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F
<br />III. COMMENTS -COMPLIANCE
<br />Below are comments on the inspection. The comments include discussion of observations made
<br />during the inspection. Comments also describe any enforcement actions taken during the inspection
<br />and the facts or evidence supporting the enforcement action.
<br />General Comments
<br />This was a partial inspection of the Munger Canyon Mine, including Loma Loadout, and portions of the mine site
<br />in Munger Canyon. I was not accompanied by an operator representative. I checked in with receptionist at mine
<br />office prior to inspection at mine site, and discussed my observations with Chuck Silengo of CAM during my
<br />subsequent inspection of the McClave Canyon Mine
<br />Weather was cloudy, cool and windy, with an approaching cold front. There was shallow water pooled in the
<br />pond, and low areas were muddy, with some remnant puddles from rains earlier in the week. Due to time
<br />constraints, I was unable to walk all the way up to the reclaimed portal area. I inspected the reclaimed waste
<br />disposal and adjacent area, and walked up the reclaimed access road as far as reclaimed Channel "D".
<br />Roads
<br />Grading, roughening, and seeding with cover crop was completed along the the portal access road, between the
<br />access trail up the North Fork of Munger and the portal bench, in July. As noted previously, there is some minor
<br />rilling on some slope areas from recent rains, but erosion was not excessive along the reclaimed road segment
<br />observed. Riprapped stream channels along the reclaimed road segment observed have functioned well, and
<br />remain in good condition. The "Quickguard" cover crop has made modest growth in most areas since the
<br />previous inspection, but there is still a high percentage of bare ground on the roughened slopes, and
<br />spreading and crimping of straw mulch will be necessary, in conjunction with (immediately following)
<br />seeding of the perennial seed mix, to be conducted later this fall. Due to inaccessibility in most areas, the
<br />seeding, mulching, and crimping in most areas will have to be done by crews on foot, with hand tools.
<br />Hydrologic Balance
<br />There was a shallow pool of water in the waste disposal area sediment pond, well below the elevation of the
<br />gated primary discharge. The SAE silt fence at the reclaimed lower road topsoil stockpile was intact and in good
<br />condition. Ditches, culverts, and berms associated with the reclaimed waste disposal site, cover soil stockpile
<br />site, waste area topsoil stockpile site, and lower road topsoil stockpile site had functioned well and were in good
<br />condition.
<br />East Salt Creek was flowing, Munger Creek was dry at the time of the inspection.
<br />Backfill and Grading
<br />Backfilled slopes along the access road held up well, with only minor rill erosion in some areas along the
<br />segment inspected. Riprapped permanent drainage segments "A", "A1", "A2", "B", "C", and "D", functioned well,
<br />with no evident erosion or siltation along their length, or at inleVoutlet locations.
<br />There were no indications of slope instability (cracking, slumping, etc.) along the reclaimed road segment
<br />inspected. As noted, upper segments of the road and the portal bench area were not checked on this
<br />inspection.
<br />As noted in recent inspections, there has been some minor rilling and gullying along portions of the upper road
<br />and portal area backfill. Any gullies 9" or deeper, such as those associated with the portal area silt fence
<br />installations that failed earlier in the summer, should be filled in with dirt or packed straw, in association
<br />with (prior to) permanent seeding,
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