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should not be included on the reclamation maps. Stormwafer control structures which are to remain should be <br />shown. <br />The affected area boundary is shown on the map for this site, though its exact location may be up to question. <br />Although it could be argued that utilizing other data to determine its location shifts it about 70 feet northward, I am <br />satisfied that it is adequately situated as shown on the map, and see no point in further relocation. There is a <br />delineation presumed to show the outer "footprint" of all past disturbance, in addition to the labeled affected area. <br />This irregular footprint exceeds the polygon of the affected area boundary on the east by about 1.5 acres. This <br />offsite damage has been suspected for several years now by Division staff, from the time of the inspection <br />transferring the permit to IUSA. However, because the boundaries were never marked, mining activities were <br />never shown on annual report maps, and the 1998 map updates were woefully poor, it was not fully realized until <br />now. This preliminary map confirms my field observations, and it may add up to a possible violation for offsite <br />damage. Though it may seem unfair, I will have to discuss this situation with the program supervisor to determine <br />whether enforcement action is warranted. If so, the best cure for such deficiency will be to reconfigure the <br />boundary to include all such offsite disturbance in the permit, and to bond for its reclamation. These aze items we <br />are already working towazd, and it is in your favor that the offsite damage occurred under the previous operator. <br />You must revise the map to show a "proposed boundary configuration" of an area of the same acreage. Configure <br />it as you deem best for your future operations, but constrained according to the criteria given. Straight sides with <br />definite comers aze obviously the easiest to mark. If enforcement action is necessary, your proposed configuration <br />will not become final until the Board approves them. <br />Summary <br />,~ ,~ <br />These comments and questions will hopefully assist you in finalizing the maps for this permit, by explaining how <br />this Division proceeds in determining which areas_and features are to included in the bonded reclamation liability, <br />and within the boundary on the maps. Your prelitztinary map 3s ,a very good start, and should take minimal effort to <br />reach a complete and adequate stage for our uses; ;. <br />I look forwazd to receiving the revisions. Please.ensure that you submit all maps, especially oversized maps (larger <br />than I1" x 17") in duplicate. Additionally, all final maps are to be signed by the preparer. As before, please do not <br />hesitate to contact me if there are questions. I may be reached,,and/or the maps mailed to the Division's Durango <br />field office: 701 Camino del Rio, Room 125, Durango, C0 .8,1301; telephone 970/247-5103 or fax 970/247-5104. <br />Sincerely, <br />~~~ ~ ' / <br />Bob Oswald <br />Environmental Protection Specialist <br />A:\west Sunday map/rco <br />