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Page 2 <br />October 11, 1991 <br />Inspection report <br />File no.: M-73-007 <br />As I have pointed out to the agency, both when I was there and over the <br />last twelve years as a consultant, the amendment process contains a <br />defect in that it is difficult for your agency AND for the operator to <br />know exactly what was changed in the permit and what was not. Once <br />again I wish to state for the record that large scale amendments should <br />be done as total permit rewrites rather than the usual process of <br />modifying only certain portions of the permit and leaving other portions <br />unchanged. In some cases, it becomes almost impossible to track what <br />was changed and what was not, especially if the original parties <br />involved in the amendment are no longer available or can't recall <br />exactly what was done. <br />Following are comments that address, point by point, your inspection <br />report. Reference to the 1985 amendment are made where applicable. <br />Page 1-2: You state "The permit covers a total of 110 acres. Forty <br />acres located east of Academy Blvd and seventy acres west of the Blvd." <br />RESPONSE: We have been unable to determine exactly where you <br />obtained these figures, but it appears they came from the last annual <br />report. Those figures represent the area of disturbance in the <br />operation as of that report date and not the permit area. The permit <br />area was increased in the 1985 amendment to 325.6 acres. <br />Page 1-2: You estimate approximately 3 million cubic yards of material <br />to be present on the site during the inspection. <br />RESPONSE: This figure is, in our opinion, far too high to be even <br />a reasonable estimate. First, your estimate does not seem to be <br />substantiated by any measurements. Second, considering this operation <br />only produces about 150,000 cubic yards of material in an excellent <br />year, having 3 million cubic yards on the ground would not only be <br />difficult to achieve but would be especially bad business practices. <br />Third, we wish to point out that the Castle Concrete Sand Pit connected <br />to the north of this site contained only about 3.6 million cubic yards <br />of sand. That operation mined to a depth of about 90 feet over an area <br />of about 25 acres. So, the volume you are stating is sufficient to fill <br />a hole with 25 acres surface area and about 75 feet deep. We seriously <br />doubt that much material could be found on this site even if all product <br />stockpiles, soil stockpiles, overburden stockpiles, and active settling <br />ponds were combined into one mass. Perhaps you meant 3 million cubic <br />feet. If you divided 3 million cubic feet by 27 to produce cubic yards <br />the roughly 110,000 cubic yards calculated in that way would certainly <br />be more in line with what is there. <br />