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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. This was a partial monthly inspection of the Loma Loadout and Munger mine site. There was no operator contact present during inspection. Weather was clear and mild. There had been a rainfall event in the Munger watershed on the night of October 18, approximately %:" of precipitation was recorded in the rain gage at the Munger portal area. There also appeared to have been recent rainfall at the Loma loadout, likely from the same storm. Offsite Suooort Facilities (Loma Loadout Conditions were generally similar to those described in the September inspection report, with the exception that fall rains have resulted in new growth of the seeded western wheatgrass, and perennial shrubs including greasewood, forage kochia, and volunteer seepweed (Suaeda), also appear more robust than in early September. As noted in the September report, annual (non-noxious) weedy species are the visually dominant species. Perennial establishment seems to have been suppressed in the areas with dense growth of annual mustard, with apparently better establishment in areas dominated by the summer annuals. A couple years will need to pass to assess the success of the most recent seeding effort. Roads The most recent rainfall event apparently was not as intense in the Munger Canyon watershed as the event that occurred prior to the previous inspection. Road surfaces, ditches, and culverts had been maintained subsequent to the September inspection, and were generally in good condition. However, maintenance is warranted in several locations. At the first (upper) and third 18" CMP road culverts below the mine bench, further maintenance is still required. The fabric outlet sleeves associated with each culvert installation were previously torn off and need to be replaced. At the fourth CMP road culvert, the inlet was partially obstructed by a large grass clump that needs to be removed. Installation of a series of water bars between the third and fourth CMP road culvert inlets is recommended, to direct road drainage to the inside road ditch. Recent flows had washed out several of the water bars that had been recently installed along the two-track road that provides to access to the small topsoil stockpile adjacent to the lower segment of the Munger Canyon haul road. These water bars need to be restored and enlarged, as appropriate. Road drainage ditches and culverts recently installed in association with the recent waste disposal area development and road realignment appeared to have functioned well. However, some maintenance is warranted. Some rock and debris has lodged immediately in front of the inlet to the 36" CMP road culvert located adjacent to the waste disposal area sediment pond, and needs to be cleaned out. The outside road ditch segment (north side of road) between the straw bale pile and the refuse area topsoil stockpile needs to be graded to remove sediment build-up. Hydrolooic Balance In the refuse area vicinity, the sediment pond appears to have been fully excavated and bermed. Anew 6" PVC primary spillway tube had been installed; inlet elevation approximately 15" above level of the shallow water currently pooled in the pond. A technical revision to eliminate the existing open channel spillway and install a new CMP spillway was very recently approved by the Division, but the approval decision is not yet final. Upon final approval, the approved spillway modifications will need to be implemented. There was evidence of additional flow in diversion and collection ditches in the portal area. Diversions and sediment control measures appear to have functioned effectively. There was standing water in the SAE-1 sump 3