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(Page 2) MINE xD / OR PROSPECTING ID }` M-77-247 INSPECTION DATE 8/28/95 & 8/29/95 INSPECTOR'S INITIALS TAS OBSERVATIONS 1. A comprehensive inspection was made of the Coaldale Quarry over a period of 2 days. The quarry is permitted for a disturbance of 100 acres of which 60 acres are currently undergoing reclamation. The designated poet-mining land use for the site ie wildlife habitat. The quarry has been inactive and in temporary cessation since August of 1990. Currently, Domtar has no plane for resuming active mining at the quarry and ie actively working to negotiate a Bale of the property. 2. The operator has completed the installation of all planned etormwater controls ae noted in the Division's previous inspection report of July 6, 1995. Therefore, Technical Revision No. 1 is now approved. 3. Domtar Gypsum has submitted a request for a second 5-year term of temporary cessation at the quarry. Approval of this request can only be granted by the Mine Land Reclamation Board. Accordingly, the Division has initated a review of the reclamation plan and the current coat to reclaim the site to wildlife habitat. There are several concerns which will need to be resolved in order for the Division to recommend approval of a second 5-year term to the Mine Land Reclamation Board. First, the existing $100,000 financial warranty ie not adequate to complete reclamation according to the approved plan. A rough estimate of the current reclamation cost prepared by Mr. Klco on August 23, 1995 indicated that the reclamation bond should be $400,000. An additional coat of $100,000 will need to be included to account for structural demolition and an indirect coat of 208. Therefore, the Division considers the permitted site to be significantly underbonded and will require that the operator post a properly executed financial warranty in the amount of $500,000 within 60 days. Second, the existing reclamation plan was based on regrading highwalle and steep slopes following completion of the mine plan. Since the mine plan has sot been completed there will be a significantly greater volume of highwall reduction and rough grading required to complete the existing plan. The Division will not recommend to the Board approval of a second 5-year term until Domtar has either posted an acceptable reclamation bond to complete the existing plan for establishment of wildlife habitat, which may be significantly higher than the $500,000 required within 60 days or has submitted an acceptable application for an amended reclamation plan with revised reclamation coats. The amended reclamation plan should address plane and/or techniques to be implemented to achieve stable highwalle and elopes within the permitted area, structural demolition for all facilities, revegetation of all barren mine benches, and final measures needed to complete revegetation of all waste dumps. The amended reclamation plan should include current maps of the disturbed area and maps showing the desired reclaimed topography. Croea sectional diagrams of the highwall areas, mine benches, and other steep slopes should be provided. 4. The Division dose not consider highwalle with an exposed veneer of gypsum to be stable and acceptable for final reclamation. However, the underlying shale contact is significantly more resistant to weathering and may be acceptable for a final configuration. Domtar should provide a narrative of the geologic strata and elope of each highwall to be left in place and a predicted factor of safety to be achieved. 5. Domtar also has the option of beginning permanent reclamation of the quarry according to the approved plan within 60 days and thereby forgoing the second 5-year term of temporary cessation. It should be emphasized that the Division will still require Domtar to poet an acceptable financial warranty in the amount of $500,000 within 60 days if this option ie chosen. 6. Throughout the inspection Mr. Klco discussed various options for reclamation of highwalle and steep elopes in the Gold Hill, senators Hill, and Copper Hill areas ae well ae the main haul road corridor. Discussions were also held regarding reclamation of mine bench areas to wildlife habitat. The mine benches are comprised predominantly of gypsum and obviously will not be suitable ae a seedbed for revegetation. A suitable plant growth medium of at least 12 inches will be needed in order to reclaim the benches to wildlife habitat. Revegetation success of the existing waste dumps was also evaluated. A significant portion of the Gillespie Hill waste dump is ready for financial warranty release. The Titanium Hill fines dump and the Senators Hill dump and Gold Hill (North) waste dumps have been graded and seeded but only contain 1/2 the vegetative cover and composition necessary for final bond release.