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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 d~uing the inspection <br />and the facts or evidence supporting the enforcement action. <br />This was a complete quarterly inspection of the Roadside Mine facility areas and office <br />records, conducted by Dan Mathews of DMG. Records were inspected on the afternoon of <br />3/25/03; field inspection was begun on 3!26/03 and concluded on 3/31/03. I was <br />accompanied on the inspection by Tonya Hammond of Snowcap Coal Company (SCC) on <br />3/25 through 3/28, and was unaccompanied on 3/31. Ms. Hammond assisted with the <br />collection of refuse slope, ditch, and channel measurements included in this report. <br />Weather conditions during the course of the inspection ranged from cloudy and cool to clear <br />and mild, with no significant precipitation, although there were brief rain showers and snow <br />flurries. There had been a fairly intense rain/hail storm in the mine vicinity the weekend <br />prior to initiation of the inspection. Winter and spring precipitation so far has been at or <br />above normal levels. <br />This report is organized into three major sections; (11 Topic Specific Observations, (2) <br />Refuse Area Slope and Terrace Drain Measurements and Compliance Evaluation, and (3) <br />Ditch and Channel Measurements and Compliance Evaluation. The refuse pile slope <br />measurements, ditch measurements, and channel measurements will assist in the evaluation <br />of compliance associated with the Phase I bond release currently under review. Slope <br />measurements on the CRDA-1 and CRDA-2 refuse areas focused on the upper benches that <br />were reclaimed during 2002, because extensive measurements documenting compliance of <br />the lower benches were taken during a special focus inspection in August 1997 (see DMG <br />inspection report dated 8/29/97 and addendum of 10/17/97.) <br />TOPIC SPECIFIC OBSERVATIONS <br />Availability of Records <br />Records were checked at the offices of J.E. Stover and Associates on 3-25-03. Required <br />records were on file and up-to-date through the 4'" Quarter, 2002. See DMG records form <br />attached. <br />Roads <br />Roads were in generally good condition, however maintenance is warranted in several <br />locations to repair minor rutting, rills at certain ditch relief drain locations, and sediment <br />accumulations in certain ditch segments. Specific locations noted include: <br />Road Maintenance Items <br />11 An apparent piping type erosion feature was observed along the side of the permanent <br />road within the North Decline reclaimed area; approximately 50 yards down the road from <br />the upper boundary gate. The hole, approximately 18" in diameter and at least several feet <br />deep should be filled in. <br />2) The lower section of the North Decline road ditch, extending from the vicinity of Pond 7 <br />down to the lower boundary of the disturbed area, exhibited washing and tilling from recent <br />