Geneva Rock Mining Permit

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    Notice of IntentiontoGeneva Rock Products,Point of the Mountain QuarryM/O35/O26

    Gommence Large Mining Operations

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    lnc,Operation

    Submitted by.

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    Notice of lntentiontoGommence Large Mining OperationsGeneva Rock Products, Inc,Point of the Mountain Quarry OperationM/O3s/O26

    Submitted by.Geneva Rock Products, Inc.1565 West 400 North

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    Notice of Intention to Commence Large Mining OperationsGeneva Rock Products, Inc.Point of the Mountain Quarry OperatioilPPROVEDTable of Contents l,fAR 2,$ 2mg

    Introduction/Project Background ,rrr,,r,r,.,rrri'r,,..,r.,......::l:l:.:i.:.:.:TT::tl. R647-4-104 Owngr/Operator Informatiolr........r.r.rr..rr.!r!.................3ll, R647-4-{05 Maps, Drawings, and Photographs...,...,,..!rrr!!.r..........5lll. R647-4-{ OG Operation Plan r.r.iiirrr...r.rrrr..rr...!r.r..!!rrrrrr.rrrrr.rrrrr........6106.1 Type of Mineral to be Mined ......6106.2 Type of Operations to be Conducted ......... ................6106.3 Estimated Acreage .................. 11106.4 Nature of the Materials to be Mined and Production Rates......................12106.5 Existing Soil Types, Location of Plant Growth Material... ......... 13106.6 Plan for Protecting and Re-Depositing Existing Soils ....... .......14106.7 Existing Vegetative Cover Communities to Establish RevegetationSuccess ................... 15106.8 Depth to Groundwater, Extent of Overburden Material and GeologicSetting..... .................17106.9 Proposed Location and Size of Ore & Waste Stockpiles, Tailings,and Discharges ........ 18lV. R647-4-/lOZ Operation Practics..,,......rr.r..rr.rr....rr..,,!r,..,.,...........'l 8V. R647-4-{08 Hole Plugging Requirements,rrrrrr'rrr.i..rrr.rrrr.rr.........2OVI. R647-4-{09

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    Table 1.Table 2.Table 3.Table 4.Table 5.Table 6.

    Figure 1Figure 2Figure 3Figure 3AFigure 4Figure 5Figure 6Figure 7

    Appendix AAppendix BAppendix CAppendix DAppendix E

    List of TablesSoil Types within the GRP POM Phase 1 Area ..............14Reclamation Seed Mix.......... ......... 15Wells in and near GRP Property ....17Runoff Volume Estimate From a 100-year, 6-hour Storm Event ....22Threatened, Endangered, and Candidate Species that May Occur within theProject Area of Influence ...............24Potential to Emit (PTE) Emissions at POM Quarry..... ...................27

    List of FiguresLocation MapPermit Area and Phase 1 MapSurface Facilities MapSurface Flow MapWell Locations MapTypical Highwall Cross SectionPhase I Mining & Reclamation MapCross Sections

    AppendicesSurety CalculationsCorrespondenceConcrete Wash Tank Sampling ResultsVegetation Cover DataPond Sift Sieve Analysis Results

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    I ntrod uction/Project BackgroundGeneva Rock Products (GRP) owns and controls approximately 872 acres of privateland, partially within and south of Draper, Utah (15547 South 300 West) in southwesternSalt Lake County and northwestern Utah County, Utah (Figure 1). The 872 acres ofGRP property occurs on both sides of l-15, near the Point of the Mountain. The area onthe east side of l-15 is known as the Point of the Mountain (POM) Quarry. The GRPproperty on the west side of l-15 is utilized for sand and gravel extraction, and forstorage of fines from those operations, as well as from the POM operations.The Permit Area covered under this Notice of Intent includes a total of 486.5 acres: 67acres on the west side of l-15 and 419.5 acres in the POM Quarry. Within the POMQuarry (and part of the 419.5 POM Quarry acres) are 16 acres that are considered tobe a Mixed Use Area, utilized by mining and construction operations. For this reason,the 16-acre Mixed Use Area is excluded from the Phase 1 bond for reclamation.Although the entire Permit Area covers 486.5 acres, only the Phase 1 portion of thePermit Area, 288 acres, is currently designed for active mining and reclamation. Anyfurther phases of mining and reclamation, once designed, would occur under additionalfuture submittals to the Utah Division of Oil, Gas and Mining for review and approval.The 288-acre Phase 1 area is outlined in Figure 2, and includes disturbance associatedwithdevelopmentof a115.5-acrepitfloor, 107-acre highwall,4l acresforstorageoffines, and 24.5 acres made up of buffer, the northern point including topsoil storageareas, and a couple areas above the highwall on the southeast side of Phase 1. (SeeFigure 3).GRP was organized in 1954 when it began supplying concrete for projects along the

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    The highwall in the northeastern portion of the property, outside the permit areaboundary, was established prior to regulation by the Division. This area will not bedisturbed under this Notice, and will not be reclaimed further.An interim reclamation cost estimate was calculated for a 2005 delineation ofdisturbance in the active mining area (see Section 9.0), and the interim reclamationbond was submitted to the Division. As part of this 2006 Notice, the surety estimate hasbeen updated; calculations are included in Appendix A.The land surface within this area of the Traverse Mountains contains a complex, rapidlychanging mix of cuts imposed upon the naturally dissected terrain. Exposures ofBonneville and pre-Bonneville sediments, underlying deeply weathered Tertiary volcanicrocks, and late Paleozoic quartzite and limestone bedrock of the Oquirrh Group (Beik2003) are common. The area has been mined for more than 75 years. Extractedmaterial is currently shipped to customers in Utah, Summit, Tooele, Carbon, and SaltLake Counties, Utah.

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    Notice of Intention to Gommence Large Mining OperationsGeneva Rock Products, lnc.Point of the Mountain Quarry Operation

    This Notice of Intention (NOl) is submitted to the Utah Division of Oil, Gas and Mining incompliance with part R647-4-103 of the Utah Minerals Reclamation Program.

    l. R6,47-4-1O4 Owner/Operatorlnformation1. Mine Name: GRP - Point of the Mountain (POM) Quarry2. Name of Permittee/ Operator/ Applicant: Geneva Rock Products, Inc., aCorporation registered to do business in the State of Utah.Business License #: Draper City ON-2003-0348Registered Agent: Tony Christofferson

    Address:Phone:E-mail address:PO Box 538 Orem. Utah 84059801-281-7800 Fax: 801-281-7830

    3. Permanent Address: P.O. Box 538 (Corporate Office),Phone: Orem, UT 84059801-281-7800 Fax: 80'l-281-7830

    4. Gompany Representative: Carl C. Clyde, Vice President, Gravel & AsphaltMaterials DivisionAddress:Phone:

    tch ristoffe rson @clyde i n c. com

    15547 South 300 West, Draper, UT801-281-7950 Fax:801-281-7970

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    9. Adjacent Land Owners:Sandy and Salt Lake Gity Metropolitan Water Treatment Facility (to thenortheast)Metropolitan Water District of Salt Lake & Sandy3430 East Danish RoadSandy, Utah 84093Saft Lake Gounty Flight Park (two 4}-acre parcels north)Salt Lake County Parks & Recreation Administration

    2001 South State Street, Suite 5440Salt Lake City, Utah 84190-2300Draper Gity (to the northeast)1020 East Pioneer RoadDraper, Utah 84020Fox Ridge lnvestments, LLC (to the southeast)

    2825 East Cottonwood Parkway # 400Salt Lake City, Utah 84121Staker Paving & Gonstruction Gompany (to the south)P.O. Box 27598Salt Lake City, Utah 84127-0598Materials Packaging, Inc. (to the southwest)15567 So. Minuteman DriveDraper, Utah 84020Interstate-15 (to the west)

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    ff. R647-4-105 Maps, Drawings, and PhotographsThe maps included in this document are those required under R647-4-105 and show:USGS 7 5 minute topography; property boundafies; access routes; existing andpfoposed impact areas and surface facilities; feclamation treatmentst cross sections ofthe cufrent topography, post mining/ reclamation, and a typical hlghwall cross section

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    lll. R647-4-{OO Operation Plan106.1 Type of Mineral to be MinedThe material to be mined is highly fractured quartzite and limestone (termed "ledgerock"by the mine operator) in addition to the alluvial sand and gravel deposits that havehistorically, and are currently being extracted from the site. All of the proposed miningwill take place in bedrock. Rock products from the operations would be used inconstruction of transportation infrastructure, and heavy industrial, commercial, andresidential construction. Final products produced from the POM pit and on-siteproduction facilities include sand and gravel, concrete, and asphalt.106.2 Type of Operations to be ConductedExisting disturbance at the POM Quarry covers approximately 190 acres, includingcurrent facilities (including approximately 16 acres designated as the 'mixed use' area),roads, and the pit. The POM Quarry will be enlarged to recover additional reserves.These reserves will include the bedrock types previously described. This NOI coversextraction associated with Phase 1 of what is expected to be a multi-phase extractionproject within the defined permit area, over the next 75 years. The ongoingdevelopment of the POM Quarry would depend upon economic conditions anddemands for aggregate and asphalt materials in the surrounding communities.Mining of bedrock will be conducted by ripping, drilling, blasting, and excavation/hauling.The drill size, blast holes, and frequency of blasting vary depending upon the situation.Blasting takes place on a variable schedule at the POM Quarry; blasting could occur 2or 3 days in a row and then not for several weeks. Mining benches will typically be 25feet wide, generated in 40-foot high lifts, and layed back approximately 15 feet to an

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    stackers. There are currently a total of 82 conveyors and 38 additional pieces ofequipment located within active pits at the POM Quarry. Electricity is used topower the stationary equipment with some power supplied by Utah Power & Light(Pacificorp) and some supplied by Geneva Rock operated diesel poweredgenerators. The majority of the electricity used at this location comes from UtahPower & Light. Fuel storage for the loader and dozers is supplied by 12,000gallon dieseltanks next to each crusher; these tanks are completely portable andinclude containment capacity of 110 percent of the tank. (See photos below).

