2009-11-14_INSPECTION - M1983102

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(Page 3) MINE ID # OR PROSPECTING ID # M-1983-102 INSPECTION DATE 11/4/09 INSPECTOR'S INITIALS PSH Bond Reduction -Topsoil The operator submitted the following estimate of available topsoil at the site with the surety reduction request; • 6,000 cubic yards located south of the mine site • 6,000 cubic yards above the east highwall • 2,330 cubic yards in the northwest corner of the floor The Operator states in the reduction request, the permit was approved for no soil on the floor and four inches in the slopes. The Division agrees no soil is required if the pit floor is reclaimed to industrial/commercial use. However, the site is not zoned industrial/commercial and without reasonable assurance of the post-mining land use the Division requires topsoil replacement in the event the site is not reclaimed to industrial use. The Division disagrees with the four inches of topsoil replacement value. The operator committed to replacing four (4) to eight (8) inches of topsoil over the entire site in the original permit. The amendment application states unless specifically discussed the reclamation methods described and approved in the original permit application will remain unchanged. Therefore, the Operator is required to replace an average of six inches of topsoil on the slopes and pit floor and the reclamation bond must reflect this requirement. The Division calculated the required topsoil to reclaim the site based on the current disturbance of: • 24.4 acres of pit floor (19,680 cubic yards) • 2.0 acres of 40' high eastern highwall (1,615 cubic yards) • 0.65 acres of bermed pit floor perimeter (525 cubic yards) The Division estimates a minimum of 21,820 cubic yards are required to reclaim the current disturbance with six inches of topsoil. The existing topsoil stockpiles were measured and the volumes are below: • 6,000 cubic yards in the southwest corner of the site • 3,800 cubic yards above the eastern highwall • 2,250 cubic yards in two stockpiles on the pit floor. The total estimated available topsoil is 12,050 cubic yards, which is not adequate to reclaim the site based on the approved reclamation plan and current site zoning. The Operator must provide the Division with evidence of rezoning and/or documentation sufficient topsoil is available at the site to reclaim the site to the approved reclamation plan to avoid a possible problem or violation in the future. The Division did not consider the topsoil available in the undisturbed east area due to the uncertainty of mining the area. Bond Reduction - Concrete/Asphalt/Equipment Debris Removal Imported concrete, rock and asphalt stockpiles were observed in several areas on the pit floor during the previous inspection. The debris has been removed from the site and the concrete and asphalt piles have been processed for resale by the Operator. The Division agrees the cost associated with debris removal and concrete/asphalt can be removed from the bond estimate.