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~ • , • (Page 2) • MINE ID # OR PROSPECTING ID # M-77-436 INSPECTION DATE_August 28, 1998 INSPECTOR'S INITIALS TAS OBSERVATIONS 1. R site inspection was made to continue with measurements necessary to calculate a current reclamation cost. Present during the inspection was Mr. Dave Hammer. The primary focus of the inspection was the current size and condition of the pit, the status of the concrete storage in Parcel E, and the re-verification of the number of loads of non-roadable mining equipment to be removed during final reclamation. Measurements listed below are based on measurementsiobservations made during the August 28, 1998 and March 25, 1998 field inspections by the Division, the June 24, 1998 aerial inspection by the Division, and the May 20, 1993 boundary survey. 2. Mining disturbances shown on the May 20, 1993 boundary survey were compared with disturbances noted in the recent June 24, 1998 aerial photographs and were revised to reflect current site conditions. Based upon the revised map of mining disturbances and observations noted during the inspection the Division estimates the existing pit to be approximately 32 acres in size with 4800 linear feet of shoreline and 7 acres of pit slopes to reclaim. There is also 5 Acre-Feet of finish grading required in the center of the pit as the operator has left spoil piles ungraded. Approximately 1,700 linear feet of east pit slope has been graded to a 3:1 slope and topsoiled. The remainder of the pit walls will need to be regraded to a 3:1 slope, topsoiled, and revegetated. Other measurements made which will be verified during a follow-up field inspection include 30.7 acres to rip and scarify prior to topsoil reapplication and 37.7 acres to revegetate. Remaining volumes of overburden and topsoil stockpiles will be verified during a follow-up field inspection. This inspector estimates that the operator has already reapplied 4,500 cubic yards of salvaged topsoil along the east pit slope. Copies of the revised map of current mining disturbances and aerial photographs taken on June 24, 1998 are included with this inspection report. 3. Approximately 1, 100 linear feet of east pit slope has been graded to a 3:1 slope, topsoiled, and seeded with an interim seed mix. There was significant gully erosion noted in 5 portions of the slope. This erosion is noted as a problem and will need to be repaired prior to financial warranty release. The Division will include a specific cost for regrading the eroded areas in the total reclamation cost of the site. Please see page 3 for details. 4. The water management system used by the operator at the Tower Pit #1 includes pit dewatering and returning groundwater inflows to the South Platte River. Review of the mine plan indicates that the pit is to be operated as a "wet pit" with no dewatering allowed. Therefore, the current dewatering practices are not in compliance with the mine plan. This matter is considered to be a problem that will require corrective actions. Please see page 3 for details. Also, the operator is advised to consult with the Office of the State Engineer prior to any further dewatering to determine if a dewatering well permit is needed. 5, The June 24, 1996 aerial photographs indicate that water is used in the processing of the sand and gravel ore and that the process water is routed through a canal along the west side and north side of the pit and then discharged to the South Platte Water. Mr. Hammer indicated previously on March 25, 1998 that D.H. Holding, Inc. applied for an NPDES Water Discharge Permit for this site 3 years ago. However, there is no evidence in the permit file that such an NPDES Permit has been issued. A discussion with Tom Boyce of the Water Quality Control Division on September 10, 1998 does not indicate that an NPDES Permit has been issued to D.H. Holding, Inc. or Hammer Companies, Int. Any correspondance verifying that an NPDES