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MINE SITE INSPECTION NARRATIVE 2 <br />Mr. Price said that the company has modified their original design for drainage on <br />the area by requesting for approval to let a gully form on the western perimeter of <br />the mine. Most of it was snow covered during the inspection but from information <br />in the mine plan, it appears to run parallel with the one of the access roads left on <br />the mine. Apparently, several rills formed during the spring runoff season of 1989. <br />At that time it was identified in their rill and gully plan and managed according to <br />the requirements approved in the plan. Since that time, the operator requested <br />approval to reshape the drainage in the area by combining the rills, they <br />centralized it into a gully. Approval of the feature required studies of surrounding <br />terrain, that data was submitted in 1990. Walden Coal indicated in their TR <br />request approved by the division July 26, 1990, that the formation of a permanent <br />gully across the Bourg property as proposed is a realistic long term approach to <br />controlling erosion along the drainage. The gully apparently remained stable <br />through the 1990 runoff season. The gully will be managed according to the rill & <br />gully reclamation plan. The gully has been graded, rip-rap has been added, and <br />the area has been reseeded. The criteria for retaining the gully is based on <br />studies of surrounding like terrain with the erosion in the gully on the mine being <br />normal. Apparently work will be implemented on the gully if the determination is <br />made that erosion is excessive in nature. I did not address this approval in any <br />detail on this inspection. The grading plan on this mine is unlike any other <br />because there is an approval for no sediment ponds during the interiem following <br />reclamation planting where runoff water quality equals out of mine, similar drainage <br />runoff water quality. This in and of itself is approved on the basis of computer <br />modeling. I would have to assume that the gully formation and approval therof is <br />tied in with this plan. That being the case, I feel that a closer review of this <br />approval would be futile. I would however, question how phase III approval for <br />bond release will be initiated without evidence of runoff sampling from the disturbed <br />area. It would seem that gully formation would result in sediment loss, did this <br />occur under storm conditions exceeding the design criteria for the mine drainage. <br />In turn is loss under normal years from this gully part of the computer design <br />approval ? <br />The two remaining alluvial ground water monitoring stations on the mine in Mann <br />Draw were noted during the inspection. They appeared to be in good repair. <br />Surface water monitoring which included NPDES requirements is no longer <br />required on the mine. <br />The 4.5 acre loadout for the mine located a few miles north of Cowdrey, Colorado <br />was also inspected. It too was snow covered. The area is fenced, signs are <br />posted meeting permit requirements. No apparent drainage control problems were <br />noted. The loadout is located next to a railroad siding is still in place. <br />The mine permit, C-81-021, expires April 21, 1993. <br />