2015-05-11_INSPECTION - C1981018 (2)

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DRMS and OSMRE inspectors agreed that Deserado does need to demonstrate (and DRMS to approve) topsoil protection measures that provide equal protection to seeding or planting quick - growing annual or perennial plants at SAES. Because no damage or loss of the topsoil resource was observed during this inspection, this situation does not warrant a notice of violation. This will be noted as a permit maintenance item and must be addressed in a reasonable timeframe. Borehole Sealing (Rule 4.07) The Team evaluated each sample borehole to determine whether applicable permanent and temporary sealing requirements were met. These results are discussed in further detail in the Evaluation Year 2016 GVB topic specific evaluation reports. The majority of reclaimed sample GVBs exhibited casing heights within 36" above surface grade, as outlined in the approved permit. The only exceptions were those casings which had been terminated within 36" below surface grade. These GVBs would still technically be in compliance with the approved permit, which states, "Surface casing or metal pipe to within 3 feet of the ground surface" (p. V -20); however, field verification of these subsurface terminations, without creating additional disturbance, was not possible. Field verification of the integrity with which these GVBs were permanently sealed and marked was likewise limited. All boreholes will need to be located and properly marked prior to bond release. The only temporarily sealed GVB, LW 1 -8, stood approximately 5 feet tall and utilized a flame arrester with safety valve as protection for surface and groundwater; people, livestock; fish and wildlife; and machinery, in accordance with 4.07.1 (1) and 4.07.2. This GVB did not discharge mine gas when Mr. Wanstedt opened the valve. This temporary seal was maintained as a bleeder in case the mine filled with water and pressure needed to be released. The mine is now filled with water and it appears as though this bleeder is no longer necessary and could be reclaimed. The data in Deserado Mine's comprehensive drill hole Abandonment Report, dated 4/17/2015, correspond with all sample GVBs observed onsite, in accordance with 4.07.3(3). Maintenance items identified during inspection; As the Team did not inspect all GVBs at Deserado Mine, this maintenance list is not intended to be inclusive. These items do not present a danger to land and water resources, people, machinery, or wildlife, but will need to be addressed prior to bond release. • The alternative protection measure of using salvaged remnant vegetative material to stabilize topsoil stockpiles at SAEs must be expressly demonstrated 51Page