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_. This may constitute a violation of both CMLRD and DA re- quirements, since the overcast material could be.deemed as fill by the DA, and failing to minimize impacts to the pre- vailing hydrologic balance by the CMLRD. Site expansion possibilities were discussed with Bi11 Casey and Harold Dole at the time of the inspection, as were al- ternatives to operations to provide greater stability to the site. Once again, the design necessity of the perched access road was called into question by Gambit, Inc. SUBSEQUENT EVENTS: On or about May 19, 1991, the site encountered another hy- drologic event creating features similar to those observed in July 1990. This was confirmed in an inspection of the property on June 4, 1991 by Gambit, Inc. Mine permit boundaries remained unmarked. Permit affected lands remain uncertain as to acres affected. No CMLRD re- quired sign was evidenced at the opening of the access road. The culvert placements agreed to in the CMLRD Technical Revision washed out, and erosion of the pit slopes and perched access road was massive, lending immediate and sig- nificant contributions of sediment to the adjacent drainage, Spring Branch. The mine area was partially inun- dated, lending proof that internal drainage of the mine area was functional and that the mine area was not con- tributing the principal source of sediment from affected lands to Spring Branch. The overcast material along the west berm, the access road, and the culvert fill of the access road over Spring Branch were the major sources of sediment from the event. The ac- tual significance is difficult to• determine. Braided streams commonly carry high sediment loads except during floods, when the event causes an energy imbalance in the stream causing more streambed and streambank erosion as the water attempts to find energy balance by increasing its sediment load. Additionally, impacts to the wetland vegetation may have been relatively minor given the low utility of the streambed vegetation, and noting the marginal utility of that vegetation for wildlife, also, noting that any event could introduce significant sediment loads to the drainage with similar visual effects once high waters subsided. Finally, the nature of erosive soils is common to a major- ity of the soils on the watershed of Spring Branch. More Correspondence of 6/15/91 to Frank G- Starkey, Elbert County Commissioners Office from Bradford Janes, Gambit, Inc. RE: Fondis Vll1 Mine - Summary Report.