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    Electrical Power Supply and Natural GasTwo rows of 138 transmission lines occur at the southern boundary of the property,adjacent to the Staker concrete operations located directly south of the POM Quarry.An underground 2o-inch high pressure natural gas line is located in the same alignmentas the transmission lines.In addition, GRP has diesel, gasoline, and LPG fueled generator sets. Thesegenerators are portable to accommodate lighting plants, pumps, and compressors.Water Supply and WastewatorWater for dust suppression, toilets, and showers is supplied from GRP'S process anddrinking water systems. The drinking water and septic systems described below arelocated within the mixed use area inside of the permit area boundary, and will continueto be utilized at the end of active mining in the POM quarry.GRP operates a drinking water system to supply culinary water to its employees. Thesystem is regulated by the Utah Division of Drinking Water and is classed as a non-transient, non-community system. Water is not treated. lts DVVW system number is18154. Well Number 11 provides water to the culinary system. Well Number Isupplies process water only, but there is no cross connection between the wells. WellNumber 10 can also provide process water. One well, a dry well shown on Figure 3 isproposed for closure and plugging. A new well has been permitted nearby; it will bedrilled approximately 1200 feet deep, with the same components as the old well. Thisnew well will be used for process water. Other wells located avnear the POM pit areshown on Figure 4.The POM Quarry maintains two septic tank systems. One system is located under theconstruction ofiice building, and one is located at the main office building (Figure 3).The latter also handles wastewater from the batch plant building that is transported viasealed HDPE pipes. Each septic system consists of a septic tank and a drain field.

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    Total Permit AreaThe total Permii Area covers 486.5 acres Phase 1 covers 288 acres Al of themalerias recoverable from within the property boundaries on the east side of 115(PON,4) are considered to be saleable The current reclamation fines pond on the west

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    depth of 9 inches. Salvaged topsoil will be stored in the proposed topsoil storage areasshown on Figure 3.Topsoil will be salvaged as much as possible from the areas to be mined; it will bestored in designated areas, and seeded to control erosion. The proposed reclamationgrowth material will be salvaged topsoil stored onsite. Other materials would be addedas needed (based upon the results of sampling), but are not included in the reclamationcost at this time. Based upon a topsoil salvage area of 59 acres, approximately71,390 cubic yards of topsoil will be stored for reclamation. lf all of this is utilized on thepit floor, then coverage of about 4 inches of topsoil would be provided for the 11S.S-acrepit floor and the S-acre topsoil storage area (northern point of property).Any topsoil previously stored above the highwall has been utilized in interim reclamationefforts. The area proposed for topsoil storage on the southwest point of the propertywould remain outside the proposed area to be mined. The topsoils stored on the pitfloor (northern point of the property) would be used in pit floor reclamation.

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    Phase I

    Wasatch LoamyCoarse Sand, 1-10% SlooesVerydeep Excessivelydrained Rapid Low Upland Sand(lndianRiceqrass)Wasatch Loamy

    Coarse Sand 10-25% slooesVerydeep

    Excessivelydrained

    Rapid Low Upland Sand(lndianRiceqrass)Bingham GravellyLoam 1-3o/o Verydeep Well-drained Moderate Low UplandGravelly

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    This onsite vegetation cover data will be included in Appendix D. Topsoil stockpiles willbe bermed to control erosion.Table 2. Reclamation Seed MixSpeciesbluebunch wheatgrasspurple three awnIndian ricegrasssand dropseedcrested wheatgrass

    big sagebrushpalmer penstemonblue flax

    PLS lbs./acre632.51

    .523Total 18

    The safety berm above the highwall would be constructed from adjacent materials, suchthat a trench/berm system is created. The layer of topsoil material on the surface in thearea of the proposed trench/berm system would be gathered to a depth ofapproximately 6 inches at the time the berm is constructed. This soil would be storedtemporarily in a windrow adjacent to the berm, then distributed over the surface of thesafety berm prior to seeding.Any topsoil previously stored in piles above the highwall has been used in concurrentreclamation. No topsoils would be stored above the highwall in the future. Soils wouldnot be applied to the inactive highwall benches because the highwall benches areexpected to fill in with spall within 2 to 3 seasons. The benches would be aerial-seededthe first fall after completion of mining in Phase 1, as a one-time measure to assist withthe establishment of plants that would then begin to hold organic matter on thebenches, and provide sparse vegetation cover on the highwall benches over time.

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    106.8 Depth to Groundwater, Extent of Overburden Material and Geologic SettingDepth to GroundwaterBased upon information obtained from the State Engineers water rights records (Table3), depth to groundwater at the POM pit is estimated at approximately 350 feet. ltgenerally is found at shallower depths to the west, approaching the Jordan River.

    Y\ ell lli,D,,,',,,,,,,(see fiquie 4l WatCi,,,',l..,Riqht No. Depth WAi,i..,Leue:ll,lt eCil,,,,,,,:,::,:,t',:t',1 a23026 GRP 840 1472 a23026 GRP 260 unknown3 a23026 GRP 310 unknown6 a23026 GRP 210 unknownI 57-8029 GRP 242 unknown9 57-7879 GRP 250 drv10 57-7879 GRP 650 33611 a23026 GRP 1200 unknownB1 57-7869 BarES &Barlow 197 10082 57-8344 BarES &Barlow 105 56c1 57-8343 Crump 7 unknownD1 57-7922 Dixon 121 27*D2 57-7922 Dixon 185 unknownJ1 57-3098 Mt Jordan 348 unknownM1 57-8363 Monroc 920 320-350M2 57-7760 Monroc 1900 320-350

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    sedimentary rock originating as a fresh water lacustrine deposit, and belonging to theTertiary Salt Lake Group (Geneva Rock Products, lnc.2002). Outcropping to the east,are members of the Oquirrh Group, which is of Pennyslvanian/Permian age. This rockis primari[ quartzite, with some layers of limestone. Bedrock in the area is highlyfaulted, fractured, and shattered, according to Geneva Rock Products, lnc. (2002), citingPitcher (1957) as their source.The Jordan River is located approximately 2 miles to the west of the POM pit at anelevation of approximately 4425 feet. The final elevation of Phase 1 is expected to bethe same as the current pit floor elevation, 4865 feet.106.9 Proposed Location and Size of Ore & Waste Stockpiles, Tailings, andDischargesThere is no waste rock associated with the POM operations. Material from the POM pitwill be sized, or crushed and screened on site as it is extracted.Two sediment ponds exist at the POM Quarry. One small pond is located near thewash plant in the southwest corner of the project area. The other is located on the westside of l-15. lt is the terminal catch basin for storm water and process-related water.tv. R647-4-1O7 Operation PracticesAs required, the relevant Operation Practices stipulated inR647-4-107 will be followed.They are described below:Public SafeW and Welfare

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    The highwall areas themselves can also generate runoff, which would report to thegently sloping pit floor. Runoff from the pit floor and the facilities area eventually drainswestward across the highway and is impounded in a small pond near the facilities area,or the large reclamation fines ponds operated by GRP. There is no storm waterdischarge leaving the property, thus there is no storm water permit for the site. Asnoted above, however, Geneva has implemented a Storm Water Management Plan forthe Point of the Mountain site. This plan is provided in Appendix G.There are no known springs within the property boundary, or up-gradient of it. Thereare two water rights (Nos. 57-3393 and 57-al 0120) to a single spring located west, anddown-gradient, of GRP's POM Quarry operations in the northwest corner of Section 13(Utah Division of Water Rights 2005). This water is impounded and is used for irrigationand domestic uses. There are no other surface water rights in, or within one-half mileof, the property.Surface Water QualityThere are no live water sources within the project area, so there is no knowninformation on surface water quality.GroundwaterThe groundwater system of the Salt Lake Valley can be divided into three generaloccurrences: 1) a confined artesian aquifer (principal), 2) a deep unconfined aquiferwhich lies between the confined aquifer and the mountains, and 3) a shallow unconfined

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    Special Status SpeciesFederally listed species that the U.S. Fishdetermined may have the potential to occur inaction are included in Table 5 (USFWS 2005).Appendix B.

    and Wildlife Service (USFWS) hasthe area of influence of the proposedUSFWS correspondence is included in

    ' Historical range'Critical habitat designated in Salt Lake and Utah Counties3 Wintering populations (only eight known nesting pairs in Utah).As summarized from UCDC (2005), clay phacelia grows on barren, precipitoushillsides in sparse pinyon-juniper and mountain brush communities. Deseret milkvetchgrows in an open pinyon-juniper-sagebrush community at a single location locatedoutside of the area of influence. Ute ladies'-tresses is found in moist to very wetmeadows, along streams, in abandoned stream meanders, and near springs, seeps,and lake shores. The Utah valvata snail occurred historically in Utah Lake, but is now

    Table 5. Threatened. Endanqered. and Candidate Species that Mav Occur within the

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    The Gofumbia spotted frog (Rana luteiventris) prefers isolated springs and seeps thathave a permanent water source, although individuals are known to move overland inspring and summer after breeding. In Utah, isolated Columbia spotted frog populationsexist in the West Desert and along the Wasatch Front (UCDC 2005). The WasatchFront population occurs in isolated springs or riparian wetlands in Juab, Sanpete,Summit, Utah, and Wasatch counties.f n Utah, the burrowing owl (Athene cunicularia) is uncommon during summer even inits preferred habitats, throughout the state. lts habitats are open, flat grasslands andprairies, but it also utilizes other open situations, such as golf courses, cemeteries, andairports. Burrowing owls typically nest in a mammal burrow (UCDC 2005) and thusrequire soils conducive to burrowing. The GRP slopes are steep, and the weedyvegetation is generally too tall to allow burrowing owls any sight distance. For thesereasons, burrowing owls are not expected to inhabit the GRP property.ln Utah, the only known breeding colonies of the American white pelican (Pelecanuserythrorhynchos) are located in the northern portions of the state, specifically within theUtah Lake/Great Salt Lake ecological complex. Preferred nesting habitats are islands,especially those associated with fresh water lakes. Preferred foraging areas areshallow lakes, marshlands, and rivers (UCDC 2005).No threatened, endangered, or sensitive (TES) species have been recorded on or nearthe operations area and due to the overall lack of vegetation and surface water onsite,TES species are not likely to occur in the area of influence.f n addition to TES species, the Bonneville cufthroat trout (Oncorhynchus clarki utah)occurs in the Bonneville Basin of Utah and is managed under a ConservationAgreemenU Strategy (USFWS 2005). No aquatic habitat exists within the area ofinfluence.109.3 Existing Soil and Plant Resources

