to replacing growth medium material over the haul roads in the same <br />manner growth medium is placed over other disturbed areas. As addressed above in response to question 15, <br />CC &V will agree to the Division's request and commit to replace "topsoil" at a depth of no less than 6" <br />during reclamation activities at the Cresson Project. This commitment also relates to haul road. The cost of <br />growth medium replacement on reclaimed haul roads are included in the financial warranty calculation <br />presented in Appendix 13 of Volume VII of the permit application. <br />25. Section 12.3.3 of the Reclamation Plan states the fertilizer blend and application rates will be determined <br />from the results of soil analyses and observations of the specific reclamation areas. The Baseline Technical <br />Report from Arcadis indicates the suitability rating of the various Soil Map Units ranges from Good to <br />Poor. Please specify how the soil analyses will be conducted given that each stockpile will likely contain <br />soils that exhibit a range of Good to Poor suitability ratings. When will soil analyses occur? How many <br />samples will be collected for each of the stockpiles? How will the Operator ensure the collected sample is <br />representative of the soils in the stockpile? <br />RESPONSE: During the removal and stockpiling ofgrowth medium at CC &V, there is significant mixing of <br />the various soil units as specified in the Arcadis report, because "in -the - field" separation of soil units is not <br />practical, nor does it have a substantive effect on the quality of the reclamation. Past experience in <br />reclamation at the Cresson Project since the 1990's has demonstrated that even the soils labeled as `poor" <br />by the Arcadis report have potential to be successful growth medium. For example, rocky upland soils such <br />as those used as growth medium for the Altman backfrll reclamation project in 2010 -2011 would be <br />considered `poor" due to texture and low organic matter. This growth medium source was sampled as it was <br />delivered to the reclamation site. Materials were collected in plastic bags, sent to a local soil laboratory, and <br />key parameters such as pH, acid -base- accounting, nitrogen, potassium, phosphorus and organic matter were <br />run. Using these analyses, it was determined that minimal soil amendments were needed except for nitrogen <br />and organics. As a result, CC &V applied a Biosol amendment broadcast with the hydromulch at a rate of <br />
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