INSPEC02071

• Permit No: C1981071
• IBM Index Class Name: Inspection
• Doc Date: 9/30/1991
• Doc Name: MINE SITE EVALUATION INSPECTION REPORT
• Media Type: D
• Archive: No

".VSPECTION REPORT Page 2
requirement. This will not be the case if those bottom line of
defense ponds are removed.
The operator was not aware of the requirement for the double
spillway for the stock ponds but instead indicated that they are
constructing them to Soil Conservation Service standards for the
impoundment size which require only one spillway. Apparently there
are to be nearly sixty of these ponds in the reclaimed area when they
are finished. The question was asked about changing the configuration
of the spillway through the embankment to meet the double spillway
standard. At the time, I wasn't sure if that would be acceptable.
After reviewing the question with my supervisor, it is an acceptable
alternative.
That being resolved, leads to another problem that rises from the
placement of these ponds on the reclaimed area. As permanent
impoundments, these "stock ponds" as well as other "ponds" on the
area will have to have a permanent pool of water throughout the year.
It is my impression that this is not the case for the approval of
the ponds on this mine. One should consider that criteria and
address it prior to bond release application.
Another area of concern that should have been emphasized more
during the closeout, was road construction on the reclaimed area. I
did not discuss it openly because I felt there was no regulatory
backup for the situation but in reviewing the matter more with my
supervisor, I have found that it may be a problem on the mine. Roads
are being redone on the mine form old haul roads and others are being
added. All of them are to be access for the post mining land use.
That is acceptable as long as they are approved as such, however, the
standards to which they are being built are of question. The
operator has designed them to access road standards. My supervisor
indicates that the State regulations concerning roads are being
changed to meet Federal standards. That being the case, the
regulations list two classes of road, one being primary and the
other being ancillary. I believe it is the position of the operator
that these roads will fall within the ancillary status which have the
least stringent design standards. That is not the case, roads in 30
CFR 816.150 (a) (ii) and (iii) are upgraded from ancillary to primary
if they are used for a period exceeding six months or to be retained
for an approved postmining land use. That being the case these roads
being left and built on the areas on this mine will have to meet
primary road design standards. There may be some grandfather issues
to be resolved or identified in this case but I would be aware of the
possibilities incurred in road construction.
The second issue discussed in the closeout session, was one of
rills and gullies and their approved plan for that. As they are now,
I know they are within compliance with their approved plan. However,
that plan allows 36 inch gully formation over 20 per cent of the
length of the ditch prior to any remedial work. In addition, there
seems to be no requirement for an annual submittal of a report
addressing the condition of gullies on the mine and committments as
to when or how they will be redone. The operator had a report for
1989, of which I was given a copy but as to '90 and '91, there was
none. The State inspector and I measured one of the gullies and made
notes for reference in the future. It appears as though that is what
is needed to keep track of the conditions in ocder to reference them