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    primarily cheat grass and other species including toadflax, six weeks fescue, bulbousbluegrass, gumweed, moth mullein, snakeweed, purple three-awn, sand dropseed, andgoldenweed. Cover from perennial species was estimated at 10-15 percent.On the northern slopes \A/yoming big sagebrush is common, in addition to most of theabove listed species.109.4 Slope Stability, Erosion Gontrol, Air Quality, Public Health & SafetySlope StabilitvPit slopes have been exposed for many years in the POM pit. Continued mineexpansion will result in overall mine slopes of 1:1. The highwalls are planned in 4O-foothigh intervals, with 25-foot wide benches. The highwall benches would be left as is, andhave been shown to be stable at the proposed 1:1 slopes. However, due to thefreezelthaw cycles, small particles of the highly fractured materials are expected tobreak off over time, and fill in the benches with spall. The final slope angle would beapproximately 45 degrees.Runoff and Erosion GontrolThe unnamed ephemeral watercourse up-gradient of the pit does not currentlydischarge over the highwall face because the drainage has been blocked. As miningprogresses the drainage will be intercepted and may occasionally contribute flows overthe highwall. However, observations are that only minor runoff is produced from thiswatershed, and the contributing watershed area will be reduced in size as miningprogresses up gradient. During reclamation, the safety berm/trench along the top of thehighwall would retain flows from the upper watershed areas.During operations and continuing under reclaimed conditions, significant amounts ofstorm water runoff would not be expected to infiltrate into the highwall (due to steepslopes and exposed bedrock). Instead, storm water would primarily run off and reach

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    The table below is taken from Newmont Gold's blasting vibration webpage for theWaihi Gold Mine in New Zealand (Newmont Gold 2006). lt shows that a slidingdoor typically produces about 0.4 inches of vibration per second, which is abouttwice as much as was generated at the two houses monitored during the blast.Geneva believes this data indicates that vibration and associated noise are withinacceptable limits.

    jumping up to 9.8 lheel drop up to 5.9nail hammering up to 3.9

    up to 1.6up to r.ig

    sliding door up to 0.4 r

    However, to assure this is the case, Geneva commits maintaining standardblasting records of each blast, including the pounds of explosives used per 8millisecond delay. if further complaints are registered, the next scheduled blastwill be monitored. lf vibrations on a monitored blast exceed 0.35 inches persecond, the number of holes, blasting patterns, delays used, and the weight ofexplosives used will be reviewed and adjusted as necessary to minimize thedetrimental effects of blasting on our neighbors.3. Trash, scrap metal, wood, buildings, and any extraneous debris attributed to theactive mining would be removed and properly disposed of within one year ofcessation of operations.

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    VII. R647-4-11O Reclamation Plan110.1 Current Land Use and Post Mining Land UseThe operations area has been used historically for mining and exploration. The easternextent of the property provides limited habitat for wildlife. The property boundary isfenced on the northeast and southeast sides, with a 4-foot field fence with 2 top strandsof barbed wire.A hang gliding park managed by Salt Lake County exists immediately adjacent toGRP's POM pit boundary in the EastTz and NE % of Section 13 (T4S R1W (see Figure3). GRP's POM property can be accessed through this park through a locked gate atthe southern half of Section 13 (T4S R1W.Residential developments are being constructed to the northeast and east of the GRPPOM property. The majority of current operations are shielded from residential areas bycurrent topography. The nearest residences are within 700 feet of the GRP propertyline.The Phase 1 area contains no original protective cover, other than on the approximately59 relatively undisturbed acres. Phase 1 mining would be expected to continue intofurther phases at GRP's POM property. However, under the current scenario, the areamay be reclaimed at the end of Phase 1 if mining does not continue into the next phase.The described reclamation and surety are based upon the scenario that GRP miningends at the end of Phase 1.Post Mining Land UseThe proposed post-mining land use would be as open space and wildlife habitat. lt ispossible that the property would be sold and developed for commercial or transportationUSES.

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    characteristics as called for by Federal and state solid waste disposal statues and rules.Any remaining concrete in the vicinity of the processing facilities would be broken up,buried on site, and covered with 3-5 feet of fill (obtained from the waste rock used infoundation preparation for the concentrator building) prior to topsoil application. Theseareas would be graded to blend with adjacent surroundings prior to topsoil application.The rock highwalls would be left as is; overall slopes would be 1:1 as shown in Figure 5.The bench surfaces would be expected to fill in with spall over 2 to 3 seasons such thatthey begin to look more like a long slope. Any topsoil remaining in storage piles abovethe highwall would be pushed over the edge, to accumulate in places on the benches,or hauled to the pit floor. lt would not be prudent for GRP to apply any of the otherremaining topsoil resource to the benches, since it will be needed for reclamation of thepit floor, and would be impractical to haul upslope and distribute to the benches, whichare expected to fill in with spall over 2 to 3 seasons. The reclamation seed mix wouldbe aerially applied one time to the benches. Due to the active spalling of thesebenches, no reclamation standard would be applied, as the benches would not beconsidered safe or reasonable to measure to a reclamation standard.There will be no waste rock dumps.The paved road between the dry mix concrete plant and the asphalt plant would remainin use for those operations. Other road spurs into the pit would be fully regraded, deep-ripped, and reclaimed.The south side of the Phase 1 area would remain open to active mining by Staker.The 4-foot high earthen safety berm would be repaired if necessary to ensure that sideslopes are 2H:1Y and this berm would be signed with DANGERM/ARNING-type signsevery 150 feet along the perimeter of the pit to further discourage access. This bermwould tie into the existing field fence on the northeast side of Phase 1. The berm would

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    110.5 Revegetation Planting Program and Topsoil RedistributionSoil Material ReplacementTopsoil will be placed on all newly disturbed and regraded surfaces of the pit floor aspart of the concurrent reclamation process at the POM Quarry, if they are no longerneeded for support of operations. Once placed, the regraded surfaces will be ripped toa depth of at least 2 feet to provide a roughened surface to retain seed and to enableroot penetration. Equipment used for this task is likely to be a dozer, and/or scraper.Topsoil stored on the northern point of the Phase 1 area will be applied to the pit floorareas.Seed Bed PreparationThe topsoil is expected to provide a reasonable growth medium for the site. On the pitfloor, the surface will be roughened by deep ripping, to create small depressions to forwater retention sites, and habitat niches. No topsoil would be applied to the reclamationfines areas prior to seeding.Seed MixtureA single seed mix is proposed for all reclaimed surfaces. The seed mixture is basedupon DOGM recommendations as included in the August 9, 2006 inspection report(bluebunch wheatgrass, purple three awn, sand dropseed, crested wheatgrass, bigsage, Palmer penstemon, and blue flax) as well as on reconnaissance of nearby areas.Should seed availability change prior to reclamation, some variation in the mix couldoccur, with agency approval. The suggested representative pre-mining vegetation wassampled in April 2007 and cover/species results are being submitted to the Division.Seedinq MethodThe seed mix would be broadcast seeded on the pit floor and fines area, and aeriallyseeded over the benches. Revegetation work, including both seedbed preparation andseed application will take place in the late fall season and seed would be spread as

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    t lX. R647-4-113 SuretySurety calculation tables and supporting information (DOGM rate sheet) are included inAppendix A. Surety is calculated for completion of operations at the end of Phase 1(288 acres). The Phase 1 pit floor, for purposes of reclamation, includes 115.5 acres ofactual pit floor, and 5 acres utilized for topsoil storage on the northern point of theproperty, so the total pit floor is shown as 120.5 acres below. Bonds will be calculatedand approved before disturbance into the remaining areas. Line items listed belowcorrespond to bond cost estimate spreadsheet provided in Appendix A.General site cleanup and removal of trash and debris. (line item 9.5) $106,768The facilities area would be cleaned up; trash & debris would be removed. Theestimate includes clean up of 50 out of 120.5 acres. $ 3,750The 82 conveyors and 38 additional pieces of equipment would be removed via 75

    The final Phase 1 pit floor would be regraded. Maximum 120.5 acres, assumes noconcurrent reclamation.Revegetation. (line items 9.7-9.8-9.9) $399,248After grading, topsoil would be applied to a depth of approximately 3 to 4 inches on thepit floor (120.5 acres). No topsoil would be applied to the reclamation fines area..There would be no waste rock. The reclamation fines material would sampled; a

    loads with a 'low boy', and 10 days of crane work.The generators would be removed.The 1200 foot asphalt road would be removed.Backfilling, grading and contouring. (line item 9.2)

    $74,385

    $ 4,800$23,833$ 8,074

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    Topsoil would be removed from the berm footprint and replaced after construction toprovide for reclamation. (line item 9.4) $40,294Warning Signs (30) would be placed along the top of the safety berm at intervals ofapproximately 150 feet. (line item 9.1) $ 8,000Fencing would be installed for 4685 feet along the top of the highwall to tie in with theexisting fence. (line item 9.6) $ 1b,461Boulders would be placed on each bench, at the point where the unnamed drainagemeets the highwall, prior to retreating from each bench. (line item 9.1) $ 19,260Demolition, removal or burial of facilities/structures, well abandonment,regrading/ripping of facilities. $ODemolition of buildings and facilities and well abandonment are not calculated in thisbond estimate because these structures/facilities are essential infrastructure for GRP'soperations and are within the mixed use area of the permit area.Regrading/ ripping stockpiles, pads and other compacted areas.(regrading/ripping pit floors and other compacted areas is included in other sections)Ripping pit floors and access roads.The pit floors would be ripped as included under revegetation.Mulching, fertilizing and seeding the affected areas.Ripping to a depth of at least 2 feet, fertilizing (fines only), and seeding would occur onthe areas as noted above under revegetation.

