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\ _ _ _ __ III III III IIIIIII III (Page 2) MINE ID ~ OR PROSPECTING ID ~ N-80-110 INSPECTION DATE 12-10-93 INSPECTOR'S INITIALS ACS OBSERVATIONS The permit for the Henderson Development/Sandy Acres Pit is held by Colorado Sand and Gravel. The pit is being operated by Cooley Sand and Gravel under contract to the permittee. This operation was active at the time of this inspection, with portable crushing, screening and washing plants active. Gravel ie mined from a wet pit using a drag-line. several loaders were in operation at the site for loading trucks and other earth-moving operations. There are no permanent structures on the site, i.e. all equipment and buildings are portable. The required entrance signs have been posted, and the permit boundaries are marked with a chain-link fence. The pit at the south end of the property has been reclaimed - it remains for the permittee to conduct proper maintenance of the re-vegetation effort (e.g. weed control, soil amendments, over-seeding) in order to gain release for the southern pond. The entire north portion of the permit area has been disturbed. Sufficient topsoil for reclamation has been stockpiled along three aides of the pit perimeter. Gravel has been mined below the water table to a depth of 20-25 feet, as a result, much of the disturbed area is a temporary gravel lake. Wash water ie pumped from a pond at the south end of the disturbed area, and discharged to the gravel lake to the north. The operator has stockpiled concrete rubble trucked in from a variety of sites at the east edge of the disturbed area. Under their MLRB permit, the operator ie permitted to utilize clean fill from off-site to back-fill the pit, however, the operator ie required to be in compliance with all other agencies having jurisdiction over land-filling. At this time, no off-site materials have been placed below the water table. In accordance with the 1987 amendment to this permit, the approved reclamation plan for the north part of the permit area (Sandy Acres) ie back-filling to grade, topsoil replacement and re-vegetation. Given that very little back-filling has been accomplished to date, and that it is estimated that 1.5 million yards or more of material would be required to completely back-fill the mined out pit, it is apparent the current $92,370.00 bond would be inadequate for the state to reclaim the pit in accordance with the approved plan. There is also a difficulty ae to how the state could provide inert fill for back-filling of the pit in the event of permit revocation and bond forfeiture. Aa discussed during the inspection, there are two ways to rectify the inadequate bonding for this site: 1. The operator could poet a bond that would be adequate to allow the state to contract for back-filling of the pit. If the operator chooses this option, an estimation of the costa that would be incurred by the et ate should be prepared by the operator for Division review. The estimate must consider likely sources for back-fill material, and anticipated costa to comply with regulations pertinent to placement of the fill. The operator could submit a technical revision to the permit which would incorporate an alternative reclamation plan to be followed by the state in the event of permit revocation. An alternative reclamation plan to leave a pond on the property would be logistically simpler, and would result in a much lower bonding requirement. If the operator elects to submit a technical revision to incorporate an alternative plan, a reclamation coat estimate for the proposed alternative reclamation, ae well as a demonstration of adequate water rights to account for evaporative loos, must be included as part of the submittal.