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MINE ID # OR PROSPECTING ID#: M-1977-348 PAGE: 4 <br />INSPECTION DATE: 10-28-04 INSPECTOR'S INITIALS: ACS <br />degrees. Ditching and furrowing to prevent concentration of <br />snowmelt and rainwater flowing down the slope can enhance the <br />stability of cover fill. Adequate rooting zone for revegetation <br />is best provided by placement of sufficient thickness of mine <br />spoil cover over the bedrock surface followed by placement of a <br />relatively thinner layer of plant growth medium, either from the <br />topsoil stockpiles that were established during mining, or from <br />suitable soil imported to the site. Plant growth medium should <br />be tested to determine fertilization requirements (note that this <br />type of testing is a commitment provided in the original permit <br />application filed in 1977). <br />7. Permit amendment AM-O1 brought most of the pre-law spoil piles <br />and spoil ridges inside the permit boundary. The purpose of this <br />permitting action was to make the pre-law material available for <br />use in reclamation. This material is suitable as backfill to <br />create reclamation contours amenable to the application of <br />topsoil or other suitable plant growth medium and the <br />establishment of vegetation. The approved permit boundaries are <br />depicted on the following maps contained in the DMG file that <br />show the pre-law spoil piles that are inside the permit: <br />a. Map no. bcc-1356, date stamped 1/19/93, labeled "PERMIT <br />BOUNDARIES," sheet 1 of 6. <br />b. Map no. bcc-1357, date stamped 1/19/93, labeled "PERMIT <br />BOUNDARIES," sheet 2 of 6. <br />c. Map no. bcc-1358, date stamped 1/19/93, labeled "PERMIT <br />BOUNDARIES," sheet 3 of 6. <br />d. Map no. bcc-1359, date stamped 1/19/93, labeled "PERMIT <br />BOUNDARIES," sheet 4 of 6. <br />e. Map no. bcc-1360, date stamped 10/20/92, labeled "PERMIT <br />BOUNDARIES," sheet 5 of 6. <br />f. Map no. bcc-1361, date stamped 10/20/92, labeled "MINING <br />PLAN," sheet 6 of 6. <br />DMG cannot require reclamation of pre-law spoils and other pre- <br />law disturbed acreage, even if it is included in the permit <br />boundary, unless reclamation operations dictate their re- <br />disturbance. Holcim expresses this regulatory principle in the <br />amendment AM-O1 application as follows. "Areas disturbed prior <br />to 7-1-76 are included within the permit boundary but will not be <br />bonded until operations or reclamation dictates their re- <br />disturbance. Pre-law areas within the permit boundary that are <br />not re-disturbed will be neither bonded nor reclaimed." Of <br />course, this statement also expresses the necessity of adjusting <br />the bonded acreage and the amount of reclamation bond prior to <br />accessing the pre-law spoils to obtain reclamation fill. See <br />item 10 below. <br />8. The following typical reclamation requirements are described in <br />the permit: <br />a. Where ample overburden is available, highwalls will be <br />