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~l III. Continents - 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 inppection and the facts or evidence supporting the enforcement action. The subsidence monitoring network was examined on Thursday, December 19, 1991. Five stations along the Florence water line and County Road 15 were observed. Energy Fuels has installed 1" square rebar in concrete for the stations and flagged the sites with wooden lathes. Site F on the Florence water line grid was an orange circle painted on the concrete of a manhole cover. The two houses at the Thompson Ranch had small "x"s chiseled on the northwest corner of the concrete porches. The intensive monitoring network is located south of the ranch and southwest of the wastepile above the Rex Carbon Mine. We walked the rebar marked Sites on the northern arm of the cross. Site N15, which has experienced the maximum amount of subsidence, is located on the south edge of a drainage. A narrow, shallow, discontinuous, subsidence crack runs E-W through this portion of the grid: The subsidence network appeared to be well maintained. Mr. Rathburn asked to see a letter documenting that landowners had been notified six months prior to mining about subsidence in order to comply with Rule 4.20.2. Mr. Weaver was unable to provide the letter that the previous owner, Dorchester, probably wrote, so NOV 91-036 was written. We visited the proposed Monarch Mine ventilation shaft on Wednesday, December 18. This site is accessed along a pre-existing mining road which is predominantly outside the permit area. The operator anticipates using this road daily to check the fan. There are two sloughed-1n existing portals that the operator is considering using. These go into the slope to the west in an area badly disturbed by previous mining operations. The northernmost portal sits 1n the southwestern corner of a meadow traversed by the road and bounded by spoils piles on the east. The spoils piles sit west of an open strip cut bounded on the east by a highwall. The road switchbacks to cross the ephemeral stream and then rises to the south past the southernmost portal. A concrete arch and foundation sit in front of the portal. Less than 100 yards upstream, there is an embankment across the stream, the function of which is unknown. Avery rough road climbs the hill southwest of the portals to access a power pole. Issues such as road upgrading, sediment control, protection from floodwaters associated with the creek and the reclamation plan were discussed. The surface water drainage system was not in place nor maintained in accordance with the plan at the mine site and the loadout. In contrast, the surface water drainage plan at the waste pile was in place and well-maintained with one exception. The following narrative discusses the specific citations of NOV 91-29. The mapped mine area drainage system consists of four ditches, two drains and a drainage routing junction protected by a concrete apron. Ditch CD-1 drains east around the shop into the drainage routing junction; it was closed directly north of the shop by material sloughed off the cut and by careless grading activities. Ditch CD-2 drains south around the coal stockpile perimeter and into Pond 1. This ditch was not present throughout its length (I.C.>.