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Tina Wehrmiester December 11, 2000 Page 2 overburden and soil as (briefly) described, however, we encourage that the 20-acre increments be formalized as reclamation phases 2. SMARA Section 2772(c)(5) that the map should include an initial stockpile location for use while the first 20-acre phase is excavated. Geotechnical Requirements (Refer to CCR Sections 3502(b)(3), (b)(4), 3704 (a), (b), (d), (e), (f)) 3. The reclamation plan calls for extensive backfilling to occur at the site to provide for an agricultural end-use. We recommend that compaction requirements be detailed in the reclamation plan. Hydrology and Water Quality (Refer to SMARA Sections 2772(c)(8), 2773(a), CCR Sections 3502 (b)(6), 3503(a)(2), (a)(3), (b)(1), (b)(2), (d), (e), 3706(a),(b), (c),(d),(e),(f),(g), 3710 (a),(b),(c), 3712) 4. The Negative Declaration states that mining will not intercept ground water. The documentation to establish this conclusion should be referenced in, and appended to, the reclamation plan. 5. A site specific erosion control plan should be included in the reclamation plan in accordance with SMARA Section 2773(a). Drainage should be sized to control a minimum of a twenty year/one hour return interval storm event. 6. Although the Negative Declaration states that the 500 foot setback from the bank of the Mokomne River is sufficient to remove the site from the 500-year floodplain, no documentation of how this was determined is given. The study showing this to be the case should be referenced in and amended to the reclamation plan. A factor to be considered in the study of this type is that river tends to shift its course on the floodplain over time within an area termed a meander belt. In order to be long-lived, a setback should be established with its starting point outside the belt width so that the river can maintain the setback despite the tendency to meander. 7. To the extent that Financial Assurances must provide for the end use of the site, sufficient detail must be provided in the plan narrative and grading plan and cross sections so that costs can be stipulated for grading the site. Performance criteria for the erosion and sediment control methods should be cited in the plan in accordance with SMARA Section 2773(a).