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continue to make no sense, aze not required by the ahemative practice and, as such aze not <br />generally performed. <br />There is, however, one exception. Over the years, should a particular pile be located in <br />close proximity to potential mine activides(most are not), it often makes sense to place a sign and <br />on a number of occasions we have indeed done so. Similarly, although not required, over the <br />yeazs we have also placed signs on reclaimed areas warning personnel to stay away from seeded <br />azeas. Placing additional signs where appropriate to protect topsoil or reclaimed areas has been <br />practiced at Colowyo. <br />1n fact, during the Division's November 1995 inspection it was requested that we place <br />signs on the topsoil piles in question and we did so until we ran out of signs. The Inspector was <br />informed of this and the fact that additional signs had been ordered. To comply with the NOV <br />abatement procedures we have placed signs on the piles, however, we believe they are not <br />required by the alternative practice. <br />3) Timing of Topsoil Piles <br />The piles noted in the NOV consist of five distinct windrow azeas. The piles noted as <br />"Sec. 11" and "Center of East Pit" were placed there in the fall of 1994 and the other three piles; <br />"Piles East of Gulch A", "025 Substation" and "West End of East Pit" were just recently placed <br />in the fall of 1995. <br />In the fall of 1994 a number of additional windrow piles were also located in Gulch A and <br />at the west end of the East Ph. During the normal course of 1995 reclamation activities, <br />approximately 90% ofthe volume m these windrows was spread onto the adjacent reclaimed <br />areas. The backfill of the auger mining area in the East Pit delayed the regrading of those <br />adjacent contours and the spreading of the "Sec. 11" topsoil pile. The highest point of the <br />regraded contours in the East pit was also not advanced and the spreading of the adjacent "Center <br />of East Pit" topsoil pile was also delayed. Due to the complexities of backfilling the multiple <br />seam pit, final determination that these small azeas of spoil advance would not be advanced was <br />not realized until this fall <br />Realizing this, and to address the DivisiOn'S concerns raised during the inspection, <br />Colowyo submitted a Minor Revision to the Division to address rescheduling of the topsoil <br />spreading until next yeaz when adjacent spoil is regraded and available. The MR acknowledged <br />the delay in spreading the topsoil, requested an extension of the time frame for the spreadimg <br />activity and proposed that signs be placed and supplemental seeding be applied to enhance the <br />50% vegetative cover already in place on the piles. We believe the submittal of the MR is <br />consistent with the Division's expressed desire in the 1992 Findings Document noted previously <br />to limit excess haulage and redistn'bution of topsoil and served to correct what amounts to little <br />more than a routine "paperwork" issue. <br />