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route is best to go with approval of this operation. This would either be a minor or major <br />amendment to the Use by Special Review. This meeting will take place on 10- 30 -14. If the <br />process requires a major amendment, then that will entail public hearings and that process <br />will likely go into the early part of 2015, after the corrective action due date required by the <br />DRMS of 12- 31 -14. We are reviewing the DRMS request to stop the present importation and <br />processing of the materials at this time. We are also considering the process by which we <br />could remove the site of recycling from the DRMS permit area. This location has been <br />backfilled and so could potentially be released from further reclamation requirements and <br />bonding. We would like an initial response to this request. <br />3. Processing Waste: The corrective action due date for this topic is 10- 31 -14. The trash and <br />refuse that you noted in your inspection and photographed (Photo 3) was inadvertently <br />brought to this site from one of our paving operations from clean -up of a project. It was never <br />intended to stay at this site and has been removed to a proper dump site. The other location <br />for what you have termed refuse and scrap (Photo 4) it not refuse or scrap at all but simply <br />spare parts and equipment for gravel mining processing. These are not scrap materials or <br />garbage and are to be re -used on this site shortly. Some of this equipment is remnants of our <br />fixed gravel plant. We now use portable equipment; however, we will be resurrecting the <br />wash plant portion from the fixed plant this winter and the associated conveyors, piping and <br />hoppers to wash gravel. In fact, this area will be cleaned -up shortly and re- organized in order <br />to re -mine this area due to the flooding of September 2013 as I noted to you during the <br />inspection. Please see Attachment 2 for further photos and descriptions of this equipment. <br />4. Revegatation (of shale stockpiles): The corrective action due date for this topic is 11- 28 -14. <br />As part of the approval for the amendment for this site, grading and erosion control with <br />seeding of the shale stockpiles is required. Other erosion control options were looked at, but <br />re- vegetation of the slopes of these piles was the best option. ASCI has since got a second <br />opinion and are working on costs from another reclamation/seeding company, but it appears <br />that the best route to go on seeding of these stockpiles is to wait until early spring (mid -April <br />or later depending on ground temps) to do this work. We realize that we were remiss in not <br />doing this seeding earlier after approval of the amendment, but be that as it may. We are <br />most concerned with making sure that the hydroseeding on this fairly sterile material works <br />as well as it can, given the cost of the project. In other words, we need to give the seed its <br />best possible chance for germination and to take root under the best conditions we can <br />supply. <br />Our reasoning is as follows: <br />• Before we hydroseed the piles of shale, we will grade them out to lessen the slopes, <br />remove the dead weeds and break up large chunks of some of the hardened shale. <br />This action will de- stabilize the crust that has formed on the shale and re- expose fine <br />particles which will even be more ground -up due to the action of the dozer treads. <br />New particles of shale will be exposed to winnowing by the wind. <br />• Winter winds across this flat valley area are strong and unobstructed until they hit <br />these shale piles. They are also more sustained in the winter lasting sometimes many <br />days. <br />