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HomeMy WebLinkAbout2005-06-28 - AGENDA REPORTS - CASPAR MINE OPPOSITION (2)Agenda Item: CITY OF SANTA CLARITA AGENDA REPORT NEW BUSINESS City Manager Approval: Item to be presented by: Kai Luoma DATE: June 28, 2005 SUBJECT: PACIFIC INDUSTRIAL MINERALS' PROPOSED "CASPAR" MINE - 11554 SOLEDAD CANYON ROAD, IN THE UNINCORPORATED AREA OF LOS ANGELES COUNTY DEPARTMENT: Planning and Economic Development RECOMMENDED ACTION City Council to adopt a Resolution opposing the proposed mine. PROJECT DESCRIPTION Pacific Industrial Minerals is seeking both U.S. Forest Service (USFS) and County of Los Angeles approval to mine up to 150,000 tons of the mineral anorthosite per year for 20 years (3 million tons). Anorthosite is used as a bonding agent in paints, ceramics, and concrete. The material will be mined in one area of the site located on the south side of the Santa Clara River then transported by loader across the river via a proposed bridge to a processing area where the ore is processed then bagged. Trucks will then pick up the bagged material for shipment. The entire site is approximately 320 acres in size. It has been named "CASPAR" by the operator. A copy of the mine plan is attached. The mining operation proposes to blast and/or scrape the material from a hillside on the site. The hillside will be stepped and ramped as the mining progresses. The mine will result in a "scar' on the hillside approximately 250 feet tall and several hundred feet wide. The actual mining area is bound on the north by the Santa Clara River and to the east and west by two tributaries to the river. Mining is proposed to come within mere feet of the two tributaries. As mentioned a new bridge must be constructed across the river. The mine is to be located on the south side of Soledad Canyon Road near the terminus of Agua Dulce Canyon Road. It abuts property owned by the City of Santa Clarita and is only a couple adopted: so _s,Rz hundred feet from the approved CEMEX mine. BACKGROUND Relatively small-scale mining operations at this site date back to the 1950s. According to the operator of the proposed mine, between 1983 and 1998 mining levels were at 30,000 tons per year. In 1996, the County issued a Conditional Use Permit (CUP) to allow the processing and hauling of up to 200,000 tons of ore. The CUP expires in April 2008. In 1998, the site was processing approximately 100,000 tons per year but mining operations were shut down by the USFS in 2000 when the permit expired. No mining has occurred at the site since 2000. Because the previous mining permits have expired (with the exception of the CUP), the proposed mining operation must receive new approvals from both the USFS and the County of LA. The USFS must authorize the mining as the claims are located in USFS-owned land. The County of Los Angeles must approve a mining and reclamation plan for the mining activity as well as the conditional use permit to process and haul the mined material. Applications for the proposed mine were originally submitted to the Forest Service and LA County in 2003. The applications remained incomplete for an extended period. Only recently did the USFS determine that their application was sufficient enough to begin environmental review. The application with the County remains incomplete. ANALYSIS In 2004, the Los Angeles County Board of Supervisors approved Cemex to mine 69.2 million tons of material to produce and sell 56.1 million tons of sand and gravel over a 20 -year period with annual mining levels of up to 5 million tons per year within a few hundred feet of the proposed CASPAR mine. The City of Santa Clarita is actively working to prevent the approved mega -mine. Until all potential remedies are exhausted, the community continues to be faced with a large scale mining threat which will negatively impact air quality, aesthetics, biota, water quality and traffic in the area. While City staff is confident that the Cemex mega mining proposal will not actually occur as proposed, the cumulative effects of another mining proposal must be considered in conjunction with the approvals which the Cemex project currently possesses. In addition, since 1960, which is the approximate time when mining first took place on the subject site, the population of the Santa Clarita Valley has grown from fewer than 40,000 to 245,000 people (an increase of about 500%). Growth of the community has moved toward the Angeles National Forest property. While mining of locatable materials may be allowable under the Mining Act of 1872, clearly it is incompatible with a growing urban community. Staff has determined that the proposed mine will result in adverse impacts to the environment and to the health, safety and welfare of the citizens of Santa Clarita and the Santa Clarita Valley. No mining has occurred at the site in over 5 years. In those five years, there have been many significant changes in the immediate area and the vicinity, such as; • Much of the mine site that had been disturbed has been reclaimed by native vegetation • Riparian habitat has been established along the river and both of the tributaries abutting the mine site • Endangered species have been confirmed to be present in the vicinity • This year's floods have washed out the access across the river on the mine site • Other mining operations in the vicinity have been approved and existing operations expanded • The population of the Santa Clarita Valley has increased by approximately 37,000 (20,000 in the City) Furthermore, the proposed mining of 150,000 tons of ore per year represents a dramatic increase in the scale of mining that historically occurred at the site. No mining has occurred in the last five years and an average of about 24,000 tons per year has occurred since 1983. The mine also includes aspects that have never