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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 complete quarterly inspection conducted by Dan Mathews of the DRMS Grand Junction Field Office. <br />The reclaimed Loma Loadout was inspected at 9:00 am, mine site at 9:45 am. Weather was partly cloudy and <br />cool. Surface areas at the loadout were moist; ground conditions at the mine area ranged from moist to muddy. <br />There was no activity at the mine or loadout site at the time of the inspection. There was murky flow in East Salt <br />Creek from snowmelt runoff; no flow in Munger Creek. Operator did not accompany me during the inspection, <br />but I did contact Gary Isaac at the mine office prior to and at the conclusion of the mine site inspection. <br />Operator reports that final reclamation of the Munger Canyon Mine site is planned for 2007. A technical revision <br />application addressing various updates to the reclamation plan is currently under review by the Division, and will <br />need to be approved before final reclamation can be initiated. Operator plans to permit a small coal waste <br />disposal site at McClane Canyon Mine to replace the Munger coal waste disposal site. Operator's right of entry <br />along the existing Munger Canyon road is the subject of a legal dispute with #11 Resources, landowner along <br />the lower segment of the road. Operator will need to maintain right of entry as necessary to perform <br />reclamation, monitoring, and maintenance activity required by permit and regulations, until final bond <br />release. <br />Availability of Records <br />Required records were on file and up to date through the 4th quarter, 2006 <br />Signs and Markers <br />The sign with DRMS address and phone number at Loma Loadout has become detached from the stake <br />and needs to be re-secured. <br />Roads <br />Haul Road up to the waste disposal area was in good condition. The portal access road beyond the waste <br />disposal area was generally in good condition, but was muddy in some sections and minor rockfall was present <br />in some locations. Culverts and culvert outlet structures were in good condition. Several of the culvert inlet <br />sumps were full or nearly full of water from snowmelt and recent precipitation. Typical spring maintenance <br />grading, and culvert inlet sump maintenance will be warranted when conditions have dried out further. <br />The temporary drill pad access road up the North Fork of Munger Creek was reclaimed in the spring and <br />summer of 2006. Due to the lengthy hike required, and the current muddylfrozen conditions along the access <br />route, the road reclamation was not inspected during this inspection. The route will be inspected during the next <br />monthly inspection. <br />Hydrologic Balance <br />There was flow in East Salt Creek, but not in Munger Creek <br />At the portal area, conditions were muddy, with a few remnant snow patches on north slopes. Water was pooled <br />6" deep in the SAE-1 sediment trap. The rock check structure was intact and functional, and silt fencing was in <br />good condition. Diversion and collection ditches and berms in the portal area were properly maintained. <br />Refuse area sediment pond contained a shallow pool, at least 12" below the level of the gated primary spillway <br />pipe inlet. <br />3 <br />