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III. Comments - Compliance <br />Below are comments on the inspection. The comments include discussion of <br />observations made during the inspection. Comments also describe any <br />enforcement actions taken during the inspection and the facts or evidence <br />supporting the enforcement action. <br />noted in this area and NOV C-91-006 was issued because of the <br />following: <br />The hay bails in the drainage way acted as a sediment trap only <br />for about one half of area leaving the other half uncontrolled. <br />In addition the reclamation plan contained a request for a small <br />area exemption (SAE) but did not demonstrate that a pond would <br />not be necessary for runoff to meet effluent standards as <br />required in Rule 4.05.2(3)(a). Such a demonstration could come in <br />the form of designs for small surface depressions that would trap <br />the water from a 10 pear 24 hour event and not discharge. <br />All reclaimed areas were walked and there did not appear any <br />erosion. All reconfigured drainage channels were hydrologically <br />stable. All reclaimed slopes were stable from slides. <br />On the Cameo seam bench the upper diversion ditch was walked and <br />appeared to be functioning properly. The revegetated Cameo <br />bench/fill was greening up from the abundant precipitation. <br />During a check of the records conducted at the Division office. <br />It was noted that the liability insurance had expired in April of <br />this year and that the NPDES permit had expired in December 1990. <br />I spoke with Ann Ihlanfeldt of the Colorado DOH and she said that <br />the mine is currently in compliance with NPDES monitoring <br />requirements. They have received quarterly monitoring reports and <br />have not noted any violations. The NPDES permit had expired last <br />December but was granted an extension. <br />