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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. This was a complete quarterly inspection of theMunger Canyon Mine Site, conducted by DanMathews of DMG. Chuck Silengo accompanied on the mine site inspection, and Walter Whitledge was contacted at the mine office. Inspection began at gam at theLoma Loadout, with no operator contact present. Mina site proper was inspected at 11:50 a.m.. Weather was clear and mild. East Salt Creek was flowing butMunger Creek was not. Availability of Recotds • Permit Application Package could not be located and had appazently been borrowed by Utah Office personneLor a consultant to LEI. A complete and current copy of the permit application volumes must be maintained at the mine office, updated promptly as revisions are approved. Active revision files should also be maintained at the mine office. • The temporary cessation notice on file is out-of--date, and should be replaced with the updated version. • Required compaction test results and P.E. certification for the coal material placed at Munger Bench were submitted to DMG but not yet on file at the mine office. The documentation should be placed on file at the mine office promptly. • 2002 Annual unpoundment certification needs to be submitted and placed on file For the SAE sediment trap impoundment. Roads and Hydrologic Balance • There was a trickle of flow in Munger drainage near the mine bench, but creek was dry further down. The main sedunent trap impoundment for the mine bench area appeared to be properly maintained. The trap contained a shallow pool several feet below the outlet pipe, and was still frozen. Some clean- out grading is needed along the containment ditch leading to the SAE impoundment. • Along the access road, inlet sump cleanout was warranted at Culverts #3 and #4. Culvert outlet tubes appeared functional. • There was some rill erosion along the short two track road segment leading to the tosoil stockpile adjacent to the lower segment of the mine access road. Water bazs should be constructed along the short road segment, or the segment should be scarified and seeded. • At the end of the short road segment, the soil stockpile undisturbed drainage diversion needs to be better defined. Backfilling and Gradine Operator had initiated spreading of cover soil over the compacted coal material on the mine bench, but had been unable to complete the work because of remaining wet azeas. The extended abatement deadline to cover the coal material with soil andreseed with approved stabilization seedmix is April 21, 2002. Offsite Support Facilities The Munger Loadout site was cleaned up and reseeded in the fall of 2001. Site perimeter berms and the silt fence sediment trap were intact and functional. No germination of seeded vegetation to date.