been part of mining at the site, such as bridge construction and bagging of mined material. For these reasons, the baseline by which to study the proposed mine should be the present conditions only. Historical mining at the site, no matter the scale, is irrelevant in determining the impacts that the proposed 3 million ton mine will create. From the information that staff has been able to obtain it is evident that the proposed mine will result in significant impacts to the environment. These impacts include: • Cumulative impacts: The recently approved Cemex mine, located just a few hundred feet from the proposed mine, will result in immitigable impacts to air quality, biota, and aesthetics. The adoption of a Statement of Overriding Considerations for these immitigable impacts by the County Board of Supervisors was necessary for the approval of Cemex. Operations from the proposed CASPAR mine will result in impacts to: • Air quality — the proposed mine will impact air quality through the generation of dust from truck and vehicle movements, loaders, blasting, the processing of ore, exhaust from trucks/equipment, generators, and other power sources. The effects of the fine powder that would result from the mining and processing of the ore must also be considered. • Biota - the mine proposes a bridge across the Santa Clara River and mining with feet of two tributaries. The Santa Clara River in this area is known to contain two federal endangered species: the Unarmored Threespined Stickleback and the Arroyo Toad. In addition, there is a potential for other endangered and sensitive species to occur in the area, including but not limited to: the Red -legged Frog, the Southwestern Willow Flycatcher, the Least Bells Vireo and the California Gnatcatcher. • Aesthetics - the mine will result in a 250 -Foot -tall, several -hundred -foot -long "scar" on the face of the mountain that will be visible from public right-of-ways. The immitigable impacts already acknowledged as part of the Cemex mine will only be exacerbated by the CASPAR mine, resulting in cumulative immitigable significant adverse impacts. These cumulative impacts cannot be mitigated and will pose a threat to the health, safety, and welfare of the citizens of Santa Clarita and the Santa Clarita Valley. Other Impacts - The city also contends that the Cemex mine will result in significant immitigable impacts to traffic and water quality for which adequate mitigation has not been identified. Again, the proposed mine will only serve to exacerbate these impacts to point that they are cumulative immitigable impacts as well, posing a threat the citizens of Santa Clarita. A letter citing these concerns was sent to the US Forest Service on June 10, 2005 and is attached. ALTERNATIVE ACTIONS The City Council may choose to: 1. Not adopt the Resolution of opposition; 2. Provide other direction as determined by the City Council. FISCAL IMPACT Adopting this Resolution will have no fiscal impact. ATTACHMENTS Mining Plan Comment Letter to United States Forest Service Resolution PROJECT DESCRIPTION CASPAR riIINE LOCATION OF MINE The Caspar Mine is located at 11554 Soledad Canyon Road, Canyon Country, CA 91350. It is a Placer Mining Claim , RUSS 1 to 16 (320ac total), located on U.S. Forest Service land in the vicinity of Lang Station. It is approximately five miles east of the interchange of the Antelope Valley Freeway and Soledad Canyon Road. The site is located in portions of the northwest quarter of Section 15, Township T4N, Range R 14W, San Bernardino Baseline and Meridian. The Caspar Mine is located at Latitude 34025141" North. Longitude 118°20'00" West. The project is composed of three areas (1) Area "A" — A 10 acre mining area located on the south side of the Santa Clara River. (2) Area "B"— A 7 acre processing and stockpiling area and (3) the river crossing that joins Areas "A&B" which needs to be repaired or replaced . ENVIRONMENTAL SETTING: GENERAL Pacific Industrial Minerals, LLC. (PIM) leases SIXTEEN Placer Mining claims (Russ 1 to 16) from Soledad Quarry,LLC. The claims are located in the Precambrian San Gabriel Anorthosite Complex of the western San Gabriel Mountains. The property contains large amounts of CAlcium feISPAR (CASPART ) which when properly processed can be used in the glass, cement, abrasives, ceramics, paint and many other commercial industries. The climate in the area is semi -arid with total annual precipitation over the past 30 years averaging 19 inches with a range of 4 to 24 inches. The rainfall occurs in an average of 31 days, generally between the months of October and April. The topography of the area is quit rugged with a relief of 700 feet. The river elevations range from 1900 to 2000 feet and the highest point is 2600 feet. The site is drained by the Santa Clara River. The landscape is generally Chamise Chaparral with a Riparian Zone along the Santa Clara River. Vegetation on the site is very limited because of the historical mining that has occurred on the property. There is no evidence of any previous vegetation reclamation. There is evidence of regrowth of semi - desert chaparral and sage scrub along with grass, such as, wild oat , foxtail grass and buckwheat. Previous biological studies indicate there are no threatened ,endangered, or candidate state or federally listed plant species known to occur on the proposed quarry or processing site. There are two threatened, endangered and candidate wildlife species that could occur on the site. they include: Least Bell's Vireo (Vireo belhi pusillus; Federal Category E) and the Willow Flycatcher (Empidonar trailli; Federal Category 2), Adjacent to the site within the Santa Clara River ,which must be crossed in order to access the site, is in the potential habitat of the Unarmored Three -spine Stickleback(Gasterosteus aculeatus willamson; Federal Category