INSPEC00060 - Laserfiche WebLink

Home Browse Search

III. COMMENTS -COMPLIANCE Below are comments on the inspection. The comments include discussion of observations made during the inspection. Comments also describe any enforcement actions taken during the inspection and the facts or evidence supporting the enforcement action. General Comments This was a partial inspection of the McClane Canyon Mine, comprised of two separate site visits, the first on July 5 and the second on July 9. Weather was clear and very warm both days; site conditions were dry. I conducted the first site visit with no operator contact present. On the second visit, I was accompanied by Jim Stover, engineering consultant to the operator, and Mike Boulay, DRMS hydrologist. Mine Manager Gary Isaac was contacted prior to the beginning of the inspection on July 9. The mine was not operating on July 5 due to holiday, but was operating on July 9. DRMS recently approved a permit transfer/succession of operator application; permittee is now McClane Canyon Mining LLC (MCM). July 5 Observations Drainage structures were generally well maintained. The ditch behind the shop on the mine bench had been recently graded. The outlet end of Culvert "K", near the sediment pond inlet was previously repaired, but there is still a narrow shard of metal hanging down from the top of the pipe that should be cut off. • Site conditions were very dry; East Salt Creek and McClane Creek were both dry. Water level in the sediment pond was approximately 1 foot below the elevation of the gated primary spillway pipe inlet. • It appeared that no additional coaly sediment had been moved from McClane Mine locations to the Munger Waste Disposal site (which has now been reclaimed). There was a small quantity of coaly sediment in the sediment drying area, and the "in-ditch" sediment trap was full of sediment. July 9 Observations The main purpose of this inspection was to view the location of a new coal waste disposal area the operator is planning to construct within the McClane Canyon permit area. This disposal site would replace the disposal area in the Munger Canyon permit area that has now been reclaimed. MCM recently submitted a minor revision application that would allow for drilling of five geotechnical investigation holes within the disposal area footprint and an alluvial monitoring well down-gradient of the anticipated disturbance, between the disturbed area and East Salt Creek. Jim Stover explained that the disposal area is planned to be located in the general area now occupied by the sediment pond and soil stockpiles. These existing facilities would be relocated further to the west; with the new sediment pond located such that all disturbance areas associated with the waste disposal site and stockpiles would drain into the pond, eliminating the need for the stockpile area small area exemptions. The general area of proposed disturbance was walked, and details of proposed well construction and location were discussed. Based on comparison of the site development described with East Salt Creek Creek Alluvial Valley Floor (AVF) boundaries depicted on permit Figure 4.1-2, it would appear that portions of the proposed disturbance (e.g. stockpiles and sediment pond) might fall within the boundaries of the undeveloped rangeland AVF of East Salt Creek. This will need to be addressed within the technical revision application that will be submitted in association with the permitting of the proposed waste disposal area, and applicable narrative within Section 4.1.2.5 of the permit application will need to be properly revised. Current sediment pond and stockpile disturbances at the mouth of McClane Canyon appear to be located up-gradient of the East Salt Creek AVF boundary, but text in various portions of Section 4.1.2.5 of the existing permit appears to be contradictory in this regard. Clarification of the AVF section text of the permit will be warranted in association with the anticipated technical revision application. It is recommended that the footprint of the coal waste disposal pile be located entirely outside of the delineated East Salt Creek alluvial valley floor boundary, to avoid potential conflicts with "restoration of essential hydrologic functions" requirements of the regulations. 3