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    Supervision during reclamation.10 percent of reclamation totalSubtotal (1)Contingency (10%)Subtotal (2)Escalation (for 5 yrs. @3.2% per yr.)

    $ 66,247

    $728,722$ 72,872$801,594$136,752

    TOTALRounded TOTAL

    $938,346$938,300

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    U.S. Fish and Wildlife Service (USFWS). 2005. Letter from Henry R. Maddox, UtahField Supervisor, Utah Field Office, West Valley City, Utah. Regarding POMQuarry Operation, Geneva Rock Expansion (FWS/R6/ES/UT/05-1317'). DatedOctober 3, 2005.

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    Figures

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    Mine Permit Number Mine Name ,4,.l J.1, ,t "-Operzlor 6.r.v^ 3-,a F,.!- -l-F Date Sen#Rcceivd ^rpl$.d( ?,-23-olIO o.rM FROM-kzoztz.--&

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    l._ ,u'

    ,u _*f* , u,

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    Mine Permit Number ttfot

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    Appendix ASurety Galculations

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    A BOND COST ESTIMATE FOR PHASE 1 ONLY

    Means(2007) 31 37 13.10-0370

    site cf eanup & trash removal Gstimate 50 out of 120.5 acres for

    Remove 24 Generators sets (assume 3 sets

    Removal & from berm/ditch area= 24' across, & aftet berm constructed)

    o

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    seeo 280 120.5 33740loosoil relocation t.oz 1 37940 zzJ+oJDOGM rates, broadcast seedinaReveoetation - Reclaim Fines

    Material $/ac tppl $/ac # acres30mp man. 175 41 7175rippinq 620 41 25420seed 284 41 1'1480

    DOGM rates, broadcast seedingReveqetation Monitorino & Weed ControlAssume one 'io per vear. 3 vears. 10 hours per triDabor $/hr :rucldhr l0urs75 30 3C 31 50Sample Reclamation Fines - qrowth potential/orqanicsLab $ abor $ iuoplies

    274 30c 6509,8 TOTAL 3797881

    9. Revegetation - Highwall Aerial SeedinqMaterial $/ac $/cu vd # acres cu voseed 280 64.r 1 8060

    )OGM |ates, broadcast seeding used for aerial seeding

    ].9 TOTAL 1 E06C9.1 Equip mob/demob ,.10 totAL 14U0t

    D10 dozer 200(992 Loader 200(track hoe 200(Cat16 orader 200(crane 200(631 scraper 200(277 haul truck 200(IOTAL 140009.11 RECLAMATION TOTAL 662471

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    Appendix BGorrespondence

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    Geneva Rock - Point of the Mountain - DOGM ResponsesJanuary 14, 2009 Page 2The table below is taken from Newmont Gold's blasting vibration webpage for the WaihiGold Mine in New Zealand. lt shows that a sliding door typically produces about 0.4inches of vibration per second, which is about twice as much as was generated at thetwo houses monitored during the blast.

    Household Activity Vibration Level in inches/second peak particle velocityJumping 9.8Heeldrop 5.9Nailhammering 3.9Walking 1.6Shutting door 1.2Slidins door 0.4

    4. Concurrent Reclamation.Geneva spent almost $500,000.00 on reclamation work in 2009. Work included tree plantingand construction of pre-formed concrete walls along the west side of the property to blockwind, reduce off-site dust, and improve aesthetics. Geneva has also paved all long-term roadareas within the quarry to limit fugitive dust, and an updated FDCP was submitted to theDAQ and approved in May, 2008 (see question 2 above). Geneva currently utilizes allaffected lands. There are no areas currently available for concurrent reclamation.5. Slope Stability.The quarry maintains 2:1 slopes in ledge rock. This meets DOGM rules at R5647-4-111.7.These slopes have been shown to be stable through the history of mining at Point of theMountain. The closest buildings to the quarry are more than 600 horizontal feet away fromthe closest point of Geneva's property; currently the distance from active mine areas tohouses in much further (see Maps 1 and 2). These distances provide adequate butfer fromthe highly unlikely occurrence of slope sloughing. In addition, Geneva inspects its highwallsand working faces for signs of weakness or stress on a daily basis to assure the safety of

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    . The property boundary is fenced wth T-post and 4 foot wke fence topped by2 strands of barbed whe.Erosion ControlErosion Control will be accomplished during operalions as delailed in Seclion Vl withthe goals of minimizing sorl loss fiom topsoil stookpiles, and minimizing offsite6edimenlalion.As discussed above in sectron 1064, delelefious or acid-forming male als are notexpected {o be encounlered during the mining and milling operations.GRP is considered a small generator of hazardous waste by the U.S EnvironmentalProteclion Agency and the Utah Division of Solid and Hazardous ste, and isoermitted as such.SollsAs previously described, any available suitable soil material will be salvaged fiom theremaining areas to be developed and made available for ongoing reclamation-

    Air QualitvA lJtah Division of Air QLrallty Approval Order was approved May 7, 2008 and isincluded in Appendix H This Approval Order requires thal ceneva follow BestAvailableCont.ol Technology (BACT) to minimize fugitive dusl emissions. To summarize theapproved BACT measures to be used:t Fugitlve Dustwillbe controlled bywet suppression methods:

    o water sprays will be used on all crushef inlet and outTet poinls, all dryscreens, and all conveyor kansfer and stacker drop points; with the use ofwatertrucks;

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    inches per second l\lonltors were set at the lasi house and the second to laslhouse on Steep l\rountain Drive, the latlea being the residence of a genllemanwho had contacted Geneva concerned about the level of vibrations Test lesultsfound vlbrations ranging from 0 15 to 0 23 inches per secondThe lab e below is taken from Newmont Gold's blasting vibration webpage for theWaihi Gold Mine in New Zealand (Newmont Gold 2006)- ll shows that a slidingdoor typlcally produces about 0 4 inches of vibration per second, which is abouttwice as much as was generated at the two houses monitored during the blast

    ceneva believes this data ind cates that vlbration and associated nolse are withinacceptable limits However, Geneva commits lo monitoring blasUng nolse andvibration in lhe future if further complaints are reglstered li vibrations on amonitored blast exceeds 0 35 inches per second the nomber of holes, blastingpatterns, delays used, and the weight of explosives used wil be reviewed andadjosted as necessary io min m ze ihe detrlmental effects ol blasting on oulneighbors

    Fmattd: Indenti Left; 0'

    vibEbion level (lnch6/@nd Fak padrcle vel.dty)

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    ReferencesBiek, Robert F 2003 Interim Geologic lvap of the Jordan Narrows Qladngle, Salt

    Lake and Ulah Counties, LJtah. 8-5-03 STATEMAP Agreement No.02HOAG005 Utah Geological Survey Open-File Repod 415. Utah GeologicalSurvey, lJtah Department of Natural Resources, in cooperation wjth U S.Geological SurveyBighorn Archaeologjcal Consullants, LLC 2005. Class lll Cultural Resource Inventoryof the Proposed Geneva Rock Gravel Pil Exlension, Salt Lake and ljtahCounties, lJtah State Projeci Autho zation Number U05-HO-1080pGeneva Rock Producis, Inc Octobe.2002 Drinking Water Source Protection Plan for

    Protection ofceneva Rock's No- 11 We,Natural Resource Conservatron Service (NRCS). 2002 Non Technical Soil Descnption(NASIS derived) of Soil Survey Area LiT612, Salt Lake Area, lJtah, as of3n/2002Nalural Resou.ce Conseruation Seruice (NRCS) '1999 Non Technical Soil Descriplion(NASIS denved) of Sorl Survey Area UT621, Utah County, Utah, Central Part asot 5t24t1999 .Nwmont Gold 2006 Waihi Gold: Vibration and Blast Vlbraton Responsehtip //w'vv'vv newrnonl com/en/operation s/au stral anrwaihigo ld/environ menUvibration/index aso Accessed Januarv 2009Pitcher, Grant G. 1957 The Geology of the Jordan Narrows Quadrangle, UlahlUnpublished Masters Thesis, Brigham Young Universityutah Administrative Code R647-4. Large Mining Operations. As in effect January 1,2003Utah Conservation Data Center (UCDC). 2005 Vedebrate Animals dalabase L,lahDepartment of Natural Resources, Division of Wldlife ResourceshltpJ/dwcdcnrutahgov/rsgis2/Search/Searchvertsasp Accessed Oclober

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    U.S. Fish and Wldlife Service (USFWS). 2005. Letter from Henry R. Maddox, UtahField Supervisor, Utah Field Ofice, Wesl Valley City, Utah. Regarding POMQuarry Operation, Geneva Rock Expansion (F!^JS/R6/ES/UT/05-'1317). Datdoctober 3,2005.