E) and the Arroyo southwestern toad (Bu/o microscaphus callfornicus). No activity will occur in the river itself and proper mitigation is being taken at the crossing to protect these species. PROJECT DESCRIPTION Created on 1/1/2005 9:31 AM GEOLOGY REGIONAL The Caspar Mine is located in the western portion of the Precambrian massif -type anorthosite pluton forming the central segment of the Transverse Range Province. The Province is relatively narrow (8 Ian to 16 km) and has an east -west trend 500 km long "transverse" to the northwest trends of the Coast Range Province and the Peninsular Range Province to the southeast. LOCAL The Anorthosite-syenite pluton underlies the western San Gabriel Mountains. The pluton is a part of a large, well fractionated, Complex comprised of Andesine anorthosite, leucogabbro, gabbro, ferrogabbro, jotunite and syenite . The pluton has three distinct stratigraphic units: 1) The anorthosite unit is the lowest and oldest unit. It is approximately 7 km thick and tends to be more mafic near its top. 2) The syenite unit overlies the anorthosite. It is 0 to 5 km thick. This unit is very mafic at its base. It is thin or missing on the north side of the body. 3) The jotunite unit is the upper unit consisting of layered johmite, ferro-gabbro and gabbro. Within the complex, the anorthosite unit has been intruded by gabbro and pyroxenitic rocks. Late stage hydrothermal events have altered much of the pyroxenites to amphibole and chlorite. At the site, the river canyon is cut into Precambrian bedrock and is filled in with alluvium. The alluvium is characterized by coarse sands and gravel with cobbles and small boulders. the crystalline basement complex exposed at the site are Precambrian anorthosite and gabbroic plutonic rocks with lamprophyre dikes and minor Cretaceous granitic Intrusive rocks. MINERALIZATION The main ore mineral of economic interest at the Caspar Mine is of the mineral group Plagioclase. The feldspar is a solid solution between two endmember feldspars,. albite (sodic Na AISi3O,) and anorthite (calcic CaAl2Si2%). Within this pluton, the anorthosite is composed of 97% Andesine (Ca,NaxA1,Si)Si3O,, a middle member of the solid solution. The remainder consists of apatite, zircon, chlorite, homblende, biotite and iron ore minerals scattered throughout. The Andesine is euhedral to subhedral and bluish gray to white in hand specimen. The euhedral crystals are characteristically tabular, commonly elongate parallel to the a -axis. Their average dimensions are about I cm by 5 cm. The composition of the feldspar is remarkably uniform throughout the intrusive. It ranges from An38 to An46, averaging An43. Mineralogical analyses using XRF techniques substantiate the cleanliness of the material . MINING OPERATIONS Mining History Small scale mining apparently began in the late 1950's comprised of dozer trenches and bulk sampling. Dr. Donald Carlisle,Ph.D. , the distinguished professor from UCLA provided a geological report on the property dated May 1, 1959 and mentioned "various cuts and exposures". By the 1970's , Monkstone Industries built a small processing facility on the site and began very small scale mining and processing. By 1980, formal Operating Plans were in place, an ENVIRONMENTAL ASSESSMENT (EA) was completed and a DECISION NOTICE, FINDING OF NO SIGNFICANT IMPACT was signed by the USFS (6/22/82). A PERFORMANCE BOND of $5000 was posted for RECLAMATION. The Plan of PROJECT DESCRIPTION Created on 1/1/2005 9:31 AM Operations was updated in 1990, reviewed again in December of 1995 and extended to December3l, 1997 when Industrial Mineral Fillers, LLC.(IMF) obtained the lease from Soledad Quarry, LLC. IMF operated Oe mine and adjacent fine grinding mill until approximately 2000 when the mining permit and lease expired. Pacific Industrial Minerals, LLC. (PIM) obtained the lease from Soledad Quarry,LLC. in 2003 and has been processing a new POO with the USFS and SMARA Plan with Los Angeles Co. Mining Resources Within the mapped quant' area, there are 10.5 million tons of salable material. A cross section through the quarry is shown in Attachment (4). The section shows the profile of the existing topography and the proposed mined out pit. A proposed mining plan is also included in Attachment (2). The quarry will have 40 foot benches ; the pit floor will be lowered to the 2000 Ft. level with a natural insitu berm left to protect the river. Mining Plan The mining of PIM's CASPAR ore will be performed under the direction of PIM's geologist and the POO. PIM leases sixteen (16) Placer claims CAMC 280405 through 2180420 known as Russ I through 16. The mining site is located in Anortbosite. It began operation in the 1960's and has operated since producing material for chicken scratch, corral sweetener, and over the past five years for the glass, stucco, paint, ceramics, cement and other commercial industries. 7 t) 1 The mineral to be extracted is Anorthosite at a projected rate o 150,toffs per year. It will be extracted by drilling and blasting hard rock drill holes averaging 40 feet in eapth with 10 foot spacing. The general mining procedure to be used will include the following steps: I . The area to be excavated is cleared of any vegetative cover. This includes transplanting sensitive cacti and yucca plants to the edge of the disturbed area. 2. Where topsoil and/or overburden exist, it is removed and stockpiled separately at the northwest side of the quarry. With the use of a bulldozer, access roads are made to the bench level for the drill and compressor. 3. Blast holes are drilled with the pneumatic rotary drill on a pattern dictated by production and market demands. 4. A controlled blast breaks the rock in the bench, which minimizes any "fly rock". Generally, the bench will be 40 feet high and 60 feet in width. 5. A bulldozer will then push the blasted rock into a stockpile.