INSPEC26227 - Laserfiche WebLink

Home Browse Search

Page 5 October 11, 1991 Inspection report File no.: M-73-007 The inspection date was 9-19-91; the report was post marked on 10-5-91. COMMENT: Rule 8.1(5)(c) states "Within ten (10) days (note: this refers to the date of inspection) is mailed to or filed at: (i.) The Mined Land Reclamation Division; and (ii) The mine office, or other suitable location designated by the operator." We recognize that your staff is short handed and under a hiring freeze, but we also want to point out that this rule is there for a purpose, namely, to notify the operator in a timely fashion about the results of an inspection. Unfortunately, the rule has not been complied with in this instance or other instances we are familiar with. We recommend the Division follow this rule and possibly develop a new procedure for preparing and sending out inspection reports. When problems are noted in the inspection report there are often deadlines that must be met to avoid a violation. If the operator is not informed exactly of what is expected in a timely fashion it can be difficult for him to meet pour deadlines. If he is expected to correct a problem a month after the inspection, but it takes two weeks to be informed exactly of the nature of the problem and what is expected, effectively his time to correct the problem is reduced to two weeks. It is suggested that deadlines for correction, if stated in the inspection report, be based upon the date the inspection report is sent to the operator and not the date the inspection is performed. RESPONSES TO PROBLEMS NOTED ON PAGE 3 OF INSPECTION Problem 1: The statement that the permit requires reclamation of a minimum of 2 acres per year is in error. The current permit does not require that. Transit Mix Concrete will conduct the reclamation in accordance with the permitted plan. Problem 2: The statement that topsoil stockpiles are eroding away is not exactly correct. Most topsoil stockpiles show little erosion and are covered with some kind of vegetation, although i[ is admitted the growth is mostly dense weeds. Nevertheless, it has been well documented that weeds can provide an important function in protecting soils and this is one of the functions of weedy species in the early stages of the natural successional process leading to a more permanent vegetation. In fact, it is our understanding that a reclamation plan for one of the oil shale operations actually encourages weed growth prior to seeding with more permanent species. Furthermore, where any erosion is occurring the soil is being deposited on land that will be topsoiled and revegetated anyway. However, because there is a requirement to protect topsoil stockpiles, Transit Mix agrees to take action to seed those stockpiles that will not be utilized this winter.