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s ~r .. <br />1. Prior to approval of the "topsoil surge piles" in 1491, the Division requested that <br />Colowyo make a firm commitment to not have these piles in place for more than one <br />year. If topsoil was to be stored for greater than one year, it was required to be <br />located in an approved topsoil storage pile area and protected from wind and water <br />erosion as required by Rule 4.06.3. <br />The Division approved the "temporary" topsoil stockpile practice with specific <br />conditions described in the permit and findings document to not leave the piles in <br />place for over one yeaz. According to the permit, "...topsoil hauled into a regraded <br />spoil area will be left in place in a narrow windrow adjacent to the azea to be <br />seeded. Since, in the spring of the next year this is the first topsoil to be respread <br />onto the advancing regraded spoil, the windrow is always left in place for less than <br />one year." Two of the five piles noted above have been in place for over one year, <br />as noted in the aerial photograph dated September 28, 1994. They should have been <br />redistributed in spring of 1995, but will probably not be respread until the spring of <br />1996 which is 1 1/2 years after being placed. <br />2. The Division concurs with Colowyo's statement that seeding of the temporary topsoil <br />piles is not necessary if the piles aze placed in the fall and respread eazly the next <br />yeaz before the revegetation can achieve any significant growth. However, two of the <br />five windrow piles were not spread in the early spring of 1995, and thus had a dense <br />concentration of weeds. Colowyo should have spread this topsoil in the spring of <br />1995, or at least seeded the piles in the spring when they realized reclamation would <br />be delayed. The violation abatement was written as such to apply only to the two <br />piles placed in the Fall of 1994. <br />3. Colowyo states that the approved topsoil storage practice did not require the use of <br />signs, and that it was never an issue during the discussions of this practice. Rule <br />4,02.7 is very clear regarding the use of topsoil signs, and makes no exception for <br />alternative storage practices, or how close the piles aze in relation to the active <br />mining area. It was noted to the operator in the previous inspection report, that <br />topsoil signs were necessary on all of the windrow piles. Only one sign was posted <br />on the date the NOV was issued. <br />4. <br />Colowyo states that a minor revision (MR) was submitted to the Division prior to <br />issuance of the NOV. The MR was handed to me at the mine moments before the <br />NOV was written, and consisted of a typed letter requesting that the topsoil <br />stockpiles remain in place for one additional year. Leaving salvaged topsoil adjacent <br />to active mining areas far up to two years did not appear to be an effective means <br />of preserving topsoil for reclamation, and did not correct the violation. The Division <br />proposes to deny the minor revision application because the topsoil handling <br />practices currently approved in the permit are more in line with regulatory <br />requirements. <br /> <br /> <br />~~ ~~? <br />~~ ~~~ <br />