\ 6. A front-end loader loads the stockpiled material into trucks for shipment to the mill or to the Primary crushing/screening plant. The quarry may generate as many as 25 truckloads per day operating 5 days per week. Operations will be during daylight hours. The final bench design is a 40 foot face and 60 foot wide bench with a final pit slope angle of 1 '/2:1(H:V). Since 1983, approximately 30,000 tons of rock has been mined. Maximum annual production is anticipated at 150,000 tons. The estimated project life is 20 years based on fluctuations in production and demand. MINE WASTE The existence of "Topsoil" is very minimal at the site. The topsoil that is encountered is cleared with a bulldozer and stockpiled for future use as a growth media. It is estimated that there will be approximately 5% or 7500 tons of mine waste generated annually. All domestic refuse will be collected in bins and disposed of at permitted landfills. No hazardous materials, other then diesel fuel, will be stored on-site. PROJECT DESCRIPTION Created on 1/1/2005 9:31 AM ORE PROCESSING A portable self -powered crushing/screening plant will be used on-site to crush, size and remove fines from the ore prior to being shipped to the mill. The unit will be permitted by the California Air Resourses Board or SCAQMD. The exact configuration is not known at this time as the unit will belong to a contractor who will be chosen in a bidding process. PROJECT DESCRIPTION Created on I/ 1 /2005 9:31 AM Plant Feed staging Site. This 20' w X I O'h tarped stockpile contains up to 400 tons of ore. 1_ Plant Feed Unit A Front-end wheeled loader remotes ore from the staging site stockpile and fills the plant feed hopper. The feed hopper is covered to protect,from rain and wind and has a capacity to provide metered sire to the plant for approximately 4 hours. A. General This unit provides dry pulverized material which can be classified into marketable products. B. Grinding Unit The plant feed hopper provides regulated feed to a vented: harnmennill. The ore passes through a rotary airlock feed valve into the grinding chamber containing a horizontal hammer assembly. C. Air Heater In order to provide dry (<1 % moisture) product, a direct -fired air heating chamber is provided. The burner is propane or natural gas fired and has a capacity of about I MM BTU/HR. The hot air is swepted through the fluid bed chamber and "flash dries" the ore. The exit gases are passed through the classifier, cyclone and dust collector prior to exhausting to atmosphere. CLASSIFYING AREA This area is composed of a Fluid Bed Air Chamber (Raymond Mechanical Air Classifier or equivalent). The air -entrained material is swept into the unit. Classified product, generally <200 mesh or <325 mesh in size passes out one portal and the coarse fraction is separated or returned to the mill for additional grinding or is collected and processed additionally through screening and magnetic separation. PROJECT DESCRIPTION Created on l/l/2005 9;31 AM LOADOUT AND BAG PACKER UNIT Classified product from the cyclone collector and the baghoase collector is collected in a surge bin. The material can be loaded directed into bulk' trucks for shipment or metered'into a MHE Impeller type packer and put into 50 or 100 lb. paper or plastic bags for shipping. Forty or twenty bags will be placed on a pallet and moved to the final warehouse area with'a forklift for shipment. PROJECT DESCRIPTION Created on 1/1/2005 9031 AM City of Santa Clarita 23920 Valencia Blvd. Phone Suite 300 (661) 259-2489 Santa Clarita Fax California 91355-2196 (661) 259.8125 Website: www.santa-clarita.com June 10, 2005 Mr. Martin Esparza Santa Clara/Mojave Rivers Ranger District Angeles National Forest 30800 Bouquet Canyon Road Saugus, CA 91350 Subject: Pacific Industrial Minerals —11554 Soledad Canyon Rd. Dear Mr. Esparza: The City of Santa Clarita has reviewed much of the materials submitted to the U. S. Forest Service for the above -referenced "Caspar" mining operation. The City finds the materials provide incomplete and contradictory information making it difficult to ascertain the specifics of the mining operation and its reclamation. For this reason, the City submitted questions to the U.S.FS. at the scoping meeting held May 26, 2005 (see attached letter). The City did not want the questions answered as part of the environmental document; rather, the City had intended to use this information in preparation of formal comments regarding the project. To this end, the City had asked that answers to the questions be provided by June 6, 2005 to allow adequate time for the City to review the answers and provide formal comments by the June 13, 2005 deadline. The City would still like to obtain the requested information prior to the preparation of the environmental document in order to fully understand and evaluate the project and provide comments about the project that can be addressed in the document. In addition to the City being unable to obtain information, in a letter from the Los Angeles County Department of Regional Planning to the Caspar mine operator, John Heter, dated May 9, 2005, the County lists four pages of additional information that is necessary before the application is complete, much less adequate to begin environmental review (see attached). The City would also like to obtain the information cited in this letter. It appears that a significant amount of information that is needed to fully evaluate this project has not been provided by the mine operator. The City fails to understand how the U.S.F.S. can begin environmental review of the project without adequate project information to fully evaluate the project's impacts on the environment. PRINTED ON RECYCLED PAPER Due to this lack of information, the comments listed below should not be considered complete, as