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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 also describe any enforcement actions taken during the <br />inspection and the facts or evidence supporting the enforcement action. <br />This was a complete inspection conducted by Tom Kaldenbach and David Berry of the Colorado <br />Division of Minerals and Geology. Forrest Luke represented the operator on Monday, Tuesday <br />morning, and Wednesday; Billy Nicholson represented the operator Tuesday afternoon. <br />The ground was wet from heavy rains that fell throughout northwestern Colorado over the four <br />days preceding the inspection. Forrest Luke reported that 2.2 inches of rain fell during the <br />period from the morning of 9/18/97 to the morning of 9/19/97. It was a fairly steady rain rather <br />than a series of storms. The precipitation data were reviewed during the inspection. Trapper <br />uses a standard 8-inch, nonrecording rain gauge for collecting precipitation. Measurements are <br />recorded daily. <br />As shown on page 4-185 of the permit application, Trapper's ponds are designed to contain the <br />runoff from a 24-hour, 1.4-inch precipitation event (a 10-year event). Spillways are designed to <br />safely pass the runoff from a 24-hour, 1.8-inch precipitation event (a 25-year event). The <br />reported 2.2 inches of rain thus provided an opportunity to examine the impacts on Trapper of a <br />greater than 25-year precipitation event. <br />Overall, the Trapper Mine weathered the heavy rains well. Evidence of the large amount of <br />runoff was widespread in the permit area: gullies in access roads, in drainage channels, and on <br />pond inslopes; ponds filled with water or in some cases sediment; boulder-sized rock riprap <br />transported in drainage channels, sturdy vegetation (cattails) flattened by strong currents in and <br />next to drainage channels. <br />There was only one offsite impact, and it was minor. About ahalf-dozen hay bales belonging to <br />an adjacent landowner were damaged by runoff from the mine. The bales had been set next to <br />and in a drainage channel. Trapper is working toward a resolution with the farmer. <br />What was striking was how well the revegetated areas held up in the heavy runoff. Topsoil <br />stockpiles and most other vegetated hillslopes showed little or no evidence of erosion. Erosional <br />down-cutting was minimal in heavily vegetated drainage channels. <br />AVAILABILITY OF RECORDS <br />All required records were on site (refer to the attached records checklist). <br />SIGNS AND MARKERS <br />Mine ID signs and blasting notice signs were at the proper locations and displayed the proper <br />information. Permit boundary signs and topsoil markers were also properly displayed. <br />ROADS AND HYDROLOGIC BALANCE <br />Roads <br />Hau/ Roads. All haul roads were in good condition, although the wet weather had made them <br />slippery. Trapper suspended coal hauling for more than a day to allow the haul roads to dry. <br />Embankments on haul roads were in good condition; in places there were minor gullies or rills. <br />Page 3 <br />