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<br />III. Comments - Compliance <br />l;elow are particular issues with regard to any of the above compliance items. <br />Enforcement actions resulting from failure to comply with the Act, Rules and <br />Regulations, and the permit also are identified below. <br />Roads (4.03 <br />A small amount of runoff from the yard area at the mine had apparently flowed <br />over the culvert at the head of the sediment pond access road and flowed down <br />the road to the pond. A small berm or ditch should be constructed to insure <br />that all drainage from the yard is directed into the collection ditch. <br />Topsoil (4.Oti) <br />Excess Spoil and Development Waste (4.09) <br />Revegetation 4. 5 <br />The potential re vegetation problems associated with the underground <br />development waste was discussed with Mr. Reschke. Sampling has indicated that <br />both the rock waste and the old surface mine spoils which Grand Mesa has <br />~ proposed for use as non toxic cover exhibit inhibitory EC and SAR levels. <br />Vegetation establishment will be made more difficult by the low precipitation <br />and southern exposures, and the fact that the major portion of the area was <br />disturbed by previous mining operations and no topsoil was salvayed. Interim <br />revegetation efforts have not been successful. <br />Air Resource Protection (4.17 <br />The major environmental concern at the rail load-out is the effect of blowing <br />coal dust on residents of Delta who live adjacent to the open coal stockpiles <br />at the load-out. In response to public comments, the Department of Health-Air <br />Quality Division has required Western Associated Coal to implement a dust <br />suppression plan at the load-out. The plan includes snow fencing to reduce <br />wind velocity on the surface of the piles ano the application of a chemical <br />binder. <br />The fact that our regulations do not allow for permit areas to be located <br />within 300 feet of occupied residences, unless the requirement is waived by <br />all affected individuals was discussed with Mr. Collins. This issue will be <br />handled tlrrouyh the pennittiny process. f+lr. Collins indicated that he felt <br />the permit boundaries and stockpile locations could be moved, if necessary. <br />