other concerns and/or comments may be identified once the requested information is made available. Based on the information that the City has been able to obtain, the City has several concerns and comments regarding the project. These are discussed below. Environmental Document — The City has concluded that the only legitimate environmental document that must be prepared for the project is an Environmental Impact Statement under NEPA and an Environmental Impact Report under CEQA for the following reasons: • Cumulative Impacts — Regardless of any other potentially significant environmental impact that may result from the mine, the fact that the proposed mine will result in significant unavoidable cumulative impacts is grounds enough to require an EIS/EIR. In 2004, the County of Los Angeles approved CEMEX to mine 69.2 million tons of material to produce and sell 56.1 million tons of sand and gravel over a 20 -year period with annual mining levels of up to 5 million tons per year within a few hundred feet of the proposed Caspar mine. On June 22, 2004, the County Board of Supervisors certified the FEIR prepared for the CEMEX mine. The environmental document identified various significant unavoidable and immitigable impacts to air quality, visual quality, and biota for which a Statements of Overriding Consideration was adopted. Due to the fact that a Statements of Overriding Considerations was adopted for these significant impacts, any additional projects that would exacerbate or increase these impacts in significance, must be considered to have significant unavoidable cumulative impacts. In terms of air quality, the proposed Caspar mine will impact air quality through the generation of dust from truck and vehicle movements, loaders, blasting, and the processing of ore. Other air quality impacts include exhaust from trucks/equipment, generators, and other power sources. The effects of the fine powder that would result from the mining and processing of the ore must also be considered. When considering biota, the proposed mine will have potentially significant impacts. The mine proposes a bridge across the Santa Clara River. The Santa Clara River in this area is known to contain two federal endangered species: the Unarmored Threespined Stickleback and the Arroyo Toad. In addition, there is a potential for other endangered and sensitive species to occur in the area, including but not limited to: the Red -legged Frog, the Southwestern Willow Flycatcher, the Least Bells Vireo and the California Gnatcatcher. The mine proposes to disturb areas within 20 feet of two blue line streams identified by the U.S.G.S. This is an area of known endangered and listed species. Consultation under the Endangered Species Act is required for the project, along with a Biological Assessment and Biological Opinion. Given the potential for both project -induced and cumulative harm to endangered species, an EIS must be prepared. An additional potentially significant cumulative impact is to the visual quality of the canyon. The Caspar mine will result in a 250 -foot -tall, several -hundred - foot -long "scar" on the face of the mountain that will be visible from public right-of-ways. These impacts, in combination with the significant impacts to air quality, biota, and visual quality caused by the CEMEX mine, are significant cumulative impacts. In addition, the City contends in a lawsuit that the EIR/EIS prepared for the CEMEX mine failed to adequately identify and address several other significant impacts. If any portions of this EIR/EIS or its findings are used as the basis for the environmental document prepared for the Caspar mine project and the City is successful in its legal challenge of the CEMEX EIR/EIS, then the environmental document prepared for the Caspar mine may be rendered inadequate. The City recommends that an independent EIR/EIS be prepared for the proposed Caspar mine. Other cumulative potentially significant impacts include: - Traffic. The approved CEMEX mine will result in up to approximately 1,200 truck trips per day. The cumulative impacts of additional truck trips that would result from the Caspar mine must be considered to be potentially significant. - Water quality. It is unclear how runoff containing mud, stockpiled ore, and fines from both the mine site and processing site will be prevented from entering either of the two blue line streams or the Santa Clara River during a storm event. It is also unclear how much and how often water is to be trucked in and from where this water will be obtained. If it comes from local wells, then the impact of the additional draw must be evaluated. Hazardous Materials — Will fuel for the trucks, equipment, generators, etc. be stored on site? Will explosives be stored? If so, in what quantities and how will safe handling be ensured? • Other Environmental Considerations — The City has identified other potential impacts that should be considered, for instance: The plans show a 100 -foot setback from a portion of the Santa Clara River. The plan does not identify from where this setback is measured. Is it from the centerline of the river? The river's edge? The floodway? Is this setback a requirement or proposed mitigation measure? How can such a setback be guaranteed in a river that meanders? Why is this 100' setback not to be maintained on the north side of the river, especially along "Area B" where processing, storage, and other activities are proposed? Where are the limits of the floodway and 100 -year flood zone? Are any structures/improvements proposed in either of theses areas? The plan identifies a dirt road that terminates at a gate north of "Area A". Aerial photographs reveal some type of large storage compound located here. This should be identified on the plans. Though the mining plan states that the river crossing will be dedicated