2012-10-18_REVISION - C1980004 - Laserfiche WebLink

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Mike Boulay -38- October 16, 2012 110. There appears to be a discrepancy in the 2008 and 2009 metals data presented in Table N -8 on page 12 of Appendix N. The values listed do not appear to coincide with the data presented in the 2008 and 2009 Annual Hydrology Reports. Please clarify this and provide an explanation of how the "Average" values listed in Table N -8 were calculated. MCM: No longer applicable, please see approved Appendix N. Rule 2.05.6(6) Subsidence Survey, Monitoring, and Control Plan 111. Subsidence has the potential, especially in areas of thin overburden, steep slopes, and cliff outcrops to cause damage to cultural resources, including rock art, rock shelters, and pictographs. From review of the project location map in Appendix J of the revision application, it is not clear that areas planned to be subsided were included in the cultural resources survey. Please identify cliff faces and areas of potential rock art within the area to be subsided (affected area), show them on a map, and submit the appropriate resource surveys for those areas so that the Division can forward this information to the SHPO. MCM: Please see Cultural Resource survey conducted for the BLM EA of the lease modification area included as Appendix J. 112. Please expand the brief text discussion on page 2.05 -71 under Rule 2.05.6(6)(b)(i)(B) regarding the magnitude of vertical subsidence as it relates to the depth of overburden. Reference to a map for those areas of high risk of surface cracking would be helpful. MCM: Please see revised page 2.05 -70, and new pages 2.05- 73 -75. 113. The Division believes that in areas of shallow overburden ( <500 feet) and steep slopes, the potential exists for surface cracks to develop that may be a hazard to recreational use and grazing. Please consider a plan for periodic monitoring and mitigation (if warranted), for these areas. MCM Rule 2.06(6)(a)(i) states that if no renewable resource lands exist, no further information need be provided in the application. The area of the mine plan in question (shown on Figure 2.1 -1 as projected to be mined in 2015 or 2016 +) does not contain renewable resource lands. Renewable resource lands are defined as aquifers and areas for the recharge of aquifers, areas for agricultural or silvicultural production of food and fiber, and pasturelands. The area in question is classified as undeveloped rangeland; rangeland is not considered a renewable resource land. Therefore, no monitoring plan will be included.