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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. This was a complete inspection conducted by Tom Kaldenbach of the Division Minerals and Geology. I inspected the site on September 19 and 21. On September 21 the operator's consultant, Jerry Koblitz of Greystone Environmental Consultants, Inc., met me on the site to discuss erosion control methods. The Division received a bond release application from the operator on January 26, 2004, and found the application complete on August 18, 2004. The bond release application requests Phase III (final) release on the entire site. The file number is SL-5. With the operator's consent, I am issuing this report from DMG's Denver office. The site was dry and fully accessible. The site appeared as it did during the previous month's inspection. AVAILABILITY OF RECORDS All required records were available at the Archuleta County courthouse (see attached list). SIGNS AND MARKERS The mine i.d. sign was properly displayed at the entrance to the site. ROADS The only roads remaining on the site are the graveled entrance gate road and a dirt road on the west side of the East Pit ridge. Both roads have been approved as permanent. The surfaces of both roads were in good condition. The ditch next to the East Pit road was in good shape. HYDROLOGIC BALANCE All ponds were reclaimed a few years ago. All ditches remaining on the site have previously been approved as permanent. A ditch drop structure on the southwest corner of the East Pit area also has been previously approved as permanent. The double-culvert in the drop structure was clear of sediment, but there are gullies on the slopes on both sides of the culverts. These gullies apparently formed during storms in September that exceeded the 10-year design storm. The operator's representative explained that these slopes would be renovated to ensure proper functioning of the drop structure. Most runoff to the drop structure comes from ditch 2S2a (extending along the southwest end of East Pit) and ditch 2S 1 (extending along the road on the west flank of the East Pit area). Downcutting was evident in these ditches and in the upper part of ditch 3Nc on the northeast end of East Pit. Designs for these ditches (and the drop structure) are in Exhibit 7 of the permit application. The Division is reviewing these designs to determine if renovation of these ditches is needed. Hydrologic monitoring was eliminated in Technical Revision TR-32 in January 2003.