solely to the Caspar mining operation, it appears that the only access to this facility is through the mining operation and across the proposed bridge. If this facility is to utilize improvements associated with the mining operation, any impacts that will be created and/or increased from this facility's operations as a result of the mine's improvements must be evaluated. - The City has been unable to determine the design of the bridge. In a conversation with the mine operator, detailed plans for the bridge have not been provided. It is impossible to fully evaluate the impacts of a bridge without plans for its design. - The mining plan does not identify how the site will be mined. It shows cross sections, but provides no plan view of the mining operation, such as the mine face, ramps, slopes, elevations, etc. Other Considerations — Other considerations include the following: • According to the mining plan dated 1/27/05, the existing plant is to be replaced with a 20,000 ton per year capacity Beneficiation facility to be housed in a new 7,500 square -foot building where ore will be processed and bagged for shipment. It further states that the facility will process minerals mined from "Area A" and "other minerals mined on the Los Angeles Forest." If the facility has a maximum operating capacity of 20,000 tons per year, why is the request to mine 150,000 tons a year? Will additional facilities need to be built to accommodate more than 20,000 tons? If so, they should be shown on the plans. If not, the mine should be restricted to the amounts that can be processed. Bagging of a product should not be considered part of the mining or processing operation. This type of operation should be considered as manufacturing. Is manufacturing a permitted use in the national forest? The statement, "other minerals mined on the Los Angeles Forest" implies that the facility will be processing and bagging minerals other than anorthosite obtained from the site and other minerals from areas off site. These other minerals and other areas are not specified anywhere in the plan or project description. Any impacts created from the processing of these materials and additional trips to deliver/pick up the materials to/from the site must be identified and evaluated. • It was indicated to the City that the previous mining operation did not go out of business but was forced to shut down by the U.S.F.S. due to the mine operating outside of its permitted area. It is the City's understanding that the previous mine operator is the same operator of the proposed mine. What guarantees are there that the mine operator will not again operate outside the permit? What compliance tools will be used to bring the operator back into compliance? What penalties will be imposed should this occur? Is it common practice for the U.S.F.S. to reissue similar permits to individual/corporations who have had previous violations? • It is indicated in one of the mining plans (there appear to be several versions) that the historical level of mining at the site was about 30,000 tons since 1983. The proposed 150,000 ton limit represents a 500% increase over historical levels. The City is very concerned about such significant increases to the levels of mining that have historically operated in Soledad Canyon. Any environmental document should include analysis of an alternative which is consistent with historic levels. As should be clear from the above discussions, the mine application is substantially lacking in information. It is unclear how the mine is to operate, what facilities are proposed, how reclamation is to occur, and how the mining operation will impact the environment. The City is unable to conduct a thorough review of the project and provide comprehensive comments due to this lack of information. The requested information and clarifications would be beneficial to not only the City's review, but in the preparation of the environmental document. The validity of such an environmental document prepared without this information and clarifications would be highly questionable. Should the U.S.F.S. proceed with the preparation of the environmental document, the City concludes that, given what is known about the project, there are potentially significant impacts that would result for the mine and an EIS/EIR should be prepared. Thank you for your consideration in this matter. Should you have any questions, please feel free to contact me at (661) 255-4365 or Kai Luoma, Senior Planner, at (661)255-4330. Sincerely, Director PlaiiKng and Economic Development PB:KL:lep SAPEMCURRENMCounty Monitoring\11554 Soledad mine\USHCommentltr 6-05.doc Enclosures cc: Kenneth R. Pulskamp, City Manager Michael Murphy, Intergovernmental Relations Officer Kai Luoma, Senior Planner James Hard, Director, L. A. County Department of Regional Planning Paul Novak, Planning Deputy, 5th District Senator Barbara Boxer Senator Dianne Feinstein Congressman Howard "Buck" McKeon 15 Los Angeles County Department of Regional Planning Planning for the Challenges Ahead James E. Hartl, A1CP John C. Heter Director of Planning 16230 Sierra Hwy. Canyon Country, CA 91351 SUBJECT: FINAL REQUEST FOR REVIEW MATERIALS Project No: SMP 00-90 In our initial environmental review of your project, the Impact Analysis Section requested, in our letter dated March 22. 2005, the following, additional materials in order to complete our review. The requested materials were: Please submit a detailed project description. The description should discuss the total amount of materials to be mined, the project lifetime, the mining operation, the reclamation plan, the total number of daily truck trips associated with transporting the mined materials, the types of equipments and vehicles involved in the proposed operation, and the total amount of water to be trucked onsite per day. In addition, please explain all existing and proposed improvements for the project site. With respect to the proposed improvements, please provide the area of all proposed structures including the milling & processing building, the office, maintenance building, and the storage buildings and indicate if they will all need be constructed. 