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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. It was noted that the Permit LD. sign at the entrance to the North Portal Area had blown over or been knocked down. The sign will need to be replaced. Roads Drainage problems and resultant erosion associated with a segment of Light Use Road 1 above the RSRDA soil borrow azea, and Haui Road 5 neaz the Xcel Dozer shed were cited in NOV CV-2002-019, and relevant observations are described in a previous section of this report. Rill erosion was observed along the segment of Light Use Road 1 between the R5RDA Soil Borrow Area and the South Porta] Facilities Area, and maintenance is warranted. Specifically, water bars along this segment of road that were removed to accommodate equipment traffic during cover soil hauling operations need to be re-constructed. At the North Decline, a culvert was recently installed to replace the road dip at the upper gate, per approved minor revision. The road dip had required frequent maintenance. Maintenance of straw bale checks and segment of berm is warranted at the lower dip section road crossing on Coal Creek. l~drologic Balance RSRDA and South Portal Area 1 Apparent break in the disturbed area collection pipe system that conveys drainage from the South Mine Portal Bench parking azea to Sediment Pond 8 is the subject ofNOV CV-2002-018, and relevant observations aze described in a previous section of this report. • A separate buried PVC pipe conveys disturbed azea drainage from a collection sump on a road segment immediately west of the South Mine Portal Bench parking area, down to Sediment Pond 8. On Monday, September 9, operator discovered that the pipe had become plugged, and storm flow over the weekend had filled in the collection sump with sediment and runoff. Water level in the sump Monday afternoon was approximately 12 inches below the top of the road berm, and water marks on the berm indicated that maximum water level had reached approximately 6 inches below the top of the berm. Operator employed a contractor to de-water and excavate sediment from the sump, and attempt was made to open up the blocked pipe with high pressure hose, but the attempt was unsuccessful. As a temporary measure, operator laid a 6 inch hose from the sump, through the road berm and down to the rip-rapped collection ditch at the base of the slope, which leads into Pond 8. The hose had been installed by Thursday, and was observed during re-inspection of the site on Friday morning. DMG requests that permanent repairs or replacement of the buried pipe with an approved alternative conveyance be implemented in a timely manner. I[ an alternative design is selected, appropriate technical revision shall be submitted by September 30.2002, and installation shall be completed within 20 days of final approval If operator chooses to repair the ezistiog pipe without modification, the cause of the failure to function as designed will need to be assessed, adequacy of the design confirmed, and repairs completed by October 15.2002. Pond 8 contained a few puddles on Sept. 9, and Pond 9 held a shallow pool from storm runoff over the weekend.