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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 <br />inspection and the facts or evidence supporting the enforcement action. <br />This was a partial inspection of the Deserado Mine conducted by Susan Burgmaier and Dan <br />Mathews of DMG. Dave Anderson and Gordon Bel] of WFU were present during the <br />inspection. Weather conditions on the site were clear, warm, and windy. Ground conditions <br />were dry. <br />The mine has recent)y started mining coal again, after a January fire precluded mining. <br />Production has been limited, so coal is still being hauled in from an outside source and <br />tamed out by rail, and probably will be until at least May 15, 1996. <br />The focus of the inspection was the refuse area drainage systems. Refuse piles 2/3, 4, and <br />5 were inspected. <br />RP-SA <br />No refuse was being placed in this area during the inspection. Refuse in the pile was <br />graded. <br />A raptor perch guard (to prevent electrocution) had been installed on the power pole at the <br />upper west end, as directed in the previous inspection report. <br />The pile has a collection ditch on either side of the pile, and a diversion ditch on the west <br />side. "In-pit" ditches are in place along the edge of the refuse, which serve to direct runoff <br />from the pile into Pond SA. The in-pit ditches are interim structures, which will be used <br />until the pile reaches final elevation and drains to the final diversion ditches. <br />The collection ditches and the diversion ditch had not been seeded. The operator indicated <br />that, since these ditches were not yet being used, final construction was not warranted. <br />Division personnel pointed out that since runoff is not presently being directed through the <br />ditches, this would be an ideal time to finalize their construction. The reason being that the <br />ditches would be well vegetated and stable when the pile was complete, resulting in less <br />sediment at pile closure from runoff being directed to a bare channel. The operator <br />indicated the ditches will be seeded this Fall. It is recommended that the operator apply <br />an erosion control mat at the time of seeding to prevent the seed from being washed down <br />into the pond, and to enhance stabilization until vegetation is established. <br />The collection ditches and the diversion ditch were partially armored, with riQ rap sections <br />and check dams. The rock used for the rip rap lined sections was rounded river rock; not <br />angular. In addition, the rock had not been placed properly, in that there was a single layer <br />of similar sized (4") rock. The rock should have been graded from gravel sized particles up <br />to the Dm,~ of 7. ", with 50% of the rock sized at 6". Check dams, also of 4" river rock, were <br />just piles of rock at regular intervals in the ditch. The channel, at the check dam locations, <br />was less than the required design size since the rock Partially filled the ditch. The check <br />dams should have been installed as described above, with the ditch excavated below, so that <br />the capacity of the ditch is as designed the entire length of the ditch. The operator <br />indicated this work would be done, the timing of which and design details will be specified <br />in the pending Technical Revision 39. <br />Deserado Mine 1 May 3, 1996 <br />