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(Page 21 MINE ID JJ OR PROSPECTING ID # M-1978-305 INSPECTION DATE 1/23/01 INSPECTOR'S INITIALS RCO OBSERVATIONS This was a partial inspection of a Construction Materials 112 permit, performed by the Division due to a request by the operator for more accurate reclamation cost estimate figures. The operator was contacted about the inspection and a time was arranged to meet at the site. The operator named on page one was present throughout the inspection. There was about a foot of snow cover, but it was not enough to prevent the pertinent inspection topics from being adequately inspected. This permit was recently converted to a 112 permit, whose first phase initially expands its acreage but changes the mining and reclamation plans only minimally. The second phase will be initiated only after complying with the several stipulations that were made part of the conversion approval. No disturbances under this permit have been carried out yet in the 112 area. The expansion of mining disturbance requires that the financial warranty is increased. The operator questioned the amount of the first financial warranty increase estimate. It was pointed out to the operator that even without this conversion, the site is underbonded and would require a financial warranty increase. It must be made clear that the conversion will not become final until the submittal of the bond increase: no disturbances are to occur beyond the original 110 boundaries without the increased bond being provided. Observations made during the inspection included location verification of the permit boundary locations and first phase boundary locations, and assessing the types of existing and proposed disturbance to the area. Little final reclamation can be performed in Phase 1 until the end of mining has been reached, due to limitations of the site. Saving the reclamation until the end of the phase contributes to a high bond. The operator is urged to ensure that all permit boundaries and phase boundaries are adequately marked this spring (accurately placed and visible markers are required, no lath pleasel. Disturbances which exist and that are to be created or increased as operations continue toward the end of Phase 1 include: a steep highwall of decomposed granite, which will be reduced to 2:1; a powerpole on a pinnacle, which will be moved to a stable final location; piled overburden to be pushed against the reduced highwall toe; a compacted pit floor, which will be loosened for later revegetation; topsoil presently stockpiled and to be stripped in newly added areas; debris, equipment and portable structures to be removed. Some of the upper slopes appear to now be adequately graded to 2:1. The operator indicated numerous items removed during recent clean-up activities, which will be accounted for in reduced clean-up task costs. Some remaining items require hauling and disposal costs, some require only hauling offsite with salvage allowed (no disposal costl. Stockpiled pitrun, processed product, oversized material and topsoil do not carry removal or handling costs in the bond estimate. However, overburden and topsoil handling costs must be part of the bond estimate, since they are part of the slope reduction and seedbed preparation portions of the reclamation. Since the approved final slope gradient is 2:1, some of the reclamation tasks to be carried out there require that they be performed manually, which carries a higher unit cost than the unit costs for mechanized tasks which may be carried out on gentler terrain. The basis of the Division's unit costs and equipment use was discussed with the operator. On the southern edge of the disturbed area is a steep slope which was excavated by the former operator under this permit. The slope is steeper than the approved final gradient, is crossed by old roadways, is not revegetated, and is not stable or reclaimed. The operator stated that he did not think it was his responsibility to reclaim it. He additionally stated that the Park Service was satisfied with its condition and would prefer that the slope not be reclaimed. The slope may not have been redisturbed by the present operator, after the permit was transferred to him, but its reclamation is his responsibility. The present operator did not apply for a new permit, which was not to include liability for past disturbances by former operators. This was a permit transfer, and requires that the successor operator assume liability for all existing mining- related disturbance. There is nothing in the file showing that the Park Service is satisfied with that portion, nor any specific exemption of that portion from further reclamation, nor any evidence of that portion's long-term stability. Reclamation costs of that area must remain in the bond amount. Several other details of the reclamation were discussed. It was agreed that blasting for highwall reduction would not be necessary, though extensive ripping and dozing will be required. A recently submitted map from the operator appears to show that the 1.25 acres in the northeast corner of the 3.16-acre permit is included in Phase 1 . The map is incorrect, and