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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. General Comments This was a complete inspection of the Munger Canyon Mine, including Loma Loadout, mine site in Munger Canyon, and office records at the McClane Canyon Mine office facility. I was not accompanied by an operator representative. I checked in with receptionist at mine office prior to inspection at mine site, and discussed my observations and probable enforcement action with Chuck Silengo of CAM during my subsequent inspection of the McClane Canyon Mine. I contacted consultant/permitting contact Jim Stover on August 17, and advised him of my observations and concerns, and indicated that I would be issuing a notice of violation for observed sediment control failures at the reclaimed Munger mine bench area. Weather was clear, warm, and relatively humid on August 16. Reclamation grading and stabilization seeding of cover crop had been completed in late July (confirmed by a brief site inspection on July 30). On July 30, site conditions were very dry, with no recent precipitation and no germination of the "Quickguard" cover crop. In contrast, on August 16, soils were moist, with evidence of relatively recent precipitation in and adjacent to the mine site permit area, and the "Quickguard" cover crop had recently germinated. Chuck Silengo indicated that there had been a relatively intense rain storm in the mine vicinity on the night of August 2, with additional lighter rain showers since that time. Description of Enforcement Actions NOV CV-2007-003 NOV CV-2007-003 was issued August 21, 2007, based on observations made during the inspection on August 16. The NOV was issued for: Failure to design, construct, and maintain appropriate sediment control measures to: a) prevent, to the extent possible, additional contributions of sediment to streamtlow or to runoff outside the permit area; b) meet the applicable State or Federal effluent limitations; and c) minimize erosion as necessary to provide protection for topsoil, vegetation, and the hydrologic balance. Specifically, five silt fence sediment control structures at the reclaimed Munger mine bench area had been undercut or knocked over and over-topped by runoff resulting from a rain storm that had occurred prior to the inspection on August 16. Minor erosion and sedimentation resulted; the structures had not been repaired and were non-functional at the time of the inspection. The NOV applies to the Munger Mine bench area that was regraded, topsoiled, and seeded with a temporary cover crop in June and early July 2007. The text of the NOV in its entirety is included as Attachment 1, to this inspection report. Digital photos that document site conditions, including failed silt fences and associated erosion, are described below. The referenced photos are included as Attachment 2, to this inspection report. As noted in the NOV narrative, following recent completion of reclamation grading and seeding in the mine bench area, one silt fence was installed in SAE #2 at the lower end of the Channel "H" west side berm, another silt fence was installed immediately to the east, in SAE #1, at the lower end of the Channel "H" east side berm, and three additional silt fence segments were installed (also in SAE #1 ), at low points along the north side perimeter berm, further east of Channel "H". Each of the 5 silt fence installations had failed and had not been repaired prior to the inspection. Both of the silt fence segments located along the Channel "H" berms had been under-cut by concentrated flow, and short rill and gully segments extended from the silt fence into the riprap of Channel "H". Minor rill erosion from 3