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III. COMMENTS -COMPLIANCE <br />Elk Creek C-1981-022 <br />23 August 2005 ~~1-- <br />PS`sa.. <br />Below are comments on the inspection. The comments include discussion of observations <br />made during the inspection. Comments also describe any enforcement actions taken during <br />the inspection and the facts or evidence supporting the enforcement action. <br />This was a partial inspection of the Elk Creek and Sanborn Creek Mines conducted by Jim <br />Stark of CDMG on 23 and 24 August 2005. Jim Burnell of CDMG and Jim Kiger of Oxbow <br />accompanied me. The mine was actively producing coal at the time of the inspection. The <br />weather was warm and sunny and the ground was dry. <br />Roads: - The A and C Gulch fire roads appear to be stable. There were no signs of erosion <br />or cracking or slumping of the backfilled roads. <br />-The mine access road is a paved road. The road is well maintained and in good condition. <br />- The Coal Gulch Road and the road spurs to the Sanborn Creek gob vent boreholes were all <br />stable and well maintained at the time of the inspection. There were no erosional problems <br />noted on the roads. <br />-The roads in Bear Creek for the Elk Creek gob vent boreholes were all well maintained and <br />stable at the time of the inspection. There were no erosional problems noted on any of the <br />roads. <br />-The road to the Hubbard Creek fan and substation was well maintained and stable at the <br />time of the inspection. <br />Hydrologic Balance: - Pond B contained water at the time of the inspection but was not <br />discharging. The embankment was well vegetated and appeared to be stable. No erosional <br />problems were noted. This pond needs to be cleaned. <br />- Pond D contained water but was not discharging at the time of the inspection. The <br />embankment was well vegetated and stable. No erosional problems were noted. The pond <br />has an oil boom and it was in place. This pond needs a trash rack and anti-vortex device <br />installed on the primary spillway. <br />- Pond F had a small pool of water in the bottom at the time of the inspection. It was not <br />discharging and it did not appear to have discharged in the recent past. The pond <br />embankment was stable and well vegetated and no erosional problems were noted. <br />- The ditches around the Hubbard Creek fan and substation were all clear and stable and <br />appeared to be functioning as designed. The clean water ditch around the site was stable <br />and in good condition. The rock splash pan at the end of the clean water ditch has filled in <br />with sediment (from a single recent storm event). <br />-The upper Hubbard Creek pond contained a small amount of water. The pond <br />embankment was well vegetated and appeared stable. No erosional problems were noted <br />on the embankment. <br />- The freshwater intake gallery was in good condition at the time of the inspection. Jim Kiger <br />indicated that OMLLC may do some work on the gravel filter bed this fall. <br />Backfilling and Grading: -The reclaimed Sanborn Creek Mine portal and substation area <br />remains stable. There was no cracking or settling of the backfilled material at the time of the <br />inspection. No erosional problems were noted on the backfilled and regarded areas. <br />- The pad for GVB-LW-04-02 was being reclaimed at the time of the inspection. Part of the <br />area appeared to be at AOC and part of the area (where the equipment operator was still <br />working) was not. The work should be done by next month's inspection. <br />