2016-04-01_INSPECTION - M2012016

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PERMIT #: M-2012-016 INSPECTOR’S INITIALS: ACY INSPECTION DATE: March 22, 2016 Page 3 of 11 approved plans. Option 2: by July 1, 2016 submit a new 112c permit application with commercial/industrial as post mining land use. Slopes may be worked upon permit approval to match the new permits reclamation requirements if necessary. The Division request that by Friday, May 06, 2016 we are notified in writing of which option Puckett Land Company will use to resolve this matter. The reclamation plan also states that if necessary weed free hay or straw mulch will be applied at 2 tons/acre and crimped 1-2” into place. Likewise fertilizers or soil amendments may also be necessary. If fertilizer is applied it shall be 40 lbs. of Nitrogen and 20 lbs. of Phosphorus. To improve soil texture, manure with 60% by weight of large chunks was recommended, no powder amendments. To date only grading and drill seeding has been implemented. Given the lack of native vegetation establishment, aggressive weed management is also recommended to prevent weed establishment from hindering revegetation success. Hard alkali soil patches were observed. To some extent this is natural but from field observations it was apparent that there is a lack of quality topsoil material which is also hindering revegetation success. The operator would likely benefit from fertilizer, soil amendments or additional top soil being brought in. Also mulching after seeding will help hold in the moisture and provide a more conducive environment for germination. Based on staff observations these additional steps are necessary to achieve the approved rangeland post mining land use. Staff also explained that it’s the Divisions policy that reclamation needs a minimum of 2 growing seasons before it can be evaluated for release. This helps the Division ensure that vegetation is sustainable. In some cases vegetation may be deemed adequate sooner or in arid or challenging areas it may require more time. This site has proved challenging and successful reclamation will likely take several years to achieve. Areas south of the power lines to the Hwy 6 fence have adequate vegetation density at this time. Some weeds were observed but no significant infestations. The Division would like re-evaluate vegetation later this spring once more plants have had time to germinate. This will ensure that established vegetation is diverse and can be better evaluated for sustainability. The majority of the inspection entailed discussions of options moving forward towards releasing the site. St aff gave suggestions as mentioned above, of potential ways to improve reclamation success. Any minor deviations from the approved reclamation plan will require a technical revision (TR) prior to implementing. The fee associated with a TR is $216.00 and several minor changes can all be made under one TR request. Additionally an operator may only make changes defined under Rule 1.1(49). Changing post mining land use may not be done under a TR. The process of making this change was outlined in the January 20 15 inspection report. The operator was notified that according to Rule 1.10.2, no amendments are allowed by State Statute for a Special Operation 111 permit. The result is that the Operator must submit a new permit as a 112(c) application. The fee associated with the new permit application is $2,696.00. Much of the permit application exhibits can be used from the original 111 permit application, but re-submitted in the new application package. One idea that was discussed is to do a partial acreage release of land with successful reclamation. Then obtain a new 112c permit to overlap the existing unreleased portion of the 111c permit. T he post mine land use would be commercial/industrial and shall comply with Rule 3. Once land is stabilized the operator may request a full release to close out the permit. The operators end goal for this location is to become a truck stop. This will require proof of county review and zoning issues prior to release.