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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~lring the inspection <br />and the facts or evidence supporting the enforcement action. <br />for the site, and subsequent sampling by the operator indicated typical levels, within permit <br />limits. Operator deduced that the reported values were likely erroneous, resulting from <br />analytical error. In a letter dated April 2, 2003, the Water Quality Control Division indicated <br />that the explanation was adequate, and that no enforcement or further corrective action <br />would be required unless there was continued non-compliance. <br />Hydrology Maintenance Items <br />1) One section of silt fencing at the South Fan reclaimed area had minor tears, and needs to <br />be repaired or replaced. A stake was broken on one of the silt fence segments at the <br />reclaimed Substation B. Silt fencing at the 016 minewater discharge site had been undercut <br />in a couple locations. The fence needs to be re-set and anchored to prevent washout <br />beneath the fabric. <br />2) Inlet ditch at the south end of Sediment Pond 2 had eroded and should be stabilized <br />3) Some build-up of the SAE berm within the reclaimed Topsoil Pile 7 location, adjacent to <br />Haul Road 4 (north side of the SAE) is warranted. It was discussed that, when vegetation <br />is successfully established and berm removal is approved, some finish grading will be <br />appropriate along the south side of the SAE to blend the reclaimed SAE area into the <br />adjacent Coal Creek channel bank, eliminating the several abrupt slope transitions. <br />4) The area between the toe of the RSRDA refuse pile and Pond 8 had been graded to <br />provide positive drainage into Pond 8, and the flex pipe that conveys seepage from the <br />portal area had been extended further down the RSRDA North Perimeter Ditch. The <br />drainage in this location had been improved as a result, but there is still wet ground along <br />the lower section of the ditch below the flex pipe outlet, apparently due to seepage from <br />the ditch. The operator indicated the piping would be extended at least another 20 feet so <br />as to discharge directly into the steep Pond 8 inflow channel, rather than the flatter ditch <br />segment where the pipe currently ends. It is likely that this measure will eliminate the <br />apparent seepage problem. <br />5) Pond 9 was dry, with sediment level approximately 8 to 12 inches below the primary <br />spillway inlet elevation. The 1" quarter 2003 sediment pond report noted that survey <br />indicated sediment volume in the pond was approximately 65% of capacity. The report <br />correctly noted that sediment cleanout should be undertaken this field season. <br />6) Some down-cutting had occurred along the berm/ditch leading to the north inlet of Pond <br />13, at the North Portal reclaimed area. The lower 40 foot segment of ditch had eroded up <br />to 15" deep. The segment needs to be repaired and properly stabilized. <br />Backfillina and Gradin <br />Backfilling and grading was visually assessed in the various areas where such work was <br />completed during 2002 or previously. All of these areas have been permanently seeded. In <br />general, the regraded areas appeared to be stable, with no excessive erosion or indications <br />of mass instability. Specific reclaimed areas are addressed below. <br />