INSPEC02048

• Permit No: C1981020
• IBM Index Class Name: Inspection
• Doc Name: Inspection Report
• Inspection Date: 9/12/2005
• Media Type: D
• Archive: No

III. COMMENTS -COMPLIANCE
Below are comments on the inspection. The comments include discussion of observations made
during the inspection, Comments also describe any enforcement actions taken during the inspection
and the facts or evidence supporting the enforcement action.
This was a complete quarterly inspection of the Loma Loadout, mine site, and office records. There was
no operator contact present during inspection of the Loma Loadout. The mine site inspection was
conducted in the accompaniment of Walter Whitledge, Mine Manager. Weather was clear and mild.
There had been another high intensity rain storm event in the Munger watershed on the
afternoon/evening of September 9. Jim Stover of J.E. Stover Associates, consultant to the operator, had
left a voice mail message to notify me of the storm and of the fact that flow had again backed into the
waste disposal area sediment pond and filled up the pond. Mr. Stover's message was recorded on
Monday morning, when I was already on my way to the mine.
Offsite Support Facilities (Loma Loadout)
Conditions were generally similar to those described in the June inspection report, with the exception that
growth stage of vegetation has advanced with the season. The Russian knapweed plants have initiated
fall growth, and should be sprayed this month. There are two small patches of knapweed within the
revegetated area that need to be sprayed. Both small patches are located near the west end of the
reclaimed area (one patch along and near the drainage containment berm along the south edge, and the
other small patch on and adjacent to the railroad fill, along the north edge). There is also a larger patch,
located to the west of the reclaimed area, between the old two-track road and the irrigation ditch. This
patch does not appear to be the operator's responsibility to control under the DMG permit. Although it is
partly within the permit area, it does not appear to be within an area that was disturbed under the permit.
Soils were moist from recent precipitation, but not muddy, even in low lying areas. SAE berm and silt
fence were intact and functional. Annual (non-noxious) weedy species are the visually dominant species.
There was a flush of winter annuals this year, dominated by Sisymbrium mustard, with a subsequent
flush of summer annuals, kochia and Russian thistle. Perennial vegetation establishment from the fall
2004 seeding remains patchy. A significant percentage of the western wheatgrass plants that
germinated in the spring have not initiated re-growth after going dormant during the heat of the summer.
Perennial establishment seems to have been suppressed in the areas with dense growth of the annual
mustard, with apparently better establishment in the areas dominated by the summer annuals. A couple
years will need to pass to assess the success of the most recent seeding effort.
Availability of Records
Required records were on file and up-to-date through the 2ntl quarter, 2005. See attached form
Roads
Heavy rain in the Munger watershed resulted in very high flows along Munger Creek and its tributaries
throughout the permit area. The rain gage at the Munger portal area showed 1.4" of precipitation. The
10 year, 24 hour storm event for the site is 1.5". However, the precipitation apparently came over a
much shorter time period than 24 hours, and in several locations the peak flow generated by the event
exceeded the capacity of road ditches, resulting in flow down the road, with resulting rills and deposition
of cobble and gravel in various location. Culverts apparently functioned effectively, however in a couple
locations the protective outlet sleeves were damaged, and culvert inlet sumps were filled with sediment.
Road surfaces, ditches, and culvert inlet sumps along the length of the road will require maintenance to
restore design conditions. Specific areas of concern include the following.
3