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adequate to determine if hazards exist. There are two vent holes shown to the west of this permit area. Please provide more information as to their condition (i.e., open, grated; cased, vent fan, etc.). The old mining features in the northwest corner of the permit azea aze not necessarily IUSA's responsibility to reclaim, if they pre-date the issuance of this permit and have not been redisturbed or utilized in the permitted operation. They may be removed from the map if desired, but might present a clearer picture if they remain on the map but clearly identified aspre-law. , It is assumed that all areas shown in brown with hachures denote waste rock dumps, which are to be graded to 2:1 slopes or less as part of final reclamation. The area occupied by the stormwater control berms and pond; in the northern half of the site must be reclaimed. This includes revegetation and maintenance until the area is released from further reclamation responsibility. I agree that the new surface detail superimposed on the map base must be tied back in to the topography, for both the final mining and reclamation maps. Please be reminded that reclamation maps should depict only those features which will remain onsite after reclamation is finished. All roads, buildings, berms, etc., that aze to be removed should not be included on the reclamation maps. Stormwater controls which are to remain should be shown. There is a delineation presumed to show the outer "footprint" of all past disturbance, in addition to the labeled affected azea boundary. This irregulaz footprint exceeds the polygon of the affected area boundary on the north, west, and south sides by up to one acre in total. However, because the boundaries were never marked, mining activities were never shown on annual report maps, and the. 1998 map updates were incomplete, it was not fully realized until now. It is not known if these areas were affected under a previous operator. The areas which can be demonstrated to be actual offsite damage (road cuts, waste rock fills, adversely affected surface drainages, etc.) may add up to a possible violation. Though it may seem unfair,- I. will have to discuss this situation with the program supervisor to determine whether enforcement action. is,warranted. If so, the best cure for such deficiency will be to reconfigure the boundary to include all such offsite disturbance in the permit, and to bond for its reclamation. These are items we are already working'toward. You must revise the map to show a "proposed boundary configuration" of an azea of the same acreage. Configure it as you deem best for your future operations, but constrained according to the criteria given. Straight sides and comers are obviously the easiest to mark. If enforcement action is necessary, your proposed configuration will not become final until the Board approves them. Summary These comments and questions will hopefully assistyou in finalizing the maps for this permit, by explaining how this Division proceeds in determining which areas and.features.are to be included in the bonded reclamation liability, and within the boundary on the maps. Your, preliminary map is a very good start, and should take minimal effort to reach a complete and adequate stage for our.uses. , , I look forward to receiving the revisions. Please ensure that you submit all maps, especially oversized maps (larger than 11" x 17") in duplicate. Additionally, final maps are to be.signed by the prepazer. As before, please do not hesitate to contact me if there are questions. I may be reached, and/or the maps mailed to the Division's Durango field office: 701 Camino del Rio, Room 125, Duratigo; CO :8t3.Q1; telephone 970/247-5103 or fax 970/247-5104. _~ . ,.- Sinc~ejrely, l -,,{] / ~, yl~ ~WN~'~'l V .... Bob Oswald Environmental Protection Specialist .: A:\camation map/rco