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Susan Mowr Page 2 PORTAL BENCH DRAINAGE K With respect to the portion of the violation cited for drainage along the portal bench, WECC believes that no violation occurred. The portal bench area is the center of a great deal of activity. Because heavy equipment is continually working on this bench, the drainage pattern occasionally changes. Particularly during spring thaw, when the area is wet, the area is prone to settling because of the newness of the fill. Each spring when the area has dried sufficiently, the entire area is regraded and regravelled to correct any drainage problems. Eventually this area will stabilize and maintenance required during the spring thaw will no longer be necessary. Contrary to the statement made in the inspection report most of the area drains to the culvert drain on the portal bench. During spring thaw, when the area is wet, drainage on the outside edge of the bench may occasionally fail to drain to the culvert. The material that was over the outslope below the guard rail was a result of winter snow removal. The portal bench is on the north-facing side of the canyon and very little snow melts on its own. The large accumulation of snow and drifting snow must be removed to the outside or outslope. Because of this snow removal, some debris is carried with the snow and is deposited when the snow melts. Each spring WECC hires a number of people to do "environmental work" around the site. The first duty of this crew is to clean up each winter's deposition of debris around the site which results from snow removal. This will be done this year as soon as weather conditions allow. As for the deposition of beet pulp on the outslope, it is an organic waste of beet processing that is not of any environmental concern. In fact it may act as a soil amendment. The amount of erosion on the portal bench outslope resulting from a small amount of water flowing over it was insignificant. This slope, which is above the main access road, has no topsoil and has been very successfully revegetated as part of the Mt. Gunnison Interim Reclamation Program. The success of the revegetation would indicate that the runoff from the portal bench has had no detrimental effect on the slope. The small amount of water which did flow over the outslope area into the access road drain and into Sedimentation Pond MB #2. Accordingly there has been no environmental damage.