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Page 4 <br />October 11, 1991 <br />Inspection report <br />File no.: M-73-007 <br />Castle Concrete and not Transit Mix Concrete. Transit Mix has an <br />agreement with Castle Concrete, their sister company (both companies are <br />owned by Continental Materials in Chicago), that they can utilize [he <br />site as a settling pond area and complete the reclamation of the site in <br />accordance with the permit. This cooperative effort was a key element <br />of the 1985 amendment to both of these permits. <br />Page 2-2: You state that the reclamation plan includes 66.1 acres that <br />was mined out before the act and the 8 acres included in the old permit <br />to be reclaimed in 10 years from 7-7-80. <br />RESPONSE: The acreages stated here have came from the now replaced <br />1980 permit document. The new plan includes all these acreages, a new <br />phasing process, and a new sequence. Therefore, all the previous <br />statements were replaced because it was recognized in 1985 that they <br />simply did not work. Furthermore, there is no differentiation between <br />pre-law and post-law disturbed land in the current permit. <br />A review of the current permit clearly shows that the 1985 <br />amendment was intended to virtually replace the previous document. On <br />Page 2 - 2 of the Introduction to the 1985 amendment it states "Most of <br />the materials in the original permit will be replaced with new <br />information included in this amendment." Further on in the same <br />paragraph it states, "In many respects, the amendment constitutes a <br />permit rewrite, not so much because the permit must be rewritten, but <br />that the amendment is large enough that it is simply easier and less <br />expensive to rewrite than to modify. A few of the minor exhibits will <br />be carried over intact from the original permit as no changes are <br />necessary in those exhibits." <br />Page 2-2: You state the reclamation plan called for 2-3 acres to be <br />reclaimed per year. You also stated that no reclamation work was <br />observed on site. <br />RESPONSE: Once again, this 2 to 3 acres of reclamation per year is <br />from a plan that was replaced in 1985. The 1985 plan makes no <br />commitment to a set number of acres per year. This was a result of <br />recognizing how this operation functions. The lack of commitment to a <br />set number of acres was not questioned in the adequacy review and was <br />approved by the Board. <br />As far as no reclamation work observed, we wish to paint out that 3 <br />acres have been revegetated, at least 5 acres final graded, and at this <br />poin[ at least 25 acres completed with backfilling with several more <br />acres in the process of being backfilled, not counting the approximately <br />10 acres being backfilled in the Castle Concrete Sand Pit which is, in <br />essence, an integral part of the overall reclamation plan for both of <br />these mines. <br />