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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. 3, shows that, under the approved drainage plan, undisturbed runoff from 11.5 acres of "upland area" would report to the sediment pond. The 7.4 acre watershed that reports to Culvert CMP-3 is not included in this upland acreage, thus the sediment pond was not designed to handle the runoff from the CMP-3 watershed. Based on current site conditions, without CMP-3 in place, it appears that drainage from the CMP-3 watershed would enter collection ditch segment "D", and report to the sediment pond. In Photo 1633, attached, the jeep is parked near the junction of the new haul road and pre-existing access road, in vicinity of CMP-3 approved location. Photo 1634 shows the upland drainage associated with CMP-3, and Photo 1635 shows the collection ditch "D" segment, along the south side of the new haul road. Temporary Rock Storage Area Narrative on page 2-18 of permit Section 2.2.5 states that large rock (18" to 30" diameter/.obtained from the cover material will be segregated and distributed on the comp/efed s/opes [of the waste disposal pile] fo/%wing-topsoi/p/acement.:.: However, the approved plan does •not.include aspecified location for storage of rock to be used later during reclamation. The approved plan in Section 2.2.5 describes phased development of the waste disposal area, indicating that disposal area development and associated topsoil salvage will occur in three or more separate construction phases. Narrative indicates thatthe surface soil horizon within the Rivra unit lon the valley floor) and the Torriorthent unit (on the sideslope) will be salvaged for topsoil and stockpiled. Rules 4.06.111) and 4.06.2(2)(a) require that topsoil be salvaged prior to disturbance, unless a variance is approved by the Division for good cause shown, for specified situations. No variance from topsoil removal was requested or approved, with respect to the waste disposal area project described in-permit Section 2.2.5. .Photo 1638 shows aprimary-rock storage pile in the background and a smaller rock pile.in the, foreground, with an equipment access route leading from a graded area adjacent to Ditch "D", to the primary storage area. The location is within the approved disturbance area, approximately 100 feet east of the active waste disposal cell. The rock storage site appears to be within the area that would be excavated during the next phase of waste disposal development. The rock storage area drains to.. collection ditch segment "D", and reports.to the sediment pond. Disturbance associated withahe.rock piles and equipment access appears to .total approximately 3000 square feet, which would equate to approximately 100 cubic yards of the Rivra surface horizon material to be salvaged (average 12 inch thicknessl. It is apparent that topsoil was not salvaged from the equipment access route or the "footprint" of the rock piles, based on the fact that original sagebrush/grass vegetation cover is still present (although sagebrush is mashed down and stems broken along the access route). It does not appear that the topsoil has been "lost" as a result of the disturbance associated with storage of the sandstone rock, and recovery of the soil with minimal loss should still be feasible. However, a storage area should have been designated for the rock, and topsoil salvage should have occurred prior to disturbance. Availability of Records Office records were not checked during the inspection, but the operator was reminded that the Division had not yet received the renewal permit document with an original signature of the appropriate CAM official. The operator indicated that the document would be promptly signed and submitted to the Division. A copy of the signed document will need to be kept on file at the mine office. 4