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April 23, 2015 C- 1981 - 018 /Deserado Mine ZTT <br />LW137 -1 vegetation vs. undisturbed vegetation. <br />SIGNS AND MARKERS — Rule 4.02: <br />The majority of the reclaimed drill holes were found with markers. Other sites were either buried and were <br />unable to locate the marker or the concrete had degraded with the marker in need of being reestablished. <br />Markers were not located on pad sites LWB 10 -1 and LWB 12-3. <br />All topsoil piles associated with the drill pad sites were properly marked and designated. <br />TOPSOIL — Rule 4.06 <br />Removal 4.06.2; Substitute Materials 4.06.4(4); Storage and Protection 4.06.3; Redistribution 4.06.4: <br />Topsoil is salvaged prior to disturbance and drilling. It is stripped in a manner that forms a berm on one side of <br />the pad to minimized erosion and to leave preexisting vegetation to help reduce compaction, maintain <br />biological activity and increase protection from the environment. <br />All topsoil piles inspected were stable with no visible signs of topsoil loss, erosion or instability. The only pile <br />inspected that had limited and sparse vegetation was the topsoil pile related to degas pad LWB 13 -1. The pile <br />was recently disturbed for reclamation of the remaining pad. The topsoil left is for the small surrounding area <br />related to the degas pipe only. The LWB 13 -1 pad was reclaimed and its associated topsoil pill was disturbed in <br />the fall of 2014. The area including the topsoil pile has been reseeded. Due to the recent activity of the topsoil <br />pile, vegetation has yet to establish itself however, the pile is stable and no signs of soil loss were observed. <br />It has come to the Division's attention that there is limited text in Deserado's permit that addresses topsoil <br />salvation and protection specifically for that of SAE drill sites. The Division has already made contact with the <br />operator's primary contact relating to this issue and respectfully requests a revision to address these <br />inadequacies within the permit. <br />Number of Partial Inspection this Fiscal Year: 6 <br />Number of Complete Inspections this Fiscal Year: 3 <br />Page 8 of 9 <br />