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Leanne Meuller January 29, 2003 Page 2 ➢ An evaluation of the long term fluctuation of groundwater elevations relative to the intended depth of mining must be evaluated to determine possible impacts to groundwater resources. ➢ The Geomatrix slope stability evaluation (dated March 28, 2002) determined the factor of safety for the reclaimed pit sideslopes. However, a "worst case scenario"should be considered in the study, which should include soil moisture conditions relative to surface streams, canals and irrigation practices. The factor of safety cited was apparently for non-saturated conditions and would be reduced under saturated conditions. As the report recommends, actual moisture conditions should be investigated and analyzed prior to finalizing the slope design. The factor of safety should meet the minimum specifications stated in the `Recommended Procedures for Implementation of DMG Special Publication 117 Guidelines for Analyzing and Mitigating Landslide Hazards in Califomia American Society of Civil Engineers and Southem California Earthquake Center' for the pit slopes under both static and seismic conditions. The report can be — viewed on line at: SCEC.org. OMR looks forward to reviewing the EIR and would stress the importance of — I incorporating specific mitigation measures identified in the document within the reclamation plan. The Surface Mining and Reclamation Act of 1975 (SMARA) (Public Resources Code Section 2710 et seq.) and the State Mining and Geology Board regulations for surface mining and reclamation practice (California Code of Regulations (CCR)Title 14, Chapter 8, Article 1, Section 3500 et seq.; Article 9, Section 3700 et i seq.) require that specific items be addressed or included in reclamation plans. Environmental assessments and mitigation measures adopted in the final EIR should be incorporated in the reclamation plan if they will be relied upon to satisfy SMARA j requirements. The reclamation plan must be a stand-alone document (SMARA 1 Section 2772(d) and all documentation for the plan must be submitted by the lead agency to the department at one time. Required information or documents that are i prepared as part of the permit application for the mine operation or as part of the i environmental document prepared for the project may be included by reference, if that item of information or document is attached to the reclamation plan when it Is submitted to the OMR for review. When submitting the reclamation plan to OMR for review,the Lead Agency is required to certify (in writing)to the Department of Conservation that the reclamation plan is in compliance with the applicable requirements of Article 1 (commencing with Section 3500)of Chapter 8 of Division 2 of Title 14 of the CCR per the requirement of SMARA