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    Genevo Point of the Mounfoin NOI MlO35lO25Public Comments & Drqtt Responses November I0, 2008 pqge I of 3

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    -

    Letter #l from Donold PetersonI , Proximity of sond ond grovel pit to residences on both sides of the mountoin.o The closest home in Solt Loke County is 0,5 miles from the Genevo pit ond wosbuilt in 2000.. The closest home in Utoh County is 0,5 miles from the Genevo pit ond wos builtin 2006 (meosurements token from Google Eorth),Genevo Sond ond Grovel hos been in operoiion ot this site since 1954, 46 yeors prior tothe older of the two noted'closesf homes, built in 2000, 0,5 miles from the octivemining oreo, City zoning in Bluffdole ond in Droper, support the sond ond groveloctivities, Genevo hos exchonged property with ihe Utoh Deportment ofTronsportotion, in order to mointoin occess to the flight porks, in support of the populorhong gliding octivity in this oreo, According to vorious plonning documents, theGenevo property odjoins open spoce, ogriculturol londs, public focilities, orcommerciol fociliiies within the Droper City boundory, the county flight porK the l-15conidor, Utoh County property, or Bluffdole city property,

    2. The effects of 'Iipping, drilling, blosting, ond excovotion houling,"The mining proctices'Iipping, drilling, blosting, ond excovotion houling" os outlined inthe Point of the Mountoin plon, ore the some proctices os hove been utilized for yeorsof the quorry, These ore typicol mining proctices, No new mining proctices oresuggested bythe plon,

    3, The vibrotion from 'Iipping, drilling, blosting, ond excovotion houling,"Genevo hos conducted monitoring of neorby homes during blosting octivities, Seismicmonitors were ploced of residences, with the result thot no ground vibrotion wos

    Genevq Poinl of the Mounfqin NOI MlO35lO26Public Commenls & Drqtt Responses November 10, 2008 poge 2 ot 3

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    o -of the Mountoin, in oddition to Genevo, Genevo hos committed in their 2008 UtohDivision of Air Quoliiy Approvol Order, Appendix A'Fugitive Dusl' control plon, to bestmonogement proctices to control dust, which moy include the following meosures:r Wotering of unpoved roods. poving. Prompt removolof debriso Restricting vehicle speeds in ond oround operotions oreoso Windbreoks. Reclomoiion of disturbed. unused oreos,

    Letler #2 John C, Norton5, Concerns over mining exponsion ond reclomoiion,

    Genevo proctices concunent reclomotion os it becomes feosible. Typicolly, once onoreo is opened up, however, mining proceeds bock ond the flot, open oreos oreutilized for equipment ond operotions until it is procticolto close ond recloim on oreo,Due to ihe depth ond loyout of the resource ot Point of the Mountoin, ii tokes o longtime to extroct the resources in on oreo while loying bock the hillside enough tooperote sofely, Genevo willconduct reclomotion occording to their opproved mineond reclomotion plon, which includes site cleon-up, ripping, topsoil, ond seeding ofcompocted oreos; qnd oeriol seeding of the pit wolls.

    Letter #3 South Mountoin Homeownels Associotion6. Concerns over mining exponsion,

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    SOUTH MOI.INTAIN HOMEOWNERS ASSOCIATION

    Dean October ZB,Z00\Division of Oil, Gas and Mining1594 W. North Temple, Suite 1210Box 145801Salt Lake City, UT 84114-5801On behalf of our homeowners, the South Mountain Homeowners Association wishes toexpress our concem over the issue of expansion of mining operation at the Point of theMountain Quarry.At least one, and potentially more than one residential development, ale built into themorintain on land that may be prone to landslides. There are also businesses on both sidesof the mountain that could be adversely impacted by various mining activities especiallyblasting.We are therefore requesting that Geneva Rock voluntarily undertake additional testing toprotect the large number of properfy holders who could be negatively affected.Sincerely yours,ni

    ,hh LV.t 4,_r-Joan M Little-BrockPresident

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    " 803 E. Rocky Mouth LaneDraper, UT84020October 18, 2008

    M.g: Dana: DeanDivision of Oil, Gas and Mining1594 W. North Temple, Suite 1.210Salt Lake City, UT 84114Dear ffi; Dean,We read the notice of plans to allow Gneva Rbck's expansion of'operations'at its point of the Mountainquarry with alarm. You note that "mining of bedrock will be conducted by ripping dritling blasting andexcavation hauling."May we point out the obvious. The location is in close proximity to a large number of homes on bothsides of the mountain. All of the above activities will greatly intrude on the lives of those living in thisimmediate area. Point of the Mountain is an area consistently swept by strong winds, and the clouds ofdust from the current operation are detrimental to the health of people throughout Draper, Sandy andbeyond. A substantial increase in Geneva RocKs operation with "ripping, drilling, blasting and excavationhauling" promises to further decrease air quality in the valley.we stand in strong opposition to increased noisq vibration and air pollution at the Point of theMountain site.Sincerely,

    rfi

    Linda MatthewsLinda Matthews

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    qFTSubject:

    Friday, September 12,200811:58 AMPaul BakerFW: FW:Geneva POM

    Hi Poul - | iust fclked to Tony. Yes, the fopsoil piles previously obove the highwoll were used {or interimreclomation.Lindo-----Originol Messcge-----From: Lindo MotihewsSent: Fridoy, Sepiember 12, 2AA8 9:04 AMTo: 'Pcul Bcker'Subieci: Rf: FW: Genevo POMPoul -My understonding is that they used this soil for interim reclonrotion thot they do from time to time. l'm checkingwith Tony on fhis, to con{irm.Thcnks.Lindo- ----Origino I Messo ge-----Itom : Poul Ba ker [moilto: poul boker@uioh. gov]Ueni' Thursdoy, Seplember 1 l, 2008 l:28 PMTo: Lindo MctthewsSubiect: Re: FW: Genevo POMI oppreciote the revised mop.

    To: Lindo MolthewsSubiect: Genevo POM

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    oLindc,Attoch ed is the revised mop you requested.

    Connie Pixton, DrofterJBR Envirorrmentol Consulionts, lnc.801-943-4144 x12Ocpixton@i brenv. com < mo i lto : cp ixton @i b renv. com >

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    Linda Matthewsrom:ent: Linda MatthewsTuesday, September 02,2008 10:48

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    o:Subject:

    Thanks Tom.Lindo-----Originol Messoge-----From : Tom t\Au nson [mcilto:fommunson @uta h. gov]Sent: Tuesdoy, Seplember 02, 2008 l0:40 AMTo: Lindo MqtthewsSubiect: Re: Genevo Point of the Mouniainlf Poul gives the o.K., I will osk for two complete copies ond the bond, eic.Tom MunsonB0r [email protected]

    >>>''LindoMotthews,'9/2/2aasg:40AM>>>

    AMTom MunsonRE: Geneva Point of the Mountain

    nototion in the species list loble hos been

    J Pour:Regording your commenis below ihat were sent by Tom Munson:.|06.6 We ore revising Figure 3 io reflect this comment;106.7 The plant wos identified os Lepidium densiflorum, however the

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    pit.The pond in the north end of the properfy is not reolly o pond but rqther o lower spol in the pii thot duringperiods or lorge precipitotion collects run-off. During most o{ the yeor it is dry or very smoll cnd is only lorger in/a" late winter cnd eorly spring during snowmeh runoff when evoporoiion is not ihot "strong". Some of the woter

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    Ufihrates into the substrote while ihe resi evoporotes.Jomey

    -----Originol Messoge-----From: Tom Munson [moilto:[email protected]]Sent: Morrdoy, July 21 , 2008 8:48 AMTo: Lindo MotlhewsSubieci: Re: FW: Genevo Point of the MountcinHi lindo, this is greoi, Thonks! li roises questions regording ihe sizing of the pond in the Norih end of theproperly. can you speck io ihis concern? Thcnks Tom> > > "Lindo Motlhews" 7 /21/2AAB 7:56 AM > > >HiTonr:Would you mind toking o quick look ot rhis pdf? lf this is whot you're looking for, l'll send over the print copy.Or pleose provide input.Thonks!Oo'From: Connie PixtonSent: Fridoy, July I B, 2008 3:23 PM

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    >>> "Lindo Motthews" A/6/2AA8 B:03 AM >>>Hi Tom:>rry, I do noi hove record of thot email from Poul. But I will look ot this todoy when I get into ihe office, affer o

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    eeiing this morning. I wos out of fhe office Thursdoy 7/J1 lhru yesterdoy.Thonks,Lindo-----Originol Messoge-----From : Tom Munson [moilto:[email protected]]Sent: Mondoy, August 04, 2008 5:07 PMTo: Lindo MotthewsSubiect: Re: FW: FW: Genevo Point of the MountoinPoul Boker hod these comments which he emoiled to you. Any luck on o response for Poul to review so we conmove forward.106.6 Plon for protecting & redepositing soilsThe text of the plcn soys topsoil thot wos being stored obove ihe highwoll hos been used for concurrentreclomation, ond solvoged soils will not be stored obove the highwoll in the future.Bosed on this chonge in the text, Figure 3 needs io be revised. lr still shows current ond fufure soil stockoilesbeing stored obove the highwoll. (PBB)106.7 Exisiing vegelotion - species and omountO- vegetotion soys "pepperweed," Lepidium densiflorum, is o noxious weed, ond ihis is not correct. This speciesEppeors to be o notive onnuql which would not be clossified os o weed. Could the report be referring to hoorycress, Cordorio drobo, or toll whitetop, Lepidium lotifolium? (pBB)>>>,'LindoMotthews''7/2B/2aasl:08PM>>>

    ptT.The pond in the norJh end of the property is noi reolly o pond but rqther o lower spoi in ihe pit thoi during-geriods or lorge precipiiotion collects run-off. During most of the yeor it is dry or very smoll ond is only lo-rger in-e late winter ond eorly spring during snowmeli runoff when evoporoiion is nof ihot i'strong". Some oi the woterinto the substrote ihe

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    -lnfiltrqtes while rest evoporotes.Jomey

    -----Originol Messoge-----From: Tom Munson [mcilto:[email protected]]Sent: Mondoy, July 21 , 2A08 8:48 AMTo: Lindo MotihewsSubieci: Re: FW: Genevo Point of ihe MounfoinHi lindo, this is greot, Thonksl lt rqises questions regording ihe sizing of the pond in the North end of theproperly. con you speuk to ihis concern? Thcnks Tom>>> "Lindo Motthews" 7/21/2aag 7:56 AM >>>Ht lom:Would you mind foking o quick look oilhis pdf? lf this is whct you're looking for, I'll send over the print copy.Or please provide input.Thanksl

    Yrndo

    From: Connie PixtonSent: Fridoy, July ,|8, 2008 3:23 PM

    Mine Permit Number nhrs/aa-c Mine Name Parilr -E *zt ,tv/aD^tratlOperator heNev/- zoctc Date t ATpv* a7z3zs?

