INSPEC02902

• Permit No: C1981020
• IBM Index Class Name: Inspection
• Doc Name: Inspection Report
• Inspection Date: 3/30/2005
• Media Type: D
• Archive: No

III. COMMENTS -COMPLIANCE
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,
in the ditch above the elevation of the temporary crossing, but the fill material placed in the ditch needs
to be removed as soon as practicable, to restore the original ditch capacity.
A short segment of silt fence below the berm/ditch at the east end of the waste disposal site topsoil
stockpile had previously been knocked over and covered by construction of the ditch. This segment of
the silt fence was properly replaced.
Backfill and Grading
The interim reclamation/partial backfill areas at the portal bench were not inspected due the small slide on
the upper section of the access road, which prevented access to the site. Reclamation grading was
completed at the Loma Loadout several years ago. The loadout is a largely flat industrial site, and
minimal backfill work,was required.
Processing Waste
The initial, phase.construction,of 3ft~rcoal waste disposal area was completed ~in November,2004t:topsoil
salvage and storage, .foundational:,preparation and cover soil stockpiling, and construction;pt,•drainage and
sediment control facilities. were constructed and several truck loads of material were hauled from the
sediment drying area at McClave Canyon Mine to the disposal area in late NovemberlDecember.
At present, the disposal site is an excavated pit, created by removal of the subsoil/alluvial material that
was stockpiled for use as non-toxic cover during reclamation. The waste material has been loosely
dumped within the pit, which at the present time contains a few shallow puddles; although,sgme drying
is evident since the previous inspection. When the ground conditions have dried sufficiently later this.
spring to.facilitate equipment operation-and allow for propeccompaction,•the;coat,waste..w,illrbe spread ,
and compacted.
It was observed that a couple large slabs of sandstone had slid down into the excavated pit at the
southeast corner, along,with a single juniper tree. This apparently. occurred during the original excavation
work. The tree will needto.be removed prior to placement of coal waste:atthataocation:•-Thesandstone
slabs will need to be removed, if necessary to ensure proper placement, compaction, and stability.:'-
There is a small pile of large sandstone rock, located to the east of the current refuse pit but within the
area that will ultimately be disturbed by disposal area expansion. The reclamation plan indicates that rock
will be distributed on the final reclaimed surface of the disposal area, but the approved plan does not
specifically address stockpiling of the rock for later use. The rock storage area and the access to the
storage area are located within the sediment controlled area, and impacts appear to be minor, however it
is apparent that topsoil was not salvaged from the location prior to disturbance associated with dumping
the rock. See narrative associated with NOV CV-2004-005.
To soil
The topsoil stockpile at the waste disposal area was seeded and mulched in November. Any runoff from
the stockpile would be directed into the sediment pond by ditches at the base of the pile. A silt fence
was installed prior to placement of soil in the stockpile, along the north side of the pile to the outside of
the ditch/berm. Topsoil was salvaged and stockpiled from most areas of disturbance associated with
development of the waste disposal area, but soil apparently was not salvaged from the rock storage area
prior to dumping of the rock. See narrative associated with NOV CV-2004-005.
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