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<br />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 />General Comments <br />This was a partial inspection of the surface facility at the McClane Canyon Mine. The inspection <br />was conducted by Dan Mathews of the DMG Grand Junction Field Office, accompanied by Walter <br />Whitledge, Mine Manager. Weather was clear and mild. Coal was being conveyed out of the <br />mine onto a relatively small coal stockpile during the inspection. <br />NOV Status Update <br />One enforcement action (NOV CV-2005-008) had been issued on October 26, 2005, following the <br />Division's inspection of October 25. The NOV was issued for failure to maintain upland diversion <br />and haul road culverts; three of which were found to be completely or partially blocked by <br />sediment during t;he 10/25/05 inspection. One additional haul road culvert (Culvert "J") was found <br />to be more than Yz blocked by sediment at its upper end during the inspection on November 1. <br />This culvert blockage had apparently been missed on the previous inspection, and the NOV was <br />modified to include Culvert "J" on November 1. The NOV abatement deadline had previously <br />been extended to November 18, and based on an extension request letter of November 18, the <br />abatement deadline was extended for a second time, with an extended abatement deadline of <br />November 25, 2005. <br />Blocked culverts cited in the NOV had been fully cleaned out prior to the inspection, with the <br />exception of the 42" diversion culvert "D", which is a buried culvert that conveys flow from the <br />main southeast tributary of McClane Creek. The operator reported that the clean-out had been <br />largely completed by manual labor, but several days prior to the inspection, another intense rain <br />storm in the watershed had generated flow down the drainage, and additional sediment was <br />deposited in the culvert. At that time, the operator contacted a utility locating service, and <br />arranged to have a vacuum excavator truck and crew perform the clean-out. The vacuum truck <br />operation was in progress at the time of the inspection, and steady progress was being made, <br />using a high pressure water jet mechanism, in combination with a large vacuum device which <br />sucks the hydraulically dislodged sediment into a large tank on the vacuum truck. <br />Roads <br />Road surtaces were generally well maintained, and road culverts "H" and "J", which had been <br />cited in NOV 008, had previously been restored to design condition. <br />Road ditches in a couple locations have scoured and sidecut in a couple locations as a result of <br />recent heavy runoff events. One segment that has been scoured is the upper segment above the <br />outlet of Culvert I, along the MSHA berm. The second segment is downstream of the "in-ditch" <br />settling basin, immediately upstream of the sediment pond. Riprap stabilization of the ditch <br />bottom and sides appears to be warranted in these locations, to prevent further down- <br />cutting or side-cutting erosion. <br />There was some sediment accumulation in the inside road ditch at the road curve down-gradient <br />from the outlet of Culvert I, in the immediate vicinity of the steel gate. This ditch segment needs <br />to be maintained to remove the accumulated sediment. Removal of the gate post would <br />improve ditch functioning and facilitate maintenance, and is recommended. <br />