2016-06-30_INSPECTION - C1981012

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Surface Mining Control and Reclamation Act or the Colorado Surface Coal Mining Reclamation Act ("pre -law" disturbances). However, we observed that areas away from the un -reclaimed DWDA #2 did not have coaly material at the surface, leading to the conclusion that coal fines might be blown from the un -reclaimed surface into the stream buffer zone. NECC staff indicated that the Abandoned Mine Lands (AML) folks have done work in this area and river banks that are covered in topsoil rather than coal fine material are likely to have been reclaimed under the AML program. We were unable to view photos or other records of pre -law disturbance areas during this inspection. Although pre -law disturbances are not retroactively held to program standards, disturbances made under the program (such as DWDA #2) must be appropriately managed and maintained, and cannot exacerbate environmental hazards with immunity due to an area's pre -law status. We discussed this area during the closeout meeting. Perimeter berms are in good condition and function to keep refuse material from slumping or being transported by surface runoff into the stream buffer zone. The concern in that wind could blow the exposed coal fine material away from the designated disposal area. Ideally, DWDA #2 would be reclaimed to prevent such off- site impacts. Mr. Head seemed amendable to this idea, indicating that he would look into it as a potential winter project. Rule 4.15: Revegetation Vince Massarotti (NECC) was spraying weeds during the inspection. Frequently encountered species include houndstongue, bindweed, thistle, mullein, and cheat grass. The reclaimed small area exemption (SAE) near the old Allen Mine portal was in good condition. Grasses and forbs are well-established and woody stems are establishing where the water tank and electrical substation used to be. Rule 5.02.4(1): Availability of Records All required records were located on site during the inspection. Several items required NECC staff assistance to find or to update such as the liability insurance certificate, the most recent bond cost calculation, water consumption records, and pond certifications. NECC has expressed interest in transitioning from paper to electronic records. As long as the public could access the records upon request, this would be acceptable. In the meantime, better organization would be extremely helpful. Maintenance Items: • Please keep Mr. Zuber apprised of potential vegetation sampling activities this summer. • If on-site permit documents are not transitioned to electronic records soon, better organization would be appreciated. • Please forward the Pond 007 and 008 bathymetry results to Mr. Zuber. • There are low areas and bare spots on top of the Pond 008 dam. • Rilling is occurring just northeast of the RDA. Although this area is not part of the RDA, it is contributing sediment to Pond 008 and should be stabilized. • Coal refuse fines have accumulated beneath the RDA conveyor system, which has fallen into disrepair. These fines should be removed and properly disposed of. • Although NECC has been working to update Map 13, we reviewed the draft copy in the 6 1 Page