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III. COMMENTS-COMPLIANCE <br />Below are comments on the inspection. The comments include discussion of observations <br />made during the inspection. Comments in Section IV describe any enforcement actions <br />taken during the inspection and the facts or evidence supporting the enforcement action. <br />Horses were being pastured in the fields (upper river terrace area) traversed by the <br />two-track dirt road. <br />The inspection also addressed the work to control contributions of suspended solids to <br />streamflow or runoff outside the permit area. Suspended solids are not to exceed <br />those of premining levels or in excess of adjacent nonmined areas (Rule 3.03.1(3)(b)). <br />A demonstration was made in July 1992 that untreated drainage from the reclaimed <br />mine site does not contribute additional suspended solids above natural conditions <br />(see Soils Loss Comparison -North Thompson Creek Mine Sites, pages 4-19i through 4- <br />19iii of the PAP). There has been no recorded incidence (Colorado Department of <br />Public Health and Environment discharge monitoring reports or monthly inspection by <br />the Division) of surface runoff from the site (no discharge from the two unreclaimed <br />sedimentation ponds). A number of other sedimentation ponds have been <br />(authorized for and) previously reclaimed. <br />Only one small erosion rivulet was observed during the inspection. This rivulet was <br />located on a portion of the reclaimed Portal 3 area, and appeared to have been <br />arrested and stabilized by vegetation and residual rock armor. There was no <br />indication that there was a contribution of suspended solids to streamflow or runoff <br />outside the permit area in excess of premining levels or in excess of adjacent <br />nonmined areas (Rule 3.03.1(3)(b)) at this rivulet or anywhere else on reclaimed areas <br />of the permit, There was no incidence or evidence of contribution of suspended <br />solids to stream flow or runoff outside the permit from any of the permanent features <br />of the disturbed areas. Permanent riprapped relief drains off reclaimed areas <br />(facilities areas of Portal 1 and the refuse disposal site) were found to be in excellent <br />condition. The gravel wearing surtaces of the permanent roads are controlling <br />erosion of the roadway. Rock, vegetation, and waterbars arrested erosion by runoff <br />on the dirt road/trail over Stony Ridge. No erosion features were noted from the <br />paved haul road to the loadout site. <br />The placement of topsoil may be recognized at the time of Phase II Bond release <br />(seedbed preparation). This mining operation was active before and at the time of <br />permit activation. Available topsoil was reportedly (PAP page 4-46) placed at a <br />depth of b inches (there was insufficient material to cover the entire site, Available <br />soils were analyzed for suitability as plant growth media and found to be suitable with <br />the addition of certain amendments). No topsoil was reportedly available for the <br />portal sites or the No. 1 or No. 3 Mines (PAP page 4-47). Six inches of suitable plant <br />growth media was reportedly used (PAP page 4-47). <br />2) degree of difficulty to complete remaining reclamation (Rule 3.03.2(2)). <br />C-81-025, Page _5_ of _B_ Pages, (date) _2 October 2001_, (initials) ~f l.~~ <br />