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    TO

    -CONFIDENTIAL BOND CLOSURE EXPANDABLEAMENDMENTOTHER

    FROM

    Description Record Number_,aNOI Incoming _Outgoing Internal _Superceded

    FtGrrF a4 -

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    environmental

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    consultants, inc.

    May 19,2008

    Mr. Keith Egan P.G.HydrologistDepartment of Environmental QualityDivision of Water Quality288 North 1480 WestSalt Lake City, Utah 84118-4870

    Subject: Request for De Minimis Determination and permit by Rule for Geneva RockProducts, Inc. Point of the Mountain euarry Operations.

    O Dear Mr. Egan:JBR Environmental Consultants, Inc. (JBR), on behalf of Geneva Rock products, Inc. (Geneva),submits this letter to the Utah Division of Water Quality (DWQ to support a determinationof deminimis impacts to groundwater for the Point of the Mountain (pOivrfQuarry operation, and thatthe facility be granted permit-by-rule under Utah's Ground Water Protection Rules (UAC R317-

    8160 south Highland Drive. sandy, Utah 84093 [p] 801.943.4144lF|a01.g42.18s2

    On August 9,2005 Utah Division of Oil Gas and Mining (DOGM) notifred Geneva that thePOM no longer. qualified as a sand and gravel or rock aggregate operation, both of which are

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    exempt from regulation under the Utah Mine Land Reclamation Act. DOGM indicated thatGeneva needed to obtain a large mining permit in order to comply with the Act's administrativerules. A file number, M/0351026, was assigned to the operation. It is JBR's understanding,following a meeting with the DWQ on October 3,2007 and a phone conversation with Mr. RobHerbert of DWQ on January 2,2008, that the Geneva facility can be granted de minimis statusand Permit by Rule from Utah Department of Environmental Quality (DEQ), but the facility willbe regulated by the DOGM (i.e., DWQ will defer to DOGM and that agency's regulations andmonitoring standards). The POM Quany Operation is a zero discharge facility, thus they do notrequire a Storm Water Permit; however they are currently operating under a Storm WaterManagement Plan (SWMP). A semi-annual surface and ground water sampling plan, currentlyunder review by DWQ, has been developed to aid in the implementation of the SWMP. Thedepth to ground water at the Gqneva POM facility has been recorded to be 250 feet or deeper.This depth to water suggests that all water that infiltrates into the substrate within the Genevaproperty will be adequately absorbed and mitigated before it reaches ground water.JBR and Geneva appreciate the opportunity to submit this letter to the Division of Water Qualtty.If you have any questions and/or comments please feel free to contact me at 801.943.4144.

    Regards,JBR ENVIRONMENTAL CONSULTANTS. INC.Dp'cu=, #r\4

    @u L'nda J. MatthewsProject Manager

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    environmental consultants, inc. www.ibrenv.com8160 South Highland Drive r Sandy, Utah 84093 [P]801 .943.4144 [Fj801.942.1852

    May 8,2008Keith E. Eagan, P.G.State of Utah Department of Environmental QualityDivision of Water QualityGround Water Protection Section288 North L460 WestPO Box L44870Salt Lake City, Utah 841L8-4870

    Subject: Geneva Rock Products, Inc. Point of the Mountain Facility, Located on theSouthern Limits of Salt Lake County, Utah: Submittal of Point of the MountainWater Monitoring Plan, May 2008 and Site Sampling Event FaU 2007Dear Mr. Eagan:On behalf of Geneva Rock Products, Inc. (Geneva), JBR Envirorunental Consultants, [nc. isproviding your office with copies of the above-referenced documents for your review andcomment. These documents are being submitted to fulfill the agreement made between Geneva

    Linda Matthewslrom: Tony Christofferson [[email protected]]Uent: Thursday, October 04,2007 10:12 AMTo: Tom Munson

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    Cc: Linda MatthewsSubject: RE: notes from the meetingTom,

    Thonks for ihe nofes, I only hove one comment. Only ihe shallow well thot is down grodient fronr thesettling pond will be sampled.Keith soid that the deeper well, thoi is seoled io o depth of 500 feet, will not be effecfed cnd we will not goinonyihing by sompling thot well.Thonks,Tony ChristoffersonProperty/Environ mento I Mono n ger

    -----Originol Messoge-----From : Tom Mu nson [mailto:tommunson@utoh. gov]Sent: Wednesdoy, October A3,2AO7 3:34 PMTo: Tony Christofferson; Lindo Motthews; Beih Ericksen; l(eith Eogon; Suson Whitelrbieci: notes {rom the meetingvBcsed on discussions ond commitments from o meetirrg between ihe Division, DEQ groundwoier section, ondihe dperotor held on October 3,2A07. Certoin surfoce wqter ond groundwoter sites will be sompled for surfoceond ground waier quolity informotion. The woter in the fines settling pond will be sampled for o bosic woferquolity suite of porometers including PH, TDS ond conductivity. The two down grodient wells northwest of thefines pond will be sompled for similor constituents to estoblish boseline conditions. The oil ond greose detention

    Linda Matthewse:?T'To: Tom Munson [[email protected]]Wednesday, October 03,2007 3:34 [email protected]; Linda Matthews; Beth Ericksen; Keith Eagan; Susan White

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    Subject: notes from the meeting

    Bosed on discussions ond commitments from o meeting between the Division, DEQ groundwoter secfion, ondihe operotor held on Ociober 3,2007. Certoin surfoce woler ond groundwoler siies will be sompled for surfoceand ground woter quolity information. The woter in the {ines setiling pond will be sompled for o basic woterquolity suite of porometers including PH, TDS cnd conduciivity. The two down grodient wells norJhwesi of thefines pond will be scmpled for similor constituents to estoblish boseline conditions. The oil ond grecse detentionbosin will be scmpled for BTEXN ot o sompling site before the bosin ond after the bosin to deiermine boselinewoter quolity on o semionnuol bosis. Arr ongoing surfoce and groundwater sompling plon will be generoted forihe site ond included in the permii. A pennii oreo mop will be generoted to describe ihe flow potterns ossocioiedwith surfoce woter within the permit orec. The Stormwoter Pollution Preveniion Plon (SWPPP) will be completedond included os o drofi plon in the permit until cpproved by DEQ.This comment will be included in nry review.

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    ronmental,consultants, inc. www.jbrenv.com8160 S. Highland Drive r Sandy, Utah 84093 r [P] 801,943.4L44 . [F] 801.942.1852

    June 28, 2007

    Suson WhiteUtoh Division of Oil, Gos ond Mining1594 Wesi Norfh Temple, Suite I 210Solt Loke City, UT 841 l4-5801RE: Vegeiofion Doto for Genevo Rock Products, Inc., Point of the Mountoin [POM)Quorrv Ooerotion M/035/026Deor Ms, White:Attochbd is the vegetotion cover doto for the Point of the Mountoin Quorry, Thisvegetotion reporf is intended for incorporotion into Genevo's Notice of Intent toCornmence Lorge Mining Operotions, os Appendix D, lt should be inserled behind theAppendix D coVer poge, Pleose coll me or Morit Souryer ot JBR (943-4144) if you hovequestions on this reporl,

    r irJ. ! -l," ' ::,!;:i'r.;r}.;5 r,,;,jl .ii .i: i, F.

    a

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    lfrgtar consurtants, inc. www.jbrenv.com8160 s. Highland Drive . sandy, utah 84093 r [p] 801.943.4L44 o [F] 801.942.1852

    April27,2007Susan WhiteUtah Division of Oil, Gas and Mining1594 West North Temple, Suite 1210Salt Lake City, UT 84114-5801RE: Res0onse to Fourth Review of NOl to Commence Larqe Minins Operations, Geneva Rock products.Inc,, Point of the Mountain POM) Quarry Operation M/03b/026Dear Ms. White:This letter includes a response to the Division's fourth review, dated April S, 2007. JBR submits thisresponse on behalf of Geneva Rock Products, Inc, (Geneva).Red-lined/strikeout pages are provided for the revised pages of the NOI text.105,2 Surface Facilities Map

    The 'mixed use area' is defined in the document on page 8 and on Figure 2 as an area within the permitarea boundary which provides support for mining activities as well as construction industry activities. Thisarea will continue to be utilized for the construction industry in the absence of the mining activity, and thusreclamation of this area is not described in the NOI or included in the bond. The description of the mixed

    109,1 lmpacts to Surface and Ground Waler Systems

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    The noted sample was taken directly from the concrete wash plant tank at POM, The material from theconcrete wash plant tank is transfened via culvert to the ponds on the west side of l-15. ln consulting withJBR's hydro-geologist and site remediation specialist, he noted that the only organic analyses performedon the sample were total petroleum hydrocarbons - diesel range organics (TPH-DRO) and TPH4asolinerange organics (TPH-GRO). The results show 37 ppm DRO and

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    .ION M. HUNTSMAN, JR.Qpv4trtgtt

    6ARYR. HERBERTLieuswnl Gdvffitor

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    State of UtahDepartment ofNatural ResourcesMICHAELR. STYLEREftcutiw Direc[or

    Division ofOil, Grs & MinirrgJOIINR. BAZADivision Director

    April5,2007

    Carl ClydeGeneva Rock Products- Inc.1565 West 400 NorthF.O. Box 538Orem, Utah 84059

    Subject; Forryth Reviqly of Notice of Intention-to Commence Larse Mininq Opcrationq,Gcncva Rock Products....Point of thc Mountairr (soutllllansen) Quar:y.. . M03r0026. Task tD# 1?_9{i.Egh i,$ke Caunrv..l.,fHhDear IyIr, Clyde:

    The Division has completed out review of youl Notice of Intention to CommenceLarge Mining Operations for the Point of the Mountain QuarrJ, located in Salt Lake.County,Utalr, which was received February 23,2007. The athohed cornment$ will rreed to beaddressed before tentative approval may be granted.

