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Colorado Mined Land Reclamation Board <br /> Page 4 <br /> March 2, 2018 <br /> conditions for approval, or portions of a condition,the Division's recommendation,by operation of Rule, <br /> automatically becomes a recommendation for denial of the application. <br /> Issues Raised by the Objecting Parties and Commenting Agencies <br /> The timely objections/comments received by the Division have been categorized as issues pertaining to <br /> Enforcement, Hydrology, Permitting, Reclamation and Wildlife. These categories are listed below and <br /> titled with bold font. Under each category the specific issues are listed in bold and italic font. The <br /> number of objectors which raised the issue is indicated in parenthesis. <br /> 1. Enforcement Issues <br /> a. Concerns regarding the lack of enforcement ability and timing for enforcement. (4) <br /> Section 3.2 and 3.3 of the Rules provides Division staff with the authority to conduct inspections of <br /> permitted mine sites and possibly unpermitted mine sites to determine whether the provisions of the Act <br /> and Rules have been complied with. Also,these Rules require the Division staff to promptly report to the <br /> Board any possible violation of a permit, law or the Rules of which they have knowledge whether <br /> obtained from personal inspection or from written reports. These Rules continue to outline the <br /> enforcement processes should a violation be found. <br /> The Division routinely conducts inspections of mining operations and takes proper enforcement action. <br /> Many of these inspections are conducted as a result of a citizen's complaint. If a citizen's complaint <br /> pertains to an issue for which the Division does not have jurisdiction,the Division will forward the <br /> complaint to the proper jurisdiction. <br /> The Board has directed the Division's staff to respond to citizen complaints within thirty days of receipt <br /> of the complaint. If a citizen complaint alleges either serious environmental problems associated with an <br /> operation or potential violation of approved conditions,Rules,or statutes,the Division shall conduct an <br /> inspection as soon as possible,but no more than five working days after receipt of the complaint. <br /> 2. Hydrology <br /> a. Concerns regarding surface and groundwater quality. (19) <br /> The Division finds LRM has supplied the required information regarding water information in accordance <br /> with Rule 6.4.7. <br /> LRM is proposing a closed surface water system intended to capture all stormwater produced on the site <br /> and that which currently runs onto the site. Stormwater will be directed toward the mine excavations and <br /> stormwater retention ponds. LRM affirmatively states that they will apply for a National Pollutant <br /> Discharge Elimination System permit from the Water Quality Control Division(WQCD) of the Colorado <br />