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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 />Since the September 6, 2001 aerial inspection, I conducted three site inspections at the Roadside Mine, the <br />first on September 25, the second on October 16, and most recently on October 25. Summarized below are <br />the observations I made during each of the inspection visits. <br />September 25, 2001 <br />Inspection was conducted during the late afternoon, early evening. Considerable progress had been made <br />with respect to dismantling/demolition of the wash plant facilities at the South Portals area lower bench, <br />and with respect to regrading at CRDA-2, since I had last been to the site on August 24. <br />Wash Plant Area <br />At the South Portals lower bench area, most of the steel wash plant structures and conveyor structures have <br />been demolished, with numerous large piles of metal and other debris in various locations. The remaining <br />intact wash plant structure is the rectangular one story building (approximately 100 feet long by 40 feet <br />wide) immediately north of the thickener tank. The thickener tank has been partially demolished, with a <br />portion of the concrete wall still standing and some metal conveyor support structure remaining. The Nl <br />conveyor transfer building and baghouse had been separated from its foundation and pushed down. <br />Concrete building foundations and concrete structure associated will[ coal reclaim tunnels and the refuse <br />truck loadout tunnel remain intact. Other structures remaining intact on the lower bench include thetwo <br />story cafeteria/trainingbui1ding, the lab facilityAhowerhouse, the office trailer and other small building <br />behind the lab, and the guard shack. The demolition contractor was at the site, with work continuing. <br />Refuse Area CRDA-2 <br />The amended reclamation plan for CRDA-2 calls for substantialregrading along the upper perimeter of the <br />active bench (top of pile), to allow for installation of a new 100 year design upper diversion. The diversion <br />would consist of two wings extending at a 2.5% gradient from a starting point immediately above the <br />center portion of the pile. Approved design cross-sections depict a roughly "V" shaped excavation along <br />the upper perimeter of the refuse, within which theriprapped diversion channel will be installed. Design <br />dimension of the excavation varies from approximately 15 to 20 feet deep, with an approximate top width <br />of 40 to 50 feet. Design dimension of the riprap channel within the excavation is trapezoidal with3 foot <br />bottom width, 2:1 side slopes, and 10 foot minimum depth. Each wing of the chawel would extend to <br />natural drainage chutes at either end of the pile, to the outside of the existing disturbed area sediment <br />collection system. The top of the pile itself is to be graded to drain towardthe outslope at a 2% grade. A <br />final component of the grading, after completion of the new upper diversion, would be to eliminate the <br />existing upper diversion. <br />Based on my observations yesterday, substantial progress has been made in regard toregrading of the top <br />of the pile and excavation along the upper perimeter in preparation far installation of the new upper <br />diversion. The new upper perimeter excavation currently varies from approximately 6 feet deep by <br />approximately 35 foot top-width at the mid-point, to approximately 18 feet deep by SO feet top-width at the <br />lower ends of each "wing". Some additional excavation and possibly some blasting of sandstone outcrop <br />would appear to be necessary to achieve final design dimensions and grades. Also, the excavation <br />currently does not extend beyond the existing perimeter sediment collection ditches along the sides of the <br />