    Flease address the cornments in the attacbed review by subrnitting replacementpflgeg viith redline/sh'ikeout tcxt. Aftor the notice is deternrined.IeChnically c9mp19te and weare prepared to issue ftnal approval, we will ask that yciu send ui trvb clean iopicd of thecomplete and corrected plarr. Upon firral approval of the penriit, we will retrm one copystamped "approved" for your recolds. Please provide a response to-this lgview by April 30.209,)L :

    Carl ClydePage 2 of3M0350026

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    Apnl 5,2007FOIIRTE REWEW OF NOTICE OF INTENTION TO COJ}MIENCE LARGE MININGOFERATIONS

    Geneva Rock producfu, fuc.Point of the Mountain ($outh Hansen) euarryw035/026April5,2007

    _105.2 Surface facilities rnpFigure 3, the surface'fncilities map, sh6ws a "mixeifuse area"-whiohjs not inoluded foraffeage or borrdirrg calculafions. Please inciude justilication for excluding this area.(PBB)SSJ.-j!-l06 - Oueration ptan

    106,6 Flan for protecting & redepositing soilsOn pages i4 and 16, the plan says soils stored above the highwall would be used forintcriln ol concurent reclarnafion. Please explain. These Jtatements appear to indicatsthe soil wiil not be used for final reclamation. fue there areas above the tiighwail thatneed soil for reclarnation? Otherwise, since lirnited soil is avaiiable for usJon the pitfloor, and since there are no plans to use the soil on the highwall benohes, would it not bemore beneficial to haul this soil to the pit floor? fiBB)On pages 14 and 30, the piur indicates rnanru.s may be used as a soil amendment, and thecover letter also mentiorts biosolids, Please include eriteria for

    Carl ClydePage 3 of3M0350026

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    April5,2007taken from several areas arrd testeri. Please ihen provide a discussion on the source ofthese organics and how to prevent further contamination. The discussion should address:

    A conrmitment to sampling the sediments again prior to reslamation hasbeen made' Please include a discussion on f,o* ihe sampling *at"rtrrrgwill be conducted.How tJ:.e area will be reclaimed a'd if the pond wilr need to be linedand/or capped.The sa'rpling ar:d monitoring plan to establish grou:rdwater ounent andooniinued operational conditions.Ift W-,1*ti*s plan should djscuss groundwater impacts and how theurine will prevent thise and othei inauiriai iompouna *o* .ii.ri'g trugoundwarer.(TM)

    R647-4-112. Variances.Topsoil varianoe: Please describe the altemate methods or fteasure$ to be utiliaed irr lieuof spreading topsoil, The exact area to be affected by the variance must be describedinstead of the term ,tertain oreas'.. (SW)Revegetation Variance: Floase describe the alternate methods or measures to be utilizedin ]ieu of a tevegetation slandard. other methods of sampling are available to measuevegetation otirer than being on the surface. Safety equip-""iro"rt"r ,op.*, t u*.ru.r,and hald hats are available to eilsurs individual tit *. If time is needed roi thc slopes tosettle it *9^Tlq be possible to put off sanrpling for s to ro years to detsrmine revegetationsuccess. ($W)

    environmental consultants, inc. www.JDrenv.com

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    8160 s. Highland Drive o Sandy, Utah 84093. [p] 801.943.4t44. [F] 801.94z.r}szFebruary 23,2007Susan WhiteUtah Division of Oil, Gas and Mining1594 West North Temple, Suite '1210Salt Lake City, UT 84114-5801

    Dear Ms. White:

    This letter includes a response to the Division's third review, dated December 4, 2006 JBR submits theserevised NOI pages and maps on beharf of Geneva Rock products, Inc, (GRp),Revisions to maps and text, in addition to comment responses below, are due to a change in the plannedpit floor elevation for end of Phase 1 mining, Mining nearly to the lowest elevation of the existing pit floorwould bring the floor elevation down to approximately 4665 feet, adding to the highwall and decreasing thesize of the pit floor' Maps have been adjusted to show Phase 1 final pit floor elevation at 4665' rather thanthe elevation shown previously. This change affects acreages of pit floor vs. highwall, which have beenadjusted throughout the document. The Phase 1 area has also been revised to show inclusion of the

    RE:

    The legend on Figure 3 has been amended to describe Phase 1 as the bonded area,

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    106.2 Type of Operations to be ConductedThe concrete and asphalt piles at the north end of the property are made up completely of material that hasbeen stockpiled from offsite. The concrete material is crushed and recycled into road base. These materialstockpiles are not considered to be part of the mining operation,106.5 SoilTypesThe Division is correct; a Figure was removed, and the Figures have been renumbered; Figure referencesto topsoilstorage areas have been corrected in the text.Wording in the text regarding topsoil storage piles has been revised to reflect the following;Topsoil stored above the highwall along the central/north property line would be utilized for interimreclamation, This soil would be utilized prior to completion of mining in Phase 1, such that the resourcewould not be lost,

    Geneva has proposed a stockpile area on the southwest point of the property, outside the area proposedfor mining, This is shown on Figure 3, Topsoil proposed for storage along the southwest point of theproperty would remain outside the proposed area to be mined.The topsoil stockpiles on the northern part of the pit floor have been added to the permit area for Phase 1.This 5 acres at the northern point of the property is also included in reclamation calculations, as part of thepit floor,Text has been added to state that a TCLP test on the reclamation fines material would be run for VOC's to

    The material in the fines pond has been recently analyzed by Geneva. The sieve and hydrometer analysesprovidedthefollowingtexturalcomposition: pebblest%;sand 23.l'/o;silt5g.5%; claylTo/0.The sieve analysis results have been added to the NOI as Appendix E; reference to t-his analysis is made in

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    section 106.5. , lseveral types of plants are known to 'volunteer' in the fines pond; Geneva has noted that grasses inparticular are expected to take hold there. The semi-permanent seed mix described above would be usedfor reclamation of the fines pond.106,7 VegetationThe revegetation seed list under 106.6 has been added to the NOl. The revegetation plan is described inthe NOl.The references to north and south slopes have been changed to south-facing and north-facing in thissection as well as in Section 10g.3.110.5 Revegetation planting program and Topsoir RedistributionThe seed mix is lisied above, under 106.6.R647-4-112 VariancesRegarding the use of topsoil, biosolids, or manure, it is Geneva's position that very litfle of the material ifpushed over the highwall, would end up any further down than the first bench. lt is expected that spall fromthe highwall will eventually fill in parts of the benches, Although the highwall would be stable, and accessto the benches would be possible, it is expected that the spall ilaterialfalling and collecting on the benchesduring the first three to five years post reclamation would not provide a safe walking/working surface forinspection of vegetation cover. In addition to ihe filling in of benches from spall, the outer edge of eachbench would gradually

    State of Utah January 24,2007

    litr.' -jilfii :, r,."_ ",:rJIJ/JONM. HUNTSMAN, JR.Covernor

    GARYR. HERBERTLieutenant Govemor

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    Department ofNatural ResourcesMICHAELR. STYLERExecutive Director

    Division ofOil, Gas & MiningJOHNR. BAZADivision Direcnr

    Carl ClydeGeneva Rock Products, Inc.1565 West 400 NorthP.O. Box 538Orem, Utah 84059

    Subject: Extension Request Granted. Geneva Rock products. Inc.. point of the

    Dear Mr. Clyde:On January 22,2007we received your letter requesting a 30 extension tofumish your response to the Division's third review of your LargeMining Plan foryour Point of the Mountain (South Hansen) euarry. you have requested thisextension because of the holidays the information had not been reviewed byGeneva's permitting person.Given the extenuating circumstances, the Division hereby grants yourextension request. Please provide your response by Febru ary 23,2007 .Thank you

    environmental consultants, inc. www.iDrenv.com

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    8160 S. Highland Drive . Sandy, Utah 84093 . [P] 801.943.4L44 r [F] 801.942.1852

    January 22,2007Doug JensenUtah Division of Oil, Gas and Mining1594 West Norlh Temple, Suite 1210Salt Lake City, Utah 84114-5801RE: Geneva Rock Products Point of the Mountain Quarry, M/035/026Dear Doug:On behalf of Geneva Rock Products, Inc, I would like to request a one-monthextension to respond the recent Division review date December 4,2006. TonyChristofferson noted that the comment letter may not have been properly routedto him due to the holiday season. Geneva has only recently had an opportunityto review the letter. Thank you for your consideration.Sincerely,

    o JON M. FIUN,I-SMAN, JRGoventorC,ARY R. HERBERTLieutenont GovctilorDecember 4,2006$tate of Utah

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    CERTIFIED R.ETij^fu\ RT CEIPT'70042s10 0004 1824 4288

    Cari ClydeGeneva Rock Products, lnc.1565 V/est 400 NorthP.O, Box 538Orem, Utah 84059

    Subject: 'lhird Review qf })Ip,liqp.o.t]ptqUdoq jql:o.-nmence Lar-ee Mining Operations,Ger:eva l{ock Products.. Point of the r\4ountain (So$!h Hansen) Quarrv. M/035/026. Task ID# 1624. Salt Lake Counrv. Urah

    Dear Mr. Clyde;The Divisjorr has courplcted a review of your response for the Point of iheIvlountain (south Hansen) Qr-rarry. received November 21,2006. After revjewing theinfomration, th.e Divisior: iras the folloMng oornments which need to be addlessed befbretentative approval may be granted-The comments u'e listed bclow under the applicable Minerals Rulo hcadin-s, Pleaseaddress only thosc itcurs requested in the attached technical rcview. Seud roplacement pagesto the original notice using redline and stril(eout text and indicate how these are to beincorporated into the plan using the anached Fbm-MR-REV-att. After the notice is

    Department ofNatural ResourcesMICHAELR. STYLERExtcuto\e Director

    Division ofOil, Gas & MiningJOHN R. B.4ZADivision Directar

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    R647-4-1 10 - Reclamatigp..Plan110,5 Revegetation plantingproEam

