INSPEC14601

• Permit No: C1981041
• IBM Index Class Name: Inspection
• Doc Name: Inspection Report
• Inspection Date: 9/9/2002
• 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.
The problem with the non-functioning collection pipe leading from the mine bench collection drains to
Pond 8 had not been resolved prior to the end of the inspection on September 13, and as a result the NOV
was issued.
NOV CV-2002-019 was issued forfailure to conduct mining and reclamation operations in a manner to
minimize erosion. More specifically, failure to maintain light use road to control or prevent erosion and
siltation, and failure to employ proper haul road drainage control measures to control or minimize erosion
and siltation.
The NOV was issued for erosion that occurred in two separate locations. The first location was observed
on the afternoon of September 9 (designated Location 2 in the NOV). Gullies had been eroded on both
sides of the lower end of reclaimed Haul Road 2, immediately south of the channel of Coal Creek. The
road segment had been backfilled and graded eazlier in the summer, and is scheduled to be revegetated this
fall. It was appazent that the erosion resulted from concentrated flow from a drainage relief ditch
associated with the neazby Haul Road S, located further up-gradient to the south. Flow from the ditch
discharged drrectly onto the reclamation backfill. There was minor rilling and washing along upper
portions of the backfilled segment, with gullies developing on lower, steeper segments of the backfill
adjacent to Coal Creek. The larger gully was on the west side of the reclaimed road, and was
approximately 12-1 S wide and 12-18 deep, approximately 30 feet in length. The smaller gully on the
oppposite side of the road was approximately 6 [o ] 0 deep, and approximately I S feet in length.
The second location was observed on the morning of September 10 (designated Location 1 in the NOV). A
gully averaging approximately 3 to 4 feet deep by 18 wide, extended for a distance of approximately 40
feet down a temporary road segment on a steep cut slope of a soil borrow area. The borrow area had been
excavated to obtain soil for Roadside Refuse Disposal Area (RSRDA) non-toxic cover. The borrow
excavation had been completed and topsoil replaced eazlier in the summer, but the site had not yet been
seeded. From the lower end of the gully, areas of minor washing, intermittent deposition and minor rilling
extended across the relatively flat bottom of the borrow excavation. The cause of the gully was
concentrated flow along a segment of Light Use Road 1. The lower segment of the road had been
temporarily extended to the bottom of the borrow azea, and the gully incised in a wheel rut on the steep
slope.
Availabiliri of Records
Records were checked on September 12, and found to be complete and up-to-date through the 2nd quarter,
2002. Since the previous complete inspection, the Division has received appropriate construction
certifications for the Coal Creek permanent diversion channel segment and the recently constructed
Sediment Pond 13, and these certifications were on file.
The operator was reminded that the annual rill and gully survey for 2002 had not yet been completed, and
that certification of the various recently completed permanent perimeter ditches and upland diversion
ditches associated with RSRDA, CRDA-1, and CRDA-2 refuse areas would need to be provided.
Signs and Markers
Soil stockpile signs had been replaced as requested on the remaining portions of Topsoil Stockpiles 1 and 2
at the North Portal Area.