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t <br />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 <br />inspection and the facts or evidence supporting the enforcement action. <br />The objective of this inspection was to conduct the field portion <br />of the special focus inspection at the Trapper Mine. OSM personnel <br />had met with Division personnel the previous week at the Division's <br />Denver office in a review and discussion of Trapper's Permit <br />Application Package (PAP), and to prepare for this field <br />inspection. The intent of this special focus inspection was to <br />determine to what degree the state program was ensuring that there <br />would not be any offsite impacts to the surface waters due to <br />mining at Trapper. Joe Dudash represented the state. OSM personnel <br />included Joe Wilcox and Mitch Rollings. The operator was <br />represented by Forrest Luke and Larry Henderson. It had been agreed <br />to, by OSM and the Division in the previous week's meeting, that <br />the special focus field inspection would involve examination of <br />surface water monitoring reports, NPDES sites, the Flume Gulch <br />monitoring station, and spoil springs. The field inspection was <br />conducted on September 3 and 4, 1996. <br />During the course of the special focus inspection, items that may <br />not have dealt directly with the focus topic, but that may have <br />been relevant to the immediate area being inspected, were also <br />discussed. Comments on these items follow the special focus topics <br />discussion in this report. <br />BIIRFACE WATER MONITORING REPORTS <br />The surface water monitoring reports were examined for the 1995 <br />calendar year. The surface water monitoring requirements are shown <br />on pages 4-241b and 4-241c of Volume 4 of the PAP. There are <br />weekly, monthly, quarterly and semi-annual water sampling <br />requirements at the NPDES sites. There are a total of fifteen NPDES <br />sites, all represented as the outfalls of sedimentation ponds. <br />Spoil springs need to be sampled once a year if the flow exceeds 5 <br />gpm. The spoil springs that are sampled are the Johnson Gulch <br />spring in the Johnson drainage, the Cottonwood and Wapiti springs <br />in the Coyote drainage, and the West Buzzard spring in the West <br />Buzzard drainage. Finally, Flume Gulch is sampled semi-annually for <br />baseline data. <br />Examination of the surface water monitoring reports demonstrated <br />that Trapper Mine .was following the required monitoring plan, <br />although several observations were made by OSM personnel. First, <br />1 <br />