    Plcase include a seed mixturt to bc used fbr final reclamatioil, The list of speoies includedin thc plan is acceptable, but the plan should detail how much of each species will beplanted' The Divisiou suggests r:elying heavily on the dominant native bunchgrasstrtuebunch wheatgrass, (pBB)R647-4-113 - Variance

    The operaior requests a val'iance from soil redistr-ibution requirements for areas where thisis not feasible or practical, such as the pit highwall benches. The alter.nate method to beused is to push any available soil over the edge of the highwall and allow it to cascadeover the benches. The op+rator states in the pian that the bcst usE of the soil is on the pitfloor.The Division agrees that linrited soil is available and that the best use is probably on tl:epit floor, but additional measure mf,ybe available for amending material that will be onthe highwall and reestablishing vegetation. Composted manure or biosolids couldprobably bc cascaded over the edge of the highwall or, if the highwall is actually a lh: lvslope, this material 00uld bc spread down the slope to increase organic mafter, watsrhoiding capaciry, and biological activiry. (pBB)The operator also request$ a va]iance from meeting revegetation success standards on thehighwall benches because it would be impraotical and unsafe to measure for vegetatiousuOcess and because *re benohes are expected to frll in with spall, Aiftough revegcrauonsttsssst stafldards would not be applied, the operator would still be required to seed theseateas.Piease provide further ittformation about why it would be irnpractical ancl unsafe to

    Means 2006 023 I5'490-2040 sirows tl:e cost to move material by truclc *Z rniles roundfipis and

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    fi2.921cy the cost to load this truck with a 950G loader wittr zero haul distance at0.44/cy- The cost to move the requir-ed soil to t}re pit floor should be shown as $3.36lcy(DJ)

    _ P:\CROUPSMINERALS\\!?W035"Saltlalce\]vt0350026-PoinrMtn\finrrt\l l272006third-rev-doc

    106.2 Type of Operations to be ConductedBased upon our meeting with the Division on July 14,2006, and in order to remove confusion regardingany planning for additional phases, we have removed from the plan any details concerning phases 2 thru S.

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    The term'conceptual' has been removed from the operations description.Under the sand and gravel heading, the introduction states that 29 acres of the proposed permit area (not29 acres of pond) are located on the west side of l-15. This description has been adjusted to show that 40acres of reclamation fines are proposed under Phase 1, and 65 acres of the overall permit area are locatedwest of l-15.

    The 26.4 acres was labeled 'current and near future fines storage', in order to separate from 'future' future(32.1 acres). This has been revised/clarified, as noted above.The dashed line does represent the mixed use area, The arrow label for the mixed use area has beenmoved over to meet up with the boundary on the Permit Area & Phase 1 map. A notation in fhe mapexplanation has been added to define this area,

    106.3 EstimatedAcreageThe text has been revised to reflect that the Phase 1 area may be reclaimed at the end of phase 1 mining,if the next phase is not mined.106,4 Nature of the Materials to be Mined and production RatesThe incorrect figure for total production has been changed per the Division's suggestion.

    106.5 SoilTypesThe soil storage piles shown in Figure 2 will be used during ongoing reclamation in the quany, and for

    environmental consultants, inc. www.jbrenv,com8160 s. Highland Drive . sandy, Utah 84093 . [p] 801.943.4L44. lFl 801.94z.rgs2

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    November 17,2006Doug JensenUtah Division of Oil, Gas and Mining1594 West North Temple, Suite 1210Salt Lake City, UT 84114-5801RE: Response to Second Review of NOI to Commence Large Mining Operations, Geneva Rock Products,Inc,, Point of the Mountain Quarry Operation M/03S/026Dear Doug:This letter includes a response to the Division's second review, dated May B, 2006, as well as additionalrevisions based upon our subsequbnt meeting July 14, 2006. JBR submits this red-lined/strikeout versionof the NOI on behalf of Geneva Rock Products, lnc, (GRp).Revisions to maps and text revolve around the removal of detail on Phases other than Phase 1, Red-lined/Shikeout pages are provided for the NOI text, All maps are included. The surety was adjustedaccoiding to the Division's review comments.104 Filing and ReviewExplanation has been added to

    Regarding the location of proposed soil stockpiles, the stockpiles located on the north end of the permitArea would be outside of Phase 1, and therefore usefulfor Phase 1 reclamation, Geneva has determinedthat there are no additional areas of the current pit floor that would be suitable for stockpiling topsoil.

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    106,6 Plan for proteciing & re-depositing soilsText has been added to indicate that soil stockpiles conshucted and not used again during the growingseason will be seeded with an annual grain such as winter barley; they will then be seeded with the semi-permanent seed mix in the fall, Soil stockpiles constructed in the fall would be seeded with the semi-permanent seed mix, Once seeded, soil stockpiles will be checked monthly during the growing season;remedial action would be taken if necessary to prevent the establishment of weeds.106.7 VegetationBased upon the Inspection Report dated August 9, 2006 (included in Appendix B of the NOI), vegetationwill be evaluated at the POM site in spring 2007.106.9 Location, size of ore, waste, etc.The variance request for impoundment of water has been deleted from this section of the NOl. since wehave no detailed mining plans for further phases.109.4 slope stability, Erosion control, Air Quality, public Hearth & safetyThe noted phrase in the Slope Stability section should have been 'break off over time'; this editorial changehas been made.The Table numbers have been corrected.

    110.1 Land UseThis section has been revised slightly to clarify that the area would phase

    establishment of plants. lf all of the stored soil were available at the end of mining in Phase 1, it would bespread out over the 144-acre pit floor at a depth of 3 to 4 inches,The seed mixture will be

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    based upon DOGM recommendations as included in the August 9, 2006inspection report (bluebunch wheatgrass, purple three awn, sand dropseed, crested wheatgrass, big sage,palmer penstemon, and blue flax) as well as on reconnaissance of nearby areas. The suggestedrepresentative pre-mining vegetation will be sampled in Spring 2007 and cover/species.results submitted tothe Division.111.12 Topsoil RedistributionComments regarding topsoil redishibution have been addressed under 1 10.5, above.R647-4-112 Varianceslmpoundments -This request has been removed from the NOl.Soils - The remaining topsoil stored above the highwall would either be pushed over, to provide some soilto portions of the benches, or hauled to the pit floor. The main use for stored topsoil would be forreclamation of the pit floor.Revegetation - The highwall benches would be seeded aerially one time only, to provide an initial seedsource that would mix in with any topsoil pushed over the top, or spall accumulating on the benches. Thiswould help to promote revegetation of the benches in order to provide some protection from noxious weedsand from erosion.Due to the active spalling of these benches, no reclamation success standard would be applied, as thebenches would not be considered safe or reasonable to measure to a reclamation standard, Over time, it is

    ' LB No fines will be hauled,Ripping costs have been adjusted.

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    9.9 The asphalt and concrete piles are no longer included in the reclamation area for Phase 1,The escalation rate has been adiusted to 1.6%.

    Thank you for your assistance.Silcerely,!'*l*WLinda J. MatthewsJBR Environmental Consultants, lnc,

    Cc: Daron Haddock, UDOGMTony Christofferson, Geneva RockCarl Clyde, Geneva Rock

    l,-State of UtahDEPARTMENT OF NATURAL RESOURCESDivision of OiI, Gas & MiningMICHAELR, STYLER JOHNR. BAZAExecutive Director Division Director

    Inspection ReportM. HUNTSMAN, JR.Govemor

    GARY R. HERBERTLieutenant Govemor supervisor Mk

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    Minerals Regulatory ProgramReport Date: August 9, 2006Mine Name: Point of the MountainOperator Name: Geneva Rock Products

    Evaluatednnnnnnn

    Comment EnforcementnnnnnnnnntrNTntr nilnunntrXtrn

    nnXntr

    Permit number: M0350026Inspection Date: July 20,2006Time: About 9:00-i 1:30 AMInspector(s): Paul Baker and Doug JensenOther Participants: Tony Christofferson (Geneva) and Jenny MahoneyMine Status: ActiveElements of fnspectionl. Permits, Revisions, Transfer, Bonds2. Public Safety (shafts, adits, trash, signs, highwalls)3. Protection of Drainages / Erosion Control4. Deleterious Material5. Roads (maintenance, surfacing, dust control, safety)6. Concurrent Reclamation

    7. Backfi lling/Grading (trenches, pits, roads,highwalls, shafts, drill holes)8. Water Impoundments9. Soils10. Revegetation11. Air Quality12. Other

    Weather: Mostly clear, 80s

    Purpose of Inspection:The purpose of the inspection was to see whether a reclaimed area above the mine would make asuitable revegetation success standard or if it would be better to use an undisturbed area as the

    Inspection Date: July 20,2006; Report Date: August9,2006Page2 of2M0350026

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    present, mostly as individual plants, include musk tliistle, pallid evening primrose, blanketflower,crested wheatgrass, bee plant, either western or thickspike wheatgrass, cicer milkvetch, and blue flax.Conclusions and Recommendations :The revegetated area is not suitable as a revegetation success standard. Although the undisturbedareas are not ideal vegetation communities, they represent the premining vegetation. This is what therules say should be sampled.The operator should try to control the musk thistle and needs to be sure it does not spread through thereclaimed area or into the mine site.The operator asked for seed mix recommendations. The mix used in the past is very diverse andcontains several adapted species, but many of them would not provide significant cover. Irecommend that the mix include bluebunch wheatgrass, purple three awn, sand dropseed, a smallamount (perhaps one pound PLS/acre) of crested wheatgrass, big sage, Palmer penstemon, and blueflax.

    Inspector's Signature

    PBB:pbcc: Tony

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    )State of Utah

    art'rl fu14'fJON M. HUNTSMAN' JR.Governor

    GARYR. HERBERILieutenant Govetnor

    i 3 ?rft$,'- .tMay 8,2006