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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. NARRATIVE TO 9-14-94 INSPECTION REPORT FOR NORTH THOMPSON CREEK MINE This inspection report documents observations made on the site on 9-14-94 and 9-15-94 as well as continued records review during 9- 19-94 through 9-22-94. This complete inspection was conducted with Russ Porter of OSM-AFO. Mr. Porter began the records check at the Garfield County Courthouse - records room at 8:30 a.m.. He was joined by Susan McCannon for the latter half of the records check which continued until 1:30 p.m.. Several questions regarding records arose during this portion of the inspection. Since the operator was not present during the inspection these questions were successfully answered a few days after the inspection. Mr. Porter noted that the AVS had indicated that Lark Mining was a partner in the mining operation, but that the permit did not reference Lark Mining. It was determined that the AVS was in error and will be changed. The permit listing of partners is correct. A copy of the bond with the OSM listed as co-beneficiary could not be located at the courthouse. The current bond does list, however, OSM as a co- beneficiary and a copy of the current bond will be placed at the courthouse. A determination of what subsidence monitoring and reporting was required could not be located. This information was later located in the 1988 Findings document on page 10: The operator will modify the permit to clearly indicate the current status of subsidence monitoring and reporting. The site inspection began at the reclaimed Mine #3. This area has been previously reclaimed and subject to phase 1 bond release. The entire reclaimed area was walked including the areas of the upland diversion ditch D-1. The area was stable with no evidence of erosion. Vegetative cover looked good with an abundance of Cicer Milkvetch, Rubber Rabbitbrush, and assorted grasses. In addition there were many wood's roses in evidence. A detention basin, shown as P-1 on map D-4-7, was noted beside the road. This structure has a single 18" CMP spillway which passes through the road embankment. This structure collects undisturbed run-off from a clean water diversion. Also noted in the reclaimed area of Mine ~`3 was another detention basin shown as P-2 on map D-4-7. This structure has no spillway and exists as a depression in the backfilled area above the road. It may have been part of the clean water diversion system when the mine was active but was not backfilled during reclamation of the rest of Mine #3. P-1 and P-2 are discussed in more detail latter in this report.