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PERMIT #: M-1981-121 <br />INSPECTOR'S INITIALS: TC1 <br />INSPECTION DATE: March 18, 2015 <br />Environmental — No noxious weeds or exposed groundwater were observed. Some erosion rilling was observed <br />in the haul road (see Photo 5) and in the aforementioned steeper highwalls. <br />Records: <br />• Revisions: Surety Increase (51-01) was approved in 1993 to increase the financial warranty to its current <br />value of $3,750 (it should be noted that this amount was based on a 1.5 -acre active mining area: 660 ft <br />x 100ft). Two Succession of Operator (permit transfers): one (SO -01) approved in 1998 and the second <br />(S0-02) to the current Operator in February 2005. <br />• Commitments/Stipulations: None. <br />• Other Records <br />a) Permit Boundary — The approved permit boundary is a 660 ft x 660 ft square offset 200 ft from the <br />section line to the south and to the west (see Figure 2) <br />b) The total permitted area is 9.9 acres. The Division's disturbed area estimate is approximately 6.6 <br />acres. Only about 2.5 acres of disturbance is within the approved permit boundary. <br />c) Previous inspections — The last inspection was performed on 10/5/2010. A lack of permit sign was <br />cited as a problem. The 2006 inspection indicated that all disturbance at that time occurred prior to <br />the permit issuance (1981). However, historical Google Earth images indicate some new <br />disturbances occurred between 1999 and 2004. <br />d) Historical disturbance — The original permit application does not appear to directly address pre -law <br />or pre -permit disturbance. However, the permit application contains references to mineral <br />investigations on site and a petition to El Paso County to approve mining activities, both in 1973 (pre - <br />law). The 1999 Google Earth image (the oldest available) indicates a majority of the southern portion <br />of the pit, which is outside the approved permit boundary, existed in 1999. <br />e) Annual reports — The anniversary date is July 23. Annual reports and fees are current through 2015. <br />Recent annual reports show a more rectangular permit boundary (2014) and an average 700 ft x 300 <br />ft disturbance (2015). It is unclear when this boundary change occurred, or if it was approved by the <br />Division. <br />f) The post -mine land use is general agriculture. <br />Bond: <br />The current bond is inadequate for 9.9 acres of approved affected area. The financial warranty was last updated <br />in 1993 (Sl -01). The current estimated disturbance is 6.63 acres. The enclosed updated financial warranty <br />estimate reflects that disturbance. Unless the Operator can demonstrate an error in the enclosed estimate or <br />has performed additional reclamation activity since the April inspection, the Division will require the additional <br />bond ($13,820) be posted. A separate surety increase letter will be sent to the Operator within 60 days of this <br />report. <br />Summary and Recommendations: <br />1. The Division observed some disturbance outside the approved permit boundary. The records are unclear as <br />to how much of this disturbance is pre -permit issuance and how much was created by the current Operator <br />(after the 2005 permit transfer). If the operator wishes to continue mining this site, a Technical Revision <br />should be requested to clarify pre- and post- permit issuance disturbance to the extent possible. This TR <br />should also clarify the permit boundary. <br />2. The Division may require structures agreements for McClelland Road, and other structures (fences, utilities, <br />etc.) within 200 ft of the pit extents depending on pre- and post -mine disturbance demonstrations discussed <br />in Item 1 above. <br />Page 3 of 7 <br />