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III. COMMENTS - COMPLL~NCE 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. Unit Train Loadout Facilities Operation Description During its operational phase, the coal haul truck unloading facilities were located on the west side of the train loadout facilities bench and were accessed by three gated entrances to the unit train loadout off of state highway 133. Coal haul trucks could enter by the west gate and stop at the scale house first, which is still in place, or they could enter by the central gate and go directly to the steel covered truck unloading building where they would bottom dump the coal into the concrete tunnel that fed the conveyor system. Sections of these two haul routes were paved while other sections were graveled. All trucks would follow a paved truck loop to the east exit gate. A portable, double walled 12,000 gallon fuel tank was located just south of and adjacent to the truck dump. A material storage area was located within the truck loop. Since the train loadout facility was constructed before SMCRA, no topsoil was salvaged. However, since the scale house and access road were constructed in 1981, topsoil for that project was salvaged. The topsoil stockpile is located off of the facilities bench just west of the truck dump facility. The bottom dumped coal would be delivered to the top of the concrete silos by means of a covered elevating conveyor, run by a motor control center building located near the truck dump. An additional motor control center, mounted on skids, was located next to the truck dump. Each of the concrete silos was 1 10 feet in height and 70 feet in diameter and could hold up to 7,000 tons of coal per silo. The three silos were connected on top by short sections of covered conveyor. A motor control center building, a pump house and a silo fan were associated with the silos. A covered elevated conveyor, run by a motor control center building, transferred coal from the silos to the train loading structure. The steel sided train loading structure was 70 feet tall, 45 feet long and 48 feet wide and contained a 250 ton surge bin and a loading chute. A motor control center building and two deicer storage tanks, 3,500 and 15,000 gallons in size, were also associated with the train loading structure. A pump house, located next to a pond in the adjacent orchard, supplied water to the train loading structure. Located in the central part of the train loadout facilities bench was a steel sided and steel roofed shop building, measuring about 100 feet long, 50 feet wide and 30 feet in height. Next to the shop building was a fuel facility, which had two 500 gallon fuel tanks. South of the shop building was the fenced-in substation. The railroad spur was 2.4 miles long and included a wye off of the main line. The railroad spur crossed over the North Fork of the Gunnison River by means of a bridge constructed by the operator. The spur line also went under a county road earthen overpass, also constructed by the operator. Associated with most of the train loadout buildings and structures were concrete footers and pads. In addition, the sediment control system consisted of one sediment pond and several culverts and ditches. Also, a coal stockpile area was located to the west of the train loadout facilities. The coal had been removed several years ago and the area covered in soil.