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2016-06-23_INSPECTION - C1981012
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2016-06-23_INSPECTION - C1981012
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Last modified
8/24/2016 6:24:06 PM
Creation date
6/24/2016 8:22:24 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981012
IBM Index Class Name
Inspection
Doc Date
6/23/2016
Doc Name
OSM Inspection Report (Emailed)
From
OSM
To
DRMS
Inspection Date
6/7/2016
Email Name
RDZ
JRS
Media Type
D
Archive
No
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6 | Page <br />Surface Mining Control and Reclamation Act or the Colorado Surface Coal Mining Reclamation <br />Act (“pre-law” disturbances). However, we observed that areas away from the un-reclaimed <br />DWDA #2 did not have coaly material at the surface, leading to the conclusion that coal fines <br />might be blown from the un-reclaimed surface into the stream buffer zone. NECC staff indicated <br />that the Abandoned Mine Lands (AML) folks have done work in this area and river banks that <br />are covered in topsoil rather than coal fine material are likely to have been reclaimed under the <br />AML program. We were unable to view photos or other records of pre-law disturbance areas <br />during this inspection. Although pre-law disturbances are not retroactively held to program <br />standards, disturbances made under the program (such as DWDA #2) must be appropriately <br />managed and maintained, and cannot exacerbate environmental hazards with immunity due to an <br />area’s pre-law status. <br />We discussed this area during the closeout meeting. Perimeter berms are in good condition and <br />function to keep refuse material from slumping or being transported by surface runoff into the <br />stream buffer zone. The concern in that wind could blow the exposed coal fine material away <br />from the designated disposal area. Ideally, DWDA #2 would be reclaimed to prevent such off- <br />site impacts. Mr. Head seemed amendable to this idea, indicating that he would look into it as a <br />potential winter project. <br />Rule 4.15: Revegetation <br />Vince Massarotti (NECC) was spraying weeds during the inspection. Frequently encountered <br />species include houndstongue, bindweed, thistle, mullein, and cheat grass. <br />The reclaimed small area exemption (SAE) near the old Allen Mine portal was in good <br />condition. Grasses and forbs are well-established and woody stems are establishing where the <br />water tank and electrical substation used to be. <br />Rule 5.02.4(1): Availability of Records <br />All required records were located on site during the inspection. Several items required NECC <br />staff assistance to find or to update such as the liability insurance certificate, the most recent <br />bond cost calculation, water consumption records, and pond certifications. NECC has expressed <br />interest in transitioning from paper to electronic records. As long as the public could access the <br />records upon request, this would be acceptable. In the meantime, better organization would be <br />extremely helpful. <br />Maintenance Items: <br />x Please keep Mr. Zuber apprised of potential vegetation sampling activities this summer. <br />x If on-site permit documents are not transitioned to electronic records soon, better <br />organization would be appreciated. <br />x Please forward the Pond 007 and 008 bathymetry results to Mr. Zuber. <br />x There are low areas and bare spots on top of the Pond 008 dam. <br />x Rilling is occurring just northeast of the RDA. Although this area is not part of the RDA, <br />it is contributing sediment to Pond 008 and should be stabilized. <br />x Coal refuse fines have accumulated beneath the RDA conveyor system, which has fallen <br />into disrepair. These fines should be removed and properly disposed of. <br />x Although NECC has been working to update Map 13, we reviewed the draft copy in the
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