2. Indicate if all the existing buildings/structures from Area 'B" will be dismantled and removed from the project site. In addition, since a portable crusher/screen facility is proposed in Area "A", please explain the operation that will take place in the proposed milling & processing building in Area `B". 3. Your letter of 1/21/04 indicated that the proposed portable crushing/screening facility in Area "A" will only be onsite on a contract basis during mining season. Please clarify if this portable facility will be dismantled and removed from the project site during non - mining season. If yes, please indicate the months of the proposed mining season and the frequency which the portable facility will be removed from the project site per year. Finally, please explain if the portable facility will utilize a generator and how it will be powered. 4. The site plan dated 1/24/05 indicated that the topsoil will be stockpiled in Area "A". Please provide the dimensions of the proposed topsoil stockpiled area. In addition, the map also indicated a stockpile in Area `B". Please provide the dimensions of the area and indicate what will be stockpiled there. 320 West Temple Street • Los Angeles, CA 9oo12 • 213-974-6411 • Fax: 213-626-0434 • TDD: 213-617-2292 May 9, 2005 Page 2 5. Your letter of 4/28/04 indicated that the erosion control plan includes a proposed catchment basin that is plastic lined. Please state if the basin is still being proposed. If yes, it must be depicted on the site plan, 6. The notes contained in the 1/24/05 site plan indicate that a fence will encompass the site for public safety. Please clarify if the fence will be placed around the entire project site. In addition, indicate the type of fence being proposed. Again, please note that the proposed fence must be clearly identified and depicted on the site plan. 7. Provide the name and address of the disposal site where the estimated 7,500 tons of mine waste generated annually and where all waste oil generated from the project will be disposed. Also, indicate where the domestic refuse will be disposed at. 8. Indicate how the proposed generator in Area "B" will be powered. In addition, state what the proposed propane tank will be used for. Finally, please clarify if diesel fuel will be used to operate any equipments and trucks at the project site. 9. Based on the recently submitted 1/24/05 site plan, your project design has changed to include portable crusher/screen facility in Area "A" and additional storage structures in Area 'B". Therefore, please submit fifteen (15) revised site plans for consultation. Please note that the revised site plan must be corrected to indicate the proposed bridge crossing rather than a culvert crossing. Furthermore, all existing and proposed improvements must be clearly labeled as such and depicted on the site plan including any fencing. 10. Submit three copies of a focus survey for arroyo toad (Bufo californicus), willow flycatcher (Empidonax traillii), three-spined unarmored stickleback (Gaslerosteus aculeates williamsoni), San Diego horned lizard (Phrynosoma coronaium hlainvillei), two -striped garter snake (Thamnophis hammondii), Slender mariposa lily (Calochortus clavaius var. gracilis), arroyo chub (Gila orcutti), and Plummer's mariposa lily (Calochortus plummerae), Santa Ana sucker (Catostomus Santaanae) and least Bell's vireo (Vireo belhi pusillus). The focused survey should identify the biological resources onsite, the potential impacts from project design, and all proposed mitigation measures. 11. Due to the recent failure of the culvert crossing, please submit 10 copies of recent photographs of the proposed bridge crossing areas. 12. Submit 10 copies of the vegetation plan, erosion control plan, and the bridge design dated 1/05. May 9, 2005 Page 3 13. Provide detailed specifications of the proposed bridge design including the bridge span, the proposed aprons, and the dimensions and materials to be used for the footings. In addition, please describe how the footings will be installed and the total amount of disturbances that will occur as a result of the bridge construction. 14. The bridge design dated 1 /05 depicted a proposed 8 inch concrete roadway. Please indicate the distance of the proposed concrete roadway. 15. Submit a drainage concept to the Department of Public Works for their review and approval. Please contact Mr. Timothy Chen at (626) 458-4921 if you have specific questions regarding this request. 16. Submit a will serve letter from Construction Water Services, written on their official letterhead, that clearly states that they have the capacity to serve and intend to provide water service for your project. The previously submitted letter nearly stated that they have the capacity to serve but did not clearly state they will serve the proposed project once the need arise. 17. The site plan dated 1/24/05 indicated that two water tanks are proposed, one in Area "A" and one in Area "B". Please provide the capacity of the proposed water tanks. 18. Please address a]] the issues raised by the Environmental Programs Division of the Department of Public Works (DPW) in their letter of December 15, 2003 to their full satisfaction. Submit a clearance letter from the DPW with respect to the project's waste disposal program. A copy of said letter was previously sent to you for your reference. 