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III. COMMENTS -COMPLIANCE <br />Below are comments on the inspection. The comments include discussion of observations made <br />during the inspection. Comments also describe any enforcement actions taken during the inspection <br />and the facts or evidence supporting the enforcement action. <br />Background <br />This was a partial site inspection of the Munger Canyon Mine, conducted by pan Mathews of the DMG <br />Grand Junction Field Otfice. Mine Manager Walter Whitledge had contacted me on the afternoon of <br />August 2, to report a flooding problem that resulted from an intense rain storm event on the evening of <br />July 25. A storm cell had tracked across an area of the Roan Cliffs, Bookcliffs, and the Grand Valley that <br />afternoon and evening, causing flood damage in various locations. The main portion of the storm cell <br />apparently bypassed the McClave Creek Drainage, but upper portions of the Munger Canyon watershed <br />apparently received very intense rainfall. On August 2, Chuck Silengo of CAM had checked the roads <br />and drainage structures at Munger, and discovered that Munger Creek and its tributaries had flowed very <br />high, and that drainage structures in several locations had been impacted. The main problem was at the <br />36" road culvert that routes undisturbed drainage from watershed "F" beneath the Munger Canyon Haul <br />Road. The culvert is located immediately adjacent to the coal waste disposal area sedimentation pond. <br />The open channel emergency spillway for the pond discharges into the undisturbed watershed "F" <br />drainage channel immediately upstream of the road culvert inlet. Flood flows in the watershed "F" <br />drainage channel had carried large volumes of fine sediment, cobbles and small boulders from higher in <br />the watershed. The culvert was clogged and buried by sediment, and water flowed out of the channel, <br />over the road, and backed up through the open spillway, filling the pond to the level of the emergency <br />spillway with water, and an unknown but likely substantial quantity of sediment. <br />I had inspected the site on the afternoon of July 25, prior to the storm event that evening. At that time, <br />the sediment pond was dry, with maximum sediment and water retention capacity (there had been no <br />appreciable inflow to the sediment pond since it had been constructed). The 36" CMP was clear and <br />unobstructed. All aspects of the drainage control plan appeared to be in compliance with the approved <br />plan, just prior to the storm event. <br />Site Observations <br />Coal Waste Area Sediment Pond <br />I arrived at the site at 08:30 on the morning of August 3. Weather was clear, warm, and humid. There <br />had been light rain the previous evening. There was muddy flow in East Salt Creek, no flow in Munger <br />Creek at the time of the inspection. Walter Whitledge of CAM, and Jim Stover of J.E. Stover and <br />Associates, engineering consultant to CAM, accompanied me on the inspection. <br />The waste disposal area sediment pond and adjacent culvert were as previously described. Sediment and <br />rock had completely filled in the ephemeral channel upstream of the culvert for a distance of 150 feet or <br />more. Flow had escaped the channel along this segment, and had come close to overtopping the low <br />berm between the channel and the sediment pond, but apparently did not. Inflow to the pond was solely <br />from water that backed up through the emergency spillway. There were cracks along the banks of the <br />incised pond along the west side (adjacent to the channel) and along the haul road fill slope at the north <br />edge of the sediment pond, apparently related to movement associated with the saturated materials. <br />Water could be heard trickling into a submerged crack along the west side of the pond. The 36" CMP <br />inlet was buried, pond was full of water and unknown quantity of sediment, which had obviously buried <br />the inlet of the 6" CMP gated primary spillway. <br />Based on my observations, it would appear that the intensity and duration of the storm within the upper <br />Munger Creek watershed and its larger tributaries (including the Watershed "F" channel) was such that <br />peak flows generated in the drainage channels significantly exceeded those associated with the 10 year, <br />3 <br />