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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 />This was a partial inspection conducted by Kent Gorham of the Colorado Division of Minerals <br />and Geology (DMG). The weather was hot and humid warm and ground conditions were <br />wet and muddy in places. Access was good to all areas by vehicle and foot. Bobby Steele <br />and Ron Thompson represented Lorencito Coal Company (LCC) during the inspection. <br />Roads <br />Road culverts along the Lorencito Canyon haul road were clear of debris and appeared <br />functional. Culvert inlets along the Jeff Canyon haul road were also found clear of sediment. <br />Recent storm runoff appears to have passed with little or no damage. Road ditches along <br />the reconstructed portion of the haul road across the disturbed area had been recently <br />cleaned of sediment deposition. <br />Hydrologic Balance <br />Silt was cleaned from the weir boxes at pond 8 and pond 9. Pond 9 riser was plugged at the <br />lowest hole due to debris from recent storm runoff. Following cleaning of the weir box, the <br />riser was cleared of vegetation and discharge of about 40 gallons per minute began. This <br />flow was slightly cloudy but appeared in compliance with the alternate limits for settleable <br />solids. Pond 8 held water at an estimated 1/3 capacity. It was some four feet below the <br />lowest discharge point on the primary riser. Vegetation on both pond embankments is <br />improving greatly due to excellent growing conditions. <br />Modification of road drainage is still necessary along the permanent road north of the un- <br />mined "center core" area. Flow at the former ramp constructed to access areas north of the <br />roadway should be channeled into another channel so it can pass safely to pond 8 or pond 9. <br />A small breach was also noted on the upper most diversion ditch on the north slope. It <br />appeared that despite these drainage issues, all flows entered constructed sediment ponds <br />and did not leave the site untreated. <br />Backfilling and Grading <br />The operator has completed work on the permanent drainage on the east side of the <br />reclaimed area. This ditch was the last remaining work to be completed as documented in <br />the Phase I bond release inspection conducted April 6, 2004 with follow-up inspection on <br />June 14, 2004 (see DMG inspections for these dates). The ditch has been re-shaped and <br />the freeboard increased where flow is directed into a riprap channel to pass to Fill 9 <br />downdrains and ultimately, to Pond 9A. Some sedimentation from recent runoff is evident at <br />the intersection but flows appear to have been handled adequately. Sideslopes will require <br />topsoiling and seeding to complete reclamation in this area. However, for Phase I bond <br />release criteria, the work appears complete. <br />3 <br />