19. Please address all the issues raised by the South Coast Air Quality Management District (AQMD) in their letter of November 25, 2003 that was previously provided to you and obtain a clearance letter from AQMD that states you have satisfied all their requirements. According to AQMD's letter of 3/23/05, your previous responses to them were unresponsive. A copy of said letter is enclosed for your reference. Please provide a copy of the clearance letter from AQMD to the Impact Analysis Section. 20. Because the previously submitted URBEMIS 2001 report is outdated, provide two copies of the URBEMIS 2002 report. Please note that the previously submitted UR13EMIS 2001 indicated that the proposed project will have significant air quality impacts with thresholds being exceeded at very high levels. In preparing the URBEMIS 2002, please make sure that all assumptions are correctly applied. May 9, 2005 Page 4 21. The 1/24/05 site plan showed that the proposed storage structures are within 100 feet of the Santa Clara River. Please explain if the proposed areas for the storage structures may be subject to flooding. Quite some time has expired since our previous letter. Although this office endeavors to complete the environmental review of your project in a timely manner, we are unable to proceed further without the stated additional materials. We are also unable to leave your case open indefinitely. We, therefore, have no choice but to give you this final notice. Please be informed that unless the stated additional review materials are submitted to this office by June 9. 2005, the file for your project will be inactivated and further processing will cease. If clarification on this matter is needed, please feel free to contact Christina Tran of the Impact Analysis Section at (213)974-6461, Monday through Thursday from 7:30 a.m. to 6:00 p.m. Our offices are closed on Fridays. Very truly yours, DEPARTMENT OF REGIONAL PLANNING James E. Hard, AICP Director of Planning rl Daryl Koutnik, Supervising Regional Planner Impact Analysis Section JEH:DLK:cdt Cc: National Forest Service Pacific Industrial Minerals, LLC City of Santa Clartta 23920 Valencia Blvd. Phone Suite 300 (661) 259.2489 Santa Clarita Fax California 91355-2196 (681) 259.8125 Website: www.santa-cladta.com May 26, 2005 Cid Morgan District Ranger Santa Clara Mojave Rivers Ranger District United States Forest Service 30800 Bouquet Canyon Road Saugus, CA 91390 Subject: Scoping Meeting Regarding Pacific Industrial Minerals' Proposed Caspar Mine on Thursday, May 26, 2005 Dear Ms. Morgan: On behalf of the City Council and the citizens of Santa Clarita, I would like to thank you for responding favorably to the City's request to hold a scoping meeting on Pacific Industrial Minerals' proposed Caspar Mine. Please accept this letter as the City's written inquiries for the public record pertaining to this proposed mining project. Your response to these inquiries will give the City a better understanding of the proposed project and help us provide comprehensive formal comments. 1. What is the historical level of mining • on the site and how was this figure calculated? How much was mined every year over the previous. ten years of mining? How much was actually sold? 2. What were the annual mining/processing amounts, number of truck trips and water use for each of the ten last years the mine was in operation? 3. How much a �ining/processing is anticipated per year during the first year, the first five years, years 5-10, and the anticipated annual maximum over the life of the proj ect7 4. What is the anticipated life of the project? At what points over the anticipated life is re -permitting required? 5. What peratits/approvals are being sought from which agencies under both the CEQA and NEPA processes? Please supply a complete list of all the permits required and how long each permit will be good for and the agency that will issue the permit? 6. How are the CEQA/NEPA processes being coordinated? Is a joint EIS/E1R being prepared? 7. Has consultation begun with any of the applicable resource agencies? Given plans to construct a bridge in a stretch of the Santa Clara River containing both the federal endangered Unarmored Threespine Stickleback and the Arroyo Toad, we would anticipate that formal consultation under the endangered species act will be required? Has that process started? 8. Will the Forest Service require completion of both the CEQA and NEPA processes and approval by both the County and Forest Service before mining re -starts? Scoping Meeting Inquiries May 26, 2005 Page 2 of 2 9. Has the SMARA Plan been completed and if so, can the City get a copy? If not, when is completion anticipated? 10. Where will project water come from? How much water will be used on a monthly and annual basis? If water is trucked in, will these additional truck trips be incorporated into the traffic study and project description? 11. What is the proposed bridge design? Has the bridge been designed in consultation with the resource agencies (i.e. Fish and Game and USFWS)? Will the proposed bridge be evaluated as part of the overall project? 12. Who are the likely customers for the mining product and how far is the product anticipated to be trucked and to where? 13. When do you anticipate that the Draft EIS/EIR will be available for public review? 14. What are the health impacts of anorthosite? In order to facilitate more thoughtful comments regarding the proposed mine, we respectfully request that responses to the above inquiries be provided by June 6, 2005. Again, thank you in advanced for your responsiveness. If you should have any questions, please feel free to contact Michael Murphy, Intergovernmental Relations Officer at 661-255-4384. Sincerely, /// Kenneth R. Pulskamp City Manager KP:TH s:ped/tina/casparminequestions.doc cc: Mayor Smyth and City Council Members Michael Murphy, Intergovernmental Relati,)ns Officer Kai Luoma, Senior Planner Tina Haddad, Management Analyst Sue O'Carroll, Willdan Associates