INSPEC16580

• Permit No: C1980007
• IBM Index Class Name: Inspection
• Doc Date: 2/4/2002
• Doc Name: COAL INSPECTION REPORT
• Inspection Date: 1/30/2002
• 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 in Section IV describe any enforcement actions
taken during the inspection and the facts or evidence supporting the enforcement action.
The single purpose of this inspection was to preview a proposed 5,750-foot-long
access road alignment up Sylvester Gulch, but alternative alignments were
discussed.
An introductory meeting was held with the following persons in attendance: Phil G.
Schmidt and Henry A. Barbe of Mountain Coal Company L.L.C (MCC); Thomas
Griepentrog of Buckhorn Geotech; Kimberly Kaal, George Goehl, Doug Marah, and
John Williams of the US Forest Service; and Byron Walker of the Division of Minerals
and Geology (Division). The meeting was opened by Mr. Phil G. Schmidt who
explained the purpose and need of the project. Mr. Henry Barbe then made a few
comments on the project, including identification of some reservations MCC had of
the current alignment, Mr. Doug Marah then outlined some of the concerns and
requirements of the U.S. Forest Service, with comments by others. Some typical design
criteria were to use as narrow a road as feasible (14') with in-sight turnouts (10' wide,
50 to 100' long with 25' to 50' transitions), curve widening, 2% in-slopes of the
roadway, use of guardrails in lieu of berms, armored drainage features, avoiding the
use of culverts, and design storms for constructed drainage crossings. Ms. Kimberly
Kaal's comments were primarily geotechnical in nature. Both Ms. Kaal and Mr. Barbe
discussed problem experiences with road work in the lower reaches of Sylvester
Gulch. Mr. Byron Walker explained that to date the Division was looking at the
proposal as an access road (frequent traffic (more traffic density than that of a light-
use road) but not a haul road for coal, spoil or coal mine waste (see Rule 1.04(111)).
With the exception of Rule 4.03.2, rules referenced are provided (extracts) at the end
of this comments section. Mr. Walker provided a copy of Rule 4.03.2 (access roads) to
Mr. Marah during the meeting. Mr. Walker advised that fords in lieu of culverts might
be permitted (see Rule 4.03.2(2)(e), but some culverts may be appropriate (see Rule
4.03.2(4)(e)). If so, the culverts would be inspected (by the operator and Division) and
be maintained by the operator, and removed if required by the approved
reclamation plan. Reclamation of the proposed road was discussed. Reclamation
requirements (Division) are outlined in Rule 4.03.2(7). Reclamation of the proposed
road (and alternative routes discussed later) appeared to be feasible, but might
require special handling of topsoil, backfill, etc. Mr. Marah asked if the road had to
be reclaimed or if it could remain. Mr. Walker advised that there was potential for
retention if the road was approved as part of the approved postmining land use and
met other requirements (see Rule 4.03.2(1)(g)). Land uses are described in Rule
1.04(71). Postmining land uses are the subject of Rule 2.05.5. Alternative land uses are
the subject of Rule 4.16.3. Mr. Marah asked if something less than the road as
designed could be left, Mr. Walker advised yes, and that there was precedence for
such reclamation (see an extract (page 2.05-61) from the Permit Application
Package for Permit C-81-019 attached). Removal of culverts might be part of partial
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