2008-04-30_INSPECTION - M1977205

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(Page 3) MINE ID # OR PROSPECTING ID # M-1977-205 INSPECTION DATE 8-23-2007 INSPECTOR'S INITIALS SSS the approved permit is listed as a problem in this report. This problem has been corrected (as long as the operator complies with permit conditions) through submittal and approval of technical revision no. 2 (TR-02). The correction date is set at January 22, 2008 which is the date that TR-02 was approved. The permit required that the pit slopes be maintained at final grade (3H:1 V) at all times. This was requested by the permittee during the amendment no. 1 process in order to keep the reclamation bond amount relatively low. During this inspection it was noted that pit slopes in parts of phase 1 and about half of phase two were much steeper than 3H:1 V and in some cases were vertical and excavated right up to the affected area boundary. This is another example of failure to comply with the conditions of the permit. In this case the operation methods have resulted in a situation where the reclamation bond is insufficient. This is noted as a problem with backfilling and grading requirements of the permit as well as financial warranty requirements of the Mined Land Reclamation Act (Act) and the Construction Materials Rules and Regulations (Rules). This problem has been corrected through submittal and approval of technical revision no. 2 (TR-02) and submittal of the significantly increased financial warranty. The correction date is set at January 22, 2008 which is the date that TR-02 was approved. The permit specified that the pit highwall will not exceed 1600 linear feet without application of topsoil and revegetation tasks performed. During this inspection the inspector noted that much of the phase 1 slopes and all of the phase 2 slopes had not had topsoil replaced or been revegetated per the permit specifications. Additionally, a buffer of 20 feet around the pit perimeters was to remain unexcavated and have limited traffic so the in-place topsoil could be spread over the pit slope. During this inspection it was noted that some of the 20' perimeter buffer has been compacted by high traffic on roadways. Where excavation has proceeded to the affected area boundary, the topsoil has been removed and will need to be hauled from other portions of the site. This is noted as a problem under the topsoil handling requirements and the financial warranty requirements of the act and rules and the approved permit. This problem has been corrected through submittal and approval of technical revision no. 2 (TR-02). The correction date is set at January 22, 2008 which is the date that TR-02 was approved. Amendment no. 1 included a commitment that the operator would provide proof of topsoil depth. The documentation was to be submitted prior to any topsoil exportation from the mine. This documentation has not been submitted to date to demonstrate, to DBMS satisfaction, that adequate topsoil reserves exist for reclamation of the site. That documentation has not been submitted and is noted as a records problem in this report. Failure to submit the topsoil documentation is noted as a problem with the corrective action and corrective action due date noted on the last page of this report. Noxious and/or problematic weed infestation consisting primarily of knapweed and thistle are scattered across the affected area. The infestation, if not controlled, will hinder successful reclamation of this site and most likely contribute to off-site spreading and establishment of these weeds. The approved weed control plan is either not being implemented or is not effective in it's current application. Please indicate what measures will be taken to improve weed control and, if appropriate, submit a technical revision to incorporate these measures into the permit. DBMS recommends that a revised and updated plan, approved by the local government weed authority, be submitted to replace the old plan. The updated plan will need to address control measures for Russian olive and Tamarisk. Weed infestation is noted as a mine plan problem, with the corrective action(s) and correction date specified on the last page of this report. Significant progress toward control of on-site weeds must be demonstrated within three years to avoid potential enforcement action. The financial warranty was recalculated in January of 2008 to account for site reclamation liabilities. That financial warranty has been submitted to, and accepted by DBMS.