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III. COMMENTS - COMPLIANCE <br /> Below are comments on the inspection. The comments include discussion of observations made <br /> during the inspection. Comments also describe any enforcement actions taken during the inspection <br /> and the facts or evidence supporting the enforcement action. <br /> General Comments <br /> This was a complete inspection of the Munger Canyon Mine, including Loma Loadout, accessible portions of the <br /> mine site in Munger Canyon, and office records at the McClane Canyon Mine office facility. I was not <br /> accompanied by an operator representative. On the initial site visit March 17, 1 conducted field inspection of the <br /> loadout and mine site. I reviewed records on file at the mine office on March 21. Gary Isaac was contacted prior <br /> to my site inspection on March 17. Mine staff was not on site on March 21, due to Good Friday holiday; however <br /> a security guard was in the office during my records review. <br /> Weather on 3/17 was cloudy and cool. I was able to drive the entire length of the reduced width haul/access <br /> road to its upper terminus, at the lower end of the fully reclaimed portal access road. There was patchy snow <br /> cover along upper sections of the road. The road surface in the upper areas was frozen but was beginning to <br /> that and was a bit soft by around 10am when I departed. <br /> was able to hike up the reclaimed road slope only a relatively short distance, possibly'/< of the distance to the <br /> portal area. Beyond that point, the slope curves slightly, presenting a more directly northerly exposure, and <br /> along this upper segment a deep, continuous snow cover was still present, which was not practicable or safe to <br /> traverse, and which prevented detailed observations. <br /> Availability of Records <br /> Required records were on file and up-to-date through the 4th quarter, with a couple exceptions noted in the <br /> Records form attached. The RN-5 Findings document and DRMS inspections subsequent to 11/07 need <br /> to be placed on file. <br /> Roads <br /> The reduced width access road was passable; later in the day access would likely have been difficult due to <br /> muddy conditions. <br /> Hydrologic Balance <br /> Lower elevations and south facing slopes in Munger Canyon are snow free; north facing slopes have patchy <br /> snow cover at lower elevations, solid snow cover at higher elevations. There was a trickle of snow-melt flow in <br /> Munger Creek at the time of the inspection. <br /> The silt fence at the lower road topsoil stockpile reclamation site SAE had functioned properly and was in good <br /> condition. The waste disposal area sediment pond contained a shallow pool of water, well below the primary <br /> discharge inlet level. Ditches, culverts, and berms associated with the reclaimed waste disposal site, cover soil <br /> stockpile site, waste area topsoil stockpile site, and lower road topsoil stockpile site appear to have functioned <br /> well and appeared to be in good condition. There was patchy remnant snow cover in these locations. <br /> Backfill and Grading <br /> Backfilled slopes along the lower reclaimed access road that I was able to observe appeared to have held up <br /> well, with no problems noted. There was patchy snow cover along the segment, with some drifting and deeper <br /> accumulations along the reclaimed channels and shaded areas. <br /> 3 <br />