2013-03-13_REVISION - C1980004 - Laserfiche WebLink

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Mike Boulay -4- March 8, 2013 During the review process of Technical Revision No. 16, it was assumed that the office area was located in an alluvial valley floor, which requires upon reclamation restoration of essential hydrologic function to an alluvial valley floor (see DRMS letter to JE Stover & Associates, dated February 13, 2008, number 59 (e)). Part of that restoration would be replacement of topsoil depth equal to the depth that was salvaged. However, during the PR -02 process an AVF report was conducted by ERO Resources and a determination was made that an AVF does not exist in the proposed disturbed area. Therefore, the topsoil replacement depth at the office does not need to match the original depth of topsoil that would have been in place. It is unknown how much topsoil was salvaged in the office area, there is no documentation with that information provided. The topsoil replacement depths have been revised, an average of fourteen inches will be replaced. Please see revised page 2.05 -27. Fourteen inches should be adequate to establish the vegetative requirements of fish and wildlife and rangeland. On page 2.05 -48, section 2.05.4(2)(e)(vii) the soil testing plan is discussed. The soil will be tested upon reclamation to determine if nutrients are needed to encourage vegetative establishment. 88. DRMS: Please refer to Item 14 above regarding bedrock groundwater monitoring. MCM: Please see revised page 2.04 -20. Due to the inaccessibility and high overburden of the area northeast of the mine, down gradient bedrock monitoring wells will not be installed. It is highly unlikely the public will use the deep bedrock groundwater located north of the proposed mine plan area. It is simply too expensive to install a domestic or livestock well at such extreme depths. The poor water quality would also discourage public use. 89. DRMS: There is still no proposed plan for laboratory analyses for the currently monitored alluvial wells listed on page 2.05 -61. Table 3 Groundwater Parameter list was added (page 2.05- 64) but on page 2.05 -61 there is no mention of the frequency for obtaining samples for laboratory analysis. Please update the discussion on page 2.05 -61 to include the frequency for obtaining laboratory analyses for the alluvial wells. MCM: Please see revised page 2.05 -61. A full suite sample from the alluvial monitoring wells will be taken annually in the Spring. 105. DRMS: The Division has not received a revised Figure 4.2 -3 with the original PR- 2 application or with the adequacy response submittal dated October 16, 2012. Please clarify this response. MCM: Please see Figure 4.2 -3, it was inadvertently left out of the October 16, 2012 submittal.