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o ~ <br />III. Comments - Compliance <br />Below are particular issues with regard to any of the compliance items. <br />Enforcement actions resulting from failure to comply with the Act, Rules and <br />Regulations, and the permit also are identified below. <br />Cessation Order C-85-043 <br />1. CO C-85-043 was issued for storage of equipment, supplies, machinery and <br />petroleum products in an area not approved for such storage or disturbance. <br />The storage area is outside of the middle creek office/shop small area <br />exemption area. <br />Material included 11 drums of cable tube, 6 plastic 5 gallon buckets of cable <br />tube, an old power shovel, numerous roof bolts, culverts, cable spools and <br />assorted mining equipment and supplies. The total area being used for storage <br />was paced off and was approximately 240 feet by 150 feet. Referring to Map <br />TR-1 and using the small area exemption ditch as a reference point, an area <br />approximately 70 feet by 240 feet outside of the approved disturbed area had <br />been disturbed by storage. <br />It was difficult to discern (due to the fairly flat terrain) what portion if <br />any of the storage area would drain into the small area collection ditch. The <br />entire office area occupies a low spot, and some ponding would be likely to <br />occur in the storage area. The potential for disturbed surface water from the <br />storage area entering the creek was low. At some point in time topsoil had <br />been stripped from the area in question and placed in a stockpile to the south <br />of the storage area. With respect to environmental harm, the most serious <br />concern was with storage of petroleum products in an uncontrolled manner on <br />the Middle Creek Alluvial Valley Floor, and the resultant potential for ground <br />water degradation. No evidence of spillage was noted during the inspection. <br />The operator offered no explanation as to why the violation had occurred. It <br />appeared that the site was being used for storage because it was flat, easily <br />accessible and immediately adjacent to the shop facility. The fact that the <br />area had not been permitted for storage of supplies and petroleum products was <br />overlooked by the operator. <br />The shop area was inspected on May 23, and reinspected on May 24. Photo <br />5/85/E-20 was taken on May 23. Photos 5/85/F-16 through 5/85/F21 were taken <br />on May 24. <br />2. NOV C-85-044 was issued for failure to promptly apply soil stabilizing <br />practices to topsoiled areas in order to control erosion. Specifically, <br />contour furrows had not been installed in the fall of 1984 on topsoiled slopes <br />of the Mine 3 Pit east of the Mine 3 haul road corridor. <br />The NOV applied to the entire area described above (approximately 50 acres). <br />