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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 /> Roads <br /> The primary permanent access road (former Haul Roads"A"and "B") had only recently melted off, but the travel <br /> surface was generally well maintained. Beyond the upper end of Road "B", Light Use Road 3A travel surface <br /> became increasingly soft. Due to muddy conditions we did not attempt to travel further south than the fenced <br /> shrub plot adjacent to LU-3A. Drainage maintenance work will be warranted at various locations along the mine <br /> entrance access roads and LU-3A, to repair minor erosion and re-set, replace, or install additional straw wattles, <br /> TRM liner material, and rock checks, as soon as ground conditions allow. Minor road outlet erosion was <br /> observed in various locations along the roads, and downcutting was noted along the segment of LU-3A adjacent <br /> to the fenced shrub plot. One significant gully, which resulted in sediment deposition outside the permit <br /> boundary along the Scotchman's Gulch channel near Culvert Installation YA-6 was observed, and NOV CV- <br /> 2009-002 (described above)was issued as a result. <br /> Hydrologic Balance <br /> Snowmelt at the site had recently begun in earnest, and permanent channels in the accessible watersheds were <br /> flowing. Interior portions of the reclaimed mine site still contained significant snow cover on north and east <br /> facing slopes, and roads were too muddy to access upper portions of the reclaimed watersheds. <br /> Permanent Channels <br /> Upper watershed channels could not be accessed. Lower watershed channels that could be accessed were <br /> carrying significant turbid flow. Segments of Channels YPM 6-2 and 5-1, upstream of Pond 12A were observed <br /> rather closely. These channels were carrying heavy flow; but it appeared that maintenance grading and TRM <br /> liner or riprap replacement would be warranted in some locations, where flow had escaped to the outside of the <br /> liner and resulted in side scour. <br /> Sediment Ponds <br /> Sediment Ponds 10, 11, 12, 12A, 13, and 14 were accessible and were inspected. All of the ponds contained <br /> open water and all were discharging. <br /> Pond 10 was inspected in the morning and was discharging clear flow; discharge was through weep hole, as <br /> water level was several inches below top of riser. <br /> Remaining ponds were inspected in the afternoon, and all of the ponds were discharging significant flow. Ponds <br /> 12 and 12A form a two pond system, with the compliance point under the CDPS discharge permit being the <br /> outflow from Pond 12. Discharge from Pond 12 was somewhat turbid, and a sample was obtained and split with <br /> the operator. There was heavy runoff of highly turbid snowmelt runoff into Pond 12 at the time the sample was <br /> obtained. Settleable Solids was analyzed by Grand Junction Laboratories on 4/24/09, and the reported value <br /> was 0.3 ml/I, which is below the CDPS permit standard of 0.5 ml/I. Inflow was discharging through the weep <br /> hole on the spillway riser at the time of the sample, with water level within one inch of the top of the riser. <br /> Pond 12A was discharging turbid flow, but because the pond is in series with Pond 12 and is not a CDPS <br /> discharge point, the discharge was not sampled. It was noted that a spoil spring has developed and was <br /> discharging clear flow of approximately 20 gpm from a point very near the downstream toe of Pond 12A. The <br /> operator will need to initiate monitoring of this spring and be watchful for impacts of the spring on stability of the <br /> Pond 12A embankment(apparent affect on stability to be noted in quarterly pond reports and annual <br /> impoundment certifications). At the time of the inspection, no cracks, slumps, or other indications of <br /> embankment instability were evident. <br /> 4 <br />