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Water Ouality Samplin .There is a sampling requirement for groundwater and surface water. Unfortunately, the <br />required water quality sampling was allowed to lapse in the recent past. We all mutually recognize the danger in <br />this, and current understanding by all parties is that such lapses will not recur. The water quality sampling is to <br />follow a scheduled frequency and be analyzed for a specified set of parameters. The files for this site include a <br />documented sampling requirement of two samples per year from each sampling point. The groundwater is to be <br />taken from the lower portal sump, and surface water from the gulch immediately downhill from the permit area. <br />The first annual samples are to be taken from each of the two locations in the spring, the second samples are to be <br />in summer, sometime during the operating season and (in the case of the surface water sample) when the gulch is <br />flowing. Please collect the samples properly (following the lab's recommendations), do not exceed the holding <br />times, and submit your analyses to this office promptly. The former operator would submit his analyses with his <br />annual reports on December 31, but if he forgot to sample, it was too late at that point to collect one. If the <br />analyses over the next few years adequately demonstrate that we can reduce the sampling frequency to once per <br />year, we will let you know. <br />Aonroved Mining Plan and Approved Reclamation Plan. We reviewed the map of the aeeas to be affected by <br />excavation, dumping, backfilling, and reclamation. The separate areas follow a sequence through a part of the <br />site. These plans were reviewed and approved as part of the amendment several years ago, and the bond was <br />based on that scenario. Please review your files to ensure that you also have this information. These plans will <br />remain in effect until they are changed through a formal permit modification. As long as these plans remain in <br />effect, the site will be monitored to ensure compliance with the plans. As the operation progresses through the <br />site according to the plan, you must inform us of such in your annual reports, and we will periodically review the <br />bond amount too. If you depart from the approved plans, such as. by mining or otherwise affecting areas not in the <br />approved sequence or method, there may be a problem with the permit or a case of insufficient amount of bond <br />posted. <br />Affected Areas. The aeeas which are approved for topsoil stockpiling, dumping and grading are close to the <br />downslope permit boundary. Any of several scenarios could result in inadvertent or accidental damage to lands <br />outside the boundary, which is typically pursued through enforcement as a possible violation. It was suggested <br />during the meeting that a permit amendment to add land to the lower portion of the permit area could provide a <br />buffer to reduce the risk of offsite damage. This limited impact 110 permit must be less than 10 acres, and <br />amending more land to this permit may cause the acreage to reach 10 or more acres. If you do not wish to convert <br />this permit to a regular 112 permit, which may contain 10 or more acres, some of the presently-permitted land <br />must be released. The northern portion of the permit lying on the. ridgetop was named as a possible candidate for <br />such a release. Reducing the permitted acres through such a partial release will enable the addition of new acres <br />through an amendment and allow the permit to remain as a 110 permit. <br />Onsite Structures. We discussed the separate reclamation tasks which aze part of the bond amount. The single <br />lazgest one is the demolition and removal of the existing mill building. This is not a historic structure nor a <br />modern one of flimsy construction. The mill building is new and of very substantial construction, but the <br />currently-approved reclamation plan states that it is neces§ary to remove it from the site. This will be an <br />expensive task when the time comes. Given the durability of the construction, it was mentioned that there may be <br />other possible future uses for the building, after mining and reclamation cease. If so, the reclamation plan and the <br />related bonded reclamation tasks may be modified. The Division will entertain the operator's request for such <br />modification if certain other materials are also submitted: a written request from the landowner stating the intent <br />and desire to leave certain structures; and written approval by the county deparhnent which has jurisdiction over <br />such matters, that certain structures may-remain. Additionally, the present mill building is situated where a <br />temporary facility is approved, and the permanent structure is to beyp on the ridgetop. We agree that the plan <br />should be changed, and the actual building will not need to be moved. <br />Permit modification. As stated above, there are various items related to the current operations which merit <br />consideration for revision in the future. Depending on the type of formal change desired, modification may take <br />