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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 />Coal Processing Waste General Observations <br />• At the time of inspection, processing waste was being hauled to the temporary storage pile within the <br />RP-SA area. Material from the temporary pile was spread and compacted on adjacent azeas of RP-SA <br />last fall, but over the winter refuse material has been hauled to the temporary pile. <br />• At the combined pile, a significant portion of the upper lift was spread over the top of the pile last fall <br />before the first significant snowfall, but wet conditions thereafter prevented fmal grading and <br />compaction of the lift. This grading and compaction is to be conducted as soon as conditions allow <br />this spring. Grading will also be conducted to eliminate the oversteepened crests of the combined <br />pile, and rilled outslopes need to be graded and roughened. <br />• Operator was cautioned regarding the need to keep the large expanses of active refuse azeas watered <br />down to control dust. Already this spring, the heavilytravelledmute from the refuse haul road onto <br />the temporary refuse stockpile was dry enough that some dust was being generated, and more frequent <br />watering of the truck route was needed, <br />• Portions of the future Refuse Disposal Area SB were walked. Area SB would be the next sub-area to <br />be opened. Areas of deeper soils along toe slopes and swales were characterized by a significant <br />component of cheatgrass, and prairie dog buttows were present in some azeas. The shallow soils <br />higher on the ridges were dominated by native shrubs and grasses. <br />snort Facilities <br />• At the East Portal reclamation area, ground had only recently thawed such that the remaining berm- <br />break" filter fabric outlets could be installed. Materials were on site and operator indicated that <br />installation would be completed promptly, in accordance with approved design. Conditions were <br />otherwise generally as described in the March inspection report. It was noted that a few roof bolts had <br />been left projecting from the sandstone above thebackfilled portal, and these should be cut. <br />Disturbance along the old road along the Scullion channel from equipment used to access the site for <br />power line removal and hydro-mulching operations remains evident. Operator indicated the route had <br />been seeded following completion of reclamation operations. Power pole holes still need to be filled <br />in. <br />• West Mine Vent Shafr (WMVS-1) installation had been completed. Site grading needs to be <br />completed to fill in the mud pit, restore the access road through the site, and install final perimeter <br />sediment control berms and sediment traps for the pad area. <br />• At Overland Conveyor Transfer Station #1, the main culvert inlet sump was nearly full andclean-out is <br />warranted. Clean-out of the culvert outlet sump and replacement of the adjacent straw bale sediment <br />check is also needed. <br />• In the D-Portal facilities area, a couple of drums containing fluidwere located immediately adjacent to <br />the concrete used oil recycle storage bunker. Several additional barrels of coagulant were noted on the <br />wash plant bench beneath the conveyor, near the lower process pond. All such fluids need to be stored <br />within the designated storage locations. <br />• Some maintenance to better define the perirne[erberm on the wash plant bench in the vicinity of the <br />thickener tank was noted to be necessary. <br />• Ditch maintenance and general site clean-up was needed in the vicinity of the conveyor structure <br />immediately north of the slot storage bench. Also, grading is needed to better define the ditch and <br />