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State of California THE RSUULL% A'Al—T u1 c_. UVURN14 Memorandum To Date Dr. Gordon F. Snow : July 9, 1990 Assistant Secretary for Resources Subsea: Draft Environmental Mr. Richard Larrouy Impact Report for San Joaquin County Planning Division the Claude C. Wood 1810 East Hazelton Avenue Quarry Project, Stockton, CA 95205 San Joaquin County, SCH# 90020113 From Department of Conservation--Office of the Director — The Mine Reclamation Program staff of the Department of Conservation' s Division of Mines and Geology has reviewed the Draft Environmental Impact Report (Draft EIR) for Claude C. Wood Company Quarry Project QX-90-1. Mine Reclamation Program files were also reviewed. The following comments, prepared by James Pompy, Gail Newton, and Lynn Jones, are offered to assist in your review of this project. The Surface Mining and Reclamation Act of 1975 (SMARA) and the State Mining and Geology Board regulations for surface mining and reclamation practice (California Code of Regulations (CCR) [formerly California Administrative Code (CAC) ] Title 14 , Chapter 8 , Article 1, Section 3500 et seq. ) (copies attached) I require that specific items be addressed or included in reclamation plans, and that the plan be submitted to and approved by the lead agency prior to the commencement of any new mining operations. The Draft EIR states that many of the items specific to reclamation are to be determined by future studies or surveys. It is not possible to adequately evaluate these items until the studies or surveys are completed and a reclamation plan specific to the site, as required by SMARA Section 2773 , is prepared. Items specific to mined-land reclamation that were not adequately addressed in the Draft EIR follow. 1. CCR Section 3503 (c) states that all reasonable measures shall be taken to protect the habitat of fish and wildlife. The site contains riparian and wetland habitat. The Draft EIR includes generalized measures to be considered but, as 2 stated above, many of the ultimate mitigations and revegetation methods will be based on the results of future studies and surveys; therefore, the measures cannot be assessed at this time. 2 . CCR Section 3503 (f) states that resoiling will be done using appropriate techniques. Resoiling is a focal issue for reclamation of prime agricultural lands. The Draft EIR states that the depth of excavation for removal of surface 3 soils will be determined at a later date, but that surface soils should be separated from subsoils and stockpiled separately. This general statement does not